IN THE COURT OF THE DISTRICT & SESSIONS JUDGE, AGRA

Misc. Application No…………../2010
Shri __A__ B __ C __…………. )………….Applicant
Age 36 years, occupation – social worker,………….)
Resident of 235 Parsi Gymkhana,……………………….)
MUMBAI 400 021.
Versus
The State of Maharashtra……………………………………) _ Opponent
ANAPPLICATIONFORTHEGRANTOFBAILU/S 438 OF THE CRIMINALPROCEDURE CODE 1973
The applicant above-named submits this application, praying to state as follows:
1. That the applicant is a social worker and active member of the Shiv Sena Party.
2. That the applicant has been serving the cause of society for the last more than twenty-five
years.
3. That during the recent by-election to the MUMBAI Municipal Corporation in Ward No. 50, the
applicant got elected with a large number of votes against his rival candidate, Shri XYZ, who
belongs to the Congress- I Party.
4. That during the election campaign, there were a great many allegations made by the members of
both the parties, and the said Congress- I candidate tried his best to make all the malicious
attempts with a sole intention to defeat the candidature of this applicant.
5. That the said Congress-I candidate could not withstand his defeat in the election, and
since the date of the declaration of the election result on………….the situation as a whole has
gone bad to worse.
6. That on or about…………, a person alleged to have been an active member of the
Congress-I Party was stabbed, and he died the following day.
7. That the applicant believes that on account of such unhealthy political activities
indulged into by the said defeated candidate, some malicious plans and designs have
been worked out with an intention so as to implicate this applicant for having committed or
concerned with such a non-bailable offence.
8. That the applicant submits that since the date of the declaration of the election result
on…………., this applicant had gone to Tirupati Balaji on a pilgrimage tour, and when he
returned back to the headquarters only yesterday night, he came to know about such an
accusation against him, and hence, this application.
9. That the applicant states and submits that he had no concerned with any such offence, if
committed by some miscreants, and the contention of this applicant will be explicit from the very
fact that this applicant was out of headquarters throughout, and thus, he is innocent, too.
10. That the applicant apprehends that he may be arrested on such an accusation, and
hence, this application.

11. That this applicant furthermore submits that if this application is not granted by the
Hon’ble Court, flagrant injustice will be done to him for no fault on his part.
12. That the applicant also believes that he will not be deprived of his legitimate and
fundamental right.
13. That the proper court-fee is paid herewith.
14. That the applicant, therefore, prays that this application be kindly allowed and orders
granting an anticipatory bail be issued in favour of this applicant.
MUMBAI,………….Sd/- ABC
APPLICANT
Dated:……………
Sd/- x X x
ADVOCATEFORAPPLICANT

VERIFICATION

I, Shri ABC, the present applicant, do hereby state on solemn affirmation that the
contents of this application in paras 1 to 14 are true and correct to the best of my
knowledge and belief, so I have signed hereunder.

Sd/- ABC APPLICANT