In The Court Ofadditional Session Judge, Distt. East Karkardooma Court, Delhi in The Matter of
In The Court Ofadditional Session Judge, Distt. East Karkardooma Court, Delhi in The Matter of
EAST
KARKARDOOMA COURT, DELHI
Sir,
It Is Respectfully Submitted As Under:-
That as per the story of the prosecution on 17th June 2017 the
allegations levelled against the accused are that at the said house
on the pretext that if she go out of the said house, accused will
finish his family and accused also asked her to sign on plain white
papers.
1. That the I.O. in this case did not investigated the matter properly, she
bring the true facts and conduct of the applicant which proves the
the accused that she was confined in the said house by the accused
where accused raped her, treated her without courtesy and moreover
beaten her. But, on the other hand it is admitted fact by the prosecutrix
3. That the prosecutrix and accused were enjoying each other’s company
4. That the entire case of the prosecution is mere abuse of process as there
motives.
5. That it is also very pertinent to mention here that the allegations made
inference can be drawn on the basis of this, that the act of making
a balance , the good and evil on each side, with the existing capacity
years consent is not ruled out and conviction for rape is not possible.
6. *****The factual situation comes under the four corners of judgment
Sadashiv Ramrao Hadbe vs. State of Maharashtra & Anr.’ 2006 (10)
SCC 92 "It is true that in a rape case the accused could be convicted
set up by the prosecutrix, the court shall not act on the solitary
happen."*******
7. That the prosecutrix did not give any explanation about the Why the
delay of around 15 days was made by her in lodging the F.I.R? This
Court Of India and other Hon’ble different High Courts which states
that the delay in lodging the F.I.R must be explained as it raises clouds
8. That it is pertinent to give in your notice that in the whole episode (i.e.
and was connected to the accused and whole world via calls and
internet. Hence, this is ruled out that she was confined in the said
house.
9. In State vs Sandeep Tiwari @ Ansul Tiwari on 10 August, 2016 the
two adults of opposite sex with their free and voluntarily consent is
records that the prosecutrix was not found any fresh injury.
10. That the applicant is residing at the above address with his family and
absconding or flee from justice and the same inference can be drawn
Hon’ble Court and have full faith on the Court of law. Hence the
into consideration that the accused has his roots in the community and
11. That the accused/applicant has clean and unblemished antecedent and
never involved in any criminal activities nor convicted in any case and
is ready to furnish the sound surety before this Hon’ble Court if release
on bail.
12. That the accused applicant undertakes to appear before this Hon’ble
Court on each day, if released on bail and this Hon’ble Court may
bail.
PRAYER:-
Delhi: Applicant
Dated: Through
Mahesh Sharma
(Advocate )
IN THE COURT OF DISTRICT & SESSION JUDGE, DISTT. SHAHDARA
R/o WA161-AShakarpur
Ph.9717015147
P.S. Shakarpur
INDEX
S.No. Particulars Page No.
1 Bail Application
3 Vakalatnama
Applicant
Dated
Delhi Through
Counsel
Mahesh Sharma
(Advocate)