Application Under Section 438 of The Code of Criminal Procedure 1973 For Grant of Anticipatory Bail

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IN THE COURT OF THE PRINCIPAL SESSIONS JUDGE

TIRUNELVELI

Crl. M.P. No ______ OF 2023

Valathi D(aged 33 /2023)


S/o Duraipandi
1/125 Maravar Colony Street
Rajavallipuram
Tirunelveli–627359 ..….. Petitioner/Accused No.2

-Vs-
State : The Inspector of Police
Thalaiyuthu P.S
Crime No. 332 of 2023 ….. Respondent/Complainant

APPLICATION UNDER SECTION 438 OF THE CODE OF CRIMINAL


PROCEDURE 1973 FOR GRANT OF ANTICIPATORY BAIL

1) The Applicant approaches this Hon’ble Court with the prayer that this Hon’ble
Court may be pleased to release the Applicant above named on bail on any suitable
terms and conditions, as this Hon’ble Court may deem fit and proper, in the event of
his arrest in connection with the Thalaiyuthu P.S with Crime No.332 of 2023
registered under sections 294(b), 323 & 506(2) of Indian Penal Code.

2) The alleged occurrence is said to have taken place within the respondent police
limit on 28.10.2023 at 05.00 PM and the matter was reported to the respondent police
on the same day.

3) The case of the prosecution, in brief, is that four people went to Tamirabarani River
side, Rajavallipuram to cook and eat food. During the course of cooking, the
complainant’s elder brother(hereinafter referred to as victim) abused Accused 1 and 2
who in turn attacked the victim and abused him with filthy languages. The
complainant got information through his relative and admitted the victim in the
hospital by calling 108 Ambulance and registered the complaint with the respondent
police.

4) It is submitted that there is no blood injury to the complainant and he was not even
admitted to the Government Hospital rather he was being treated only as OP and
discharged from the hospital on the same day.

5) It is submitted that the police have falsely implicated the Petitioner/Accused No.2
in the present case

6) It is submitted that the petitioner is not having any criminal cases and belongs to a
good and respectable family.
7) It is submitted that there is no likelihood of tampering with the evidence or
influencing/ intimidating the witness. The petitioner shall not leave his residing place
and the petitioner shall made himself available for interrogation in course of further
investigation, as and when required.

9) Hence the petitioner is not required in any kind of investigation, nor any custodial
interrogation is required and no recovery can be made out at the instance of the
petitioner.

9) It is the first Anticipatory Bail application and no similar application is pending


before Hon’ble High Court of Madras, Madurai Bench.

10) It is also submitted that the petitioner will not evade the process of law if he is
released on bail. Further, the petitioner is ready to offer adequate sureties for his
release on bail.

It is therefore prayed that this Hon’ble Court may graciously be pleased to pass an
order to enlarge the petitioners/accused on bail in the event of their arrest on such
terms and condition as this Hon’ble Court may deem fit and proper and thus render
justice.

MS 7102/2022
Date : 30.10.2023 ADVOCATE FOR THE PETITIONER

SIGNATURE OF THE PETITIONER


IN THE COURT OF THE
PRINCIPAL SESSIONS JUDGE,
TIRUNELVELI
Crl. M.P. No ________ OF 2023

Valathi D
…….. Petitioner/Accused

Versus

State Through Inspector of Police,


Thalaiyuthu P.S in Cr No. 332 of 2023

------------------------------------------------
APPLICATION UNDER
SECTION 438 OF THE CODE
OF CRIMINAL PROCEDURE
1973 FOR GRANT OF
ANTICIPATORY BAIL
-----------------------------------------------

Advocates for the Petitioner


S.Thangapalanikumar
MS 7102 of 2022
Vivekanandan.A
MS 3949 of 2021

Address
2/122 Thangamman Kovil St,
Kuppakurichi,
Burkitmanagaram Post,
Tirunelveli-627351
Ph : 9791322420

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