IN THE COURT OF HON’BLE SESSIONS JUDGE RAIGAD,

AT. ALIBAG.

Cri. Misc. Application No. /2008.

Kawaljeetsing Tirlochansing Gell

Age : 22 years, Occupation – Business,
Resident of Sai Nagar Co-operative,
Housing Society, Room No. A-206,
Sector No. 4, Kalamboli Colony,
Taluka Panvel, District Raigad

Versues

The State of Maharashtra

First Application for grant of Bail under

Section 439 of Cr. P.C. in connection with
Kalamboli, Navi Mumbai Police Station
bearing C.R. No. I 420/2008 for the alleged
offence under Section 407, 411, 34 of IPC

May It Please Your Honour :

The above named Applicant most respectfully submit as under :-

That the complaint is lodged by one Mr. Indrakant Gulab Za who is manager of Kavita
Goods Transport Company alleging that their company got tender of transporting the containers
of Appar Industries to Uran. So complainant transport those containers from Silvasa to Uran, he
engaged trailor of Geel Transport Company, Trailor No. HR 38/E-808 and container No
MEBU2708429 from Silvasa to J.N.P.T. It is alleged that applicant with the help of one Mr.
Vikas Chaudhari who is the cleaner and Ramesh who is the Driver on the said trailor make
breach of trust by misappropriating goods of Rs. 2,50,000/- from the container.
Pursuant to the above complaint the applicant was arrested on 03.10.2008 and he was
remanded to P.C.R. till 05.10.2008 and now h is in MCR.
Therefore the above named applicant most respectfully pray for grant of Bail on the
following amongst other grounds :-
1. That the applicant is innocent and has not committed any offence.
2. That the applicant is no way concerned with this alleged offence.
3. The name of the applicant is not at all mentioned in the F.I.R. as few days before this
incident, there was a murder of colleague of this applicant and at that time he marched to
the police station as the police have not arrested the accused, to take the revenge of that
incidence, the police implicate this applicant falsely in this offence.
4. The applicant is permanent resident of his address given in title clause.
5. That the main co-accused in this offence was already released on bail by this Hon,ble
Court in Criminal Misc. Application No. /2008. Hence this applicant is also
entitled for bail on the ground of parity.
6. The applicant is ready to co-operate with process of investigation and to ebide by any
reasonable conditions that this Hon,able Court may impose.
7. That nothing is to be recovered form the custody of the present applicant.
8. That a false and concocted case has been filed against the present applicant.
9. That the applicant has not committed any offence. He is innocent and law abiding citizen.
10. That the alleged offence is not punishable with death or imprisonment for life.
11. That the offence is exclusively triable by learned J.M.F.C.
12. That the application for bail was given in the court of J.M.F.C. Panvel but the same was
rejected as the offence is of serious nature ant property involved is huge.
13. That no other application for grant of Bail is pending before this Hon’able Court or
Hon’able High Court.
14. That the charge sheet is not filed.

It is therefore most respectfully prayed that the applicant may kindly be released on Bail
And concerned Police Station may be directed accordingly.
And for which act of kindness, the applicant as in his duty bound shall ever pray.

Alibag
Date : / /2008 Advocate for Applicant