Anda di halaman 1dari 27

1

BEFORE THE COUORT OF SESSIONS AT DINDOSHI,

(BOMBAY DIVISION) GOREGAON, MUMBAI

ANTICIPATORY BAIL APPLICATION NO. ______ OF 2017

IN

C. R. NO. 220 OF 2017 – (DINDOSHI POLICE STATION)

DISTRICT: MUMBAI

Application under Section 438 of Cr. P.C.

seeking Anticipatory Bail in connection

with the complaint lodged by Rajkumar

Lalchand Pande being C. R. No. 220 of

2017 alleged against the accused for

offences punishable under sections 406,

420, 120 (B), 191, 192, 193, 196, 198,

425 of the I.P.C. registered under

Dindoshi Police Station on 19th March,

2017.

ARVIND BRIJKISHOR JANGID)

@ SHARMA, aged, 50 years, )

Occ:Business, residing at 5th flr,)

Khakar House, Jai Jawan Lane )

Daftary Road, Malad (West), )

Mumbai 400 097. ) … Applicant

Versus
2

STATE OF MAHARASHTRA )

at the instance of Senior )

Inspector of Police, Dindoshi )

Police Station, Mumbai. ) … Respondent

TO,

THE HON’BLE PRINCIPAL JUDGE

AND OTHER HON’BLE JUDGES OF

THE HON’BLE SESSIONS COURT

AT DINDOSHI, MUMBAI.

THE HUMBLE APPLICATION OF

THE APPLICANT ABOVE

NAMED.

MOST RESPECTFULLY SHEWETH :

That the present applicant is a respected citizen of

India. The Applicant hails from good and respectable family

and he is having high status stature in the society. He is

innocent and he has been falsely implicated in FIR bearing

No. 220 of 2017, lodged with Dindoshi Police Station, which

was registered against him on 17th March, 2017 upon a

complaint of Rajkumar Lalchand Pande, who claims to be a

tenant of the Applicant in one his properties. The Applicant

apprehends that he would be arrested by the Respondent in

a false and frivolous case registered against him since past

3 to 4 days. The applicant is receiving phone calls from


3

Dindoshi Police and he is forcibly called to the Police

Station, therefore, there is a strong apprehension that the

office bearers of the Dindoshi Police Station, especially one

API, Ravi Adani, would arrest him in connection with the

FIR No. 220 of 2017. A copy of the FIR along with the

Statement dated 1st February, 2016 is annexed herewith

and marked as Annexure “A”.

The prosecution case in brief is as follows:-

(1) It has been alleged that the Applicant, Arvind

Ramkishor Pande, is residing at address mentioned in his

statement dated 1st February, 2016 since last 40 years,

whereas his wife, Ushadevi, sons Ashish Pande, Rahul

Pande, and Vishal Pande are residing in Kashimira along

with the Sister-in-law of the complainant. It is also alleged

that he is residing at Shashi Mangalam School as he is

employed as Bus Driver over there and his residential

building is been demolished since last 2 years and his

family members are residing at Kashimira on a temporary

basis.

(2) It has been alleged that in the year1973 the

complainant came to Mumbai for the first time and

therefore he started residing at Rashmi Kunj building,

Room No. 403, S. K. Patil Road, Daftary Road, Malad (East),

Mumbai 400 097. The building in which the complainant


4

was residing was 1st storey building and in that building all

together 58 tenants used to reside. The above mentioned

building was owned by one Babubhai Mehta, and through

him the father of the complainant i.e. Lalchand Gopinath

Pande had leased room No. 403 as tenant.

(3) It has been alleged that the above mentioned Rashmi

Kunj building was initially owned by one Mrs. Hasumati

Ishwarlal Mehta and she had constructed the building in

the 1962. It is further alleged that the said Rashmi Kunj

building was thereafter sold to one Mr. Babubhai Mehta

and hence Mr. Babubhai Mehta became the owner of the

property. During the year 1976 Mr. Babubhai Mehta sold

the above mentioned Rashmi Kunj building to Himmatlal

Mehta. Thereafter in the year 1997, the owner Himmatlal

Mehta sold the building along with the tenants to the owner

of Harigira Construction, named Mr. Brij Kishor Sharma

and hence Mr. Brij Kishor Sharma became the owner of the

Rashmi Kunj building. Allegedly, the room premises being

No. 403 stayed as it is and the father of the complainant

paid the rent to the owner and accordingly paid an amount

of Rs. 106/- as the rent to the owner.

(4) It has been alleged that in the year 2003 Rashmi Kunj

building became as old as 40 years approximately and the

structure became dilapidated in nature and therefore the


5

Municipal Corporation of Greater Mumbai had issued a

Notice under sec. 354 of the BMC Act to the owner as the

building has become inhabitable for human being.

(5) It has been alleged that as the Municipal Corporation

had initiated action against the building structure, therefore

the owner Mr. Brij Kishor Sharma had issued notices to 58

tenants. Also it is alleged that one Notice was issued to the

father of the complainant by the Landlord claiming him to

be the tenant.

(6) It has been alleged that as the father of the

Complainant was old and around 60 years of age, therefore,

the complainant used to look after the day to day affairs of

the property of his father and accordingly he has the

knowledge after receiving such notices from the Landlord,

the tenants had gathered together and arranged for meeting

with Landlord, Mr. Brij Kishor Sharma and accordingly, had

a meeting with him at his office. In the meeting it was

decided that the expenses towards repair and restoration of

the building would be borne by the tenants and the

remaining amount would be borne by the owner, Mr. Brij

Kishor Sharma. Accordingly, a few of the tenants had

collected the amount towards repair and restoration of the

building and had gone to the office of Mr. Brij Kishor

Sharma, where his son Mr. Arvind Jangid was present and
6

accordingly, the tenants were to bear the costs of the entire

repair and restoration of the building as the company which

owned the building had insufficient funds in its account.

Thereafter the tenants left the office without depositing

money with the owner. Thereafter 2 to 3 years passed away

and the condition of the building premises further

deteriorated.

(7) It has been alleged that during that period 28 tenants

had surrender their tenancy right to the Landlord, Mr. Brij

Kishor Sharma and 30 tenants continued to reside in the

building structure which clearly shows that in spite of

repairing the building, that was in a dilapidated state, the

owner, Mr. Brij Kishor Sharma and his son, Anil Sharma

(Arvind Jangid), chose to pay the tenants, who left the

premise over using the money for repair and restoration of

the building and made it clear that the owner had no

intention to restore the premises which is in a inhabitable

state and had no intention to cheat the tenants and make

them surrender tenancies to them.

(8) It has been alleged that in the year 2005 the owner,

Mr. Brij Kishor Sharma, sent a notice under sec. 354 of the

BMC Act, to the remaining 30 tenants for vacating their

premises and when the tenants failed to vacate the

premises the son of the owner i.e. Mr. Arvind Jangid, the
7

present Applicant filed a R.A.E. Suit against 30 tenants in

the Small Causes Court at Bandra.

(9) It has been alleged that the Applicant had filed Civil

Suit against the 30 tenants in the Small Causes Court at

Bandra and had lodged one Separate Suit against the

Complainant as a view that the structure No. 403 was

illegal structure and hence, a separate suit was filed against

the complainant.

(10) It has been further alleged that in both the suits the

Court had order the Applicant to carry out necessary

expenses to repair the building structure. Meanwhile, the

name of the company, owned by Mr. Brij Kishor Sharma

was changed to Maharshi Construction Co. from Angira

Company. In the meantime, 2 more tenants had

surrendered their tenancy right to the Landlord and the

remaining 28 tenants were asked to submit their

Undertaking before the Court stating that they would be

responsible for their life if any untoward incident took place

in the premises. Accordingly, 28 tenants had submitted

their Undertaking to the Company and thereafter the

Applicant had carried out propping of the structure i.e. to

support the structure with the help of erecting wooden

pillars to avoid collapse of the building and to increase the

strength of the structure.


8

(11) It has been alleged that in the circumstances

prevailing upon that period of the year 2010, it was the view

point of the Complainant that the original owner, Mr. Brij

Kishor Sharma and his son, Arvind Jangid had given up the

intention of removing the tenants out of the building

structure by putting forward the dilapidated condition of

the building. In the year 2010, someone from the vicinity

had given false information to the police and accordingly the

police officer and the Municipal Corporation’s Fire

Department had rushed to the building premises, but no

structural damage or collapse had occurred, therefore they

all went away. Thereafter there were various meetings at

the office of the Mr. Brij Kishor Sharma, BMC Officers and

the Police personnel, but without any outcome of these

meetings and after a few months there was one more such

complaint alleging the collapse of the building and therefore

28th tenants had lodged a Civil Suit bearing No. 1837 of

2010 at the City Civil Court, Dindoshi, Court Room No.8.

The Hon’ble Court was pleased to dismiss the suit filed by

the 28 tenants and accordingly the tenants had approached

the Hon’ble High Court through an Appeal from Order being

No. 1064 of 2011 and through which the impugned order of

the Hon’ble City Civil Court was set aside.


9

(12) It has been alleged that as the owner had no options

as the court cases had gone against him therefore he sold

off the entire building along with the tenants and the land

to one Aiyannar enterprises on 21/02/2012 for a sum of

Rupees 85lacs to the partner S. Shanmughaiya Solamuktu.

It is further alleged that when the complainant had

enquired about the said transaction he gathered knowledge

that the partner S. Shanmughaiya Solamuktu was nearly a

watchman/labour ( bodyguard of Mr. Brijkishore Sharma ).

(13) It has been alleged that the applicant is the real owner

of the building Rashmi kunj and he had shown this

property to be sold to Aiyannar Enterprises to take of his

liabilities of the tenant and the departmental procedures

with an intention to carry out a fresh application for

constructing a new building and obtaining the permission

for the same.

(14) It has been alleged that when the suit was being

decreed one hireling of Mr. Arvind Jangid came to the

building and threatened the tenants to move out peacefully

or face dire consequences and therefore the tenants had

lodged a complaint against him. Thereafter the applicant

had allegedly brought 8-10 people along with him to the

building premise without informing any of the tenants

started demolishing the building and tore apart 5-6 rooms


10

which were surrendered to them by the tenants who had

left the building premises. It is further alleged that when the

complainant gathered knowledge about such act of the

applicant he rushed to his building and saw that the

building was being torn apart by some people and therefore

he demanded some departmental or court orders but the

people who were trying to demolish the building failed to

show such documents therefore the complainant dialled

100 and called the police. As soon as the police arrived, the

labors that were carrying out their work of demolishing left

their tools and fled away, therefore the police lodged an FIR

bearing no. 324 of 2012 under section 170, 288, 427, 34 of

the IPC and arrested the present applicant and the

contractor.

(15) It has been alleged that in the year 2012 the 28

tenants again filed a civil suit bearing no. 2629 of 2012 and

accordingly the applicant hearing had informed the court

about the redevelopment of the said property and in the

meanwhile and untoward incident occurred at Mumbra,

Thane where depilated building had collapsed and

innumerable lives were lost therefore the ward officer had

started falling the owners and the tenants of such buildings

in a joint meeting and started disconnecting water and

electricity supply of such buildings and accordingly the


11

water and electricity supply of our building was also

disconnected and therefore the 17 tenants that were left in

the building approach the city civil court for some orders

and in the proceedings the advocate of the original owner

Mr. Brijkishore Sharma assured to provide permanent

alternate accommodation to the 28 tenants and also

informed that the present applicant has sold the company

to some other business man.

(16) It has been alleged that accordingly the interim relief

was not allowed therefore the officers of the municipal

corporation had issued orders to pull down the building

structure therefore 13 tenants out of the 17 tenants had left

the premises and went to some alternate accommodation

and the 4 tenants kept residing in the same premises.

(17) It has been alleged that thereafter no advances

occurred in the status of the matter pertaining to the

building premises therefore the suspicion of the remaining

tenants grew and they informed the Dindoshi police ad sat

on a hunger strike near the building. 3 days into the hunger

strike as the health of the tenant’s deteriorated, the police

requested to end their fast and took them to hospital.

Thereafter the applicant had given three months’ rent to the

13 tenants who had already left the premises and 1 year

rent to the 4 remaining tenants.


12

(18) It has been alleged that the applicant made an affidavit

and gave it to the tenants assuring them a permanent

alternate accommodation in the redeveloped structure and

hence believing in the assurances of the applicant the

tenants left their fast and allowed the applicant to pull

down the building structure.

(19) It has been alleged that after the passage of 1 year

when the tenants went to the applicant hearing to demand

the rent for the next year to which the applicant had denied

to pay the rent and told them to surrender their tenancy

rights to him. Thereafter the tenants approached the

Hon’ble High Court through a writ petition wherein the

Hon’ble High Court dismissed the writ petition directing the

tenants to file proceedings before appropriate court.

(20) It has been alleged that out of the 17 tenants, 11

tenants had financial hardships hence 6 tenants chose to

file a suit against the applicant in small cause’s court at

Bandra which is pending till date.

(21) It has been alleged that mean while the father of the

accused passed away and thereafter the applicant started

looking after the business of the late Brijkishore Sharma,

thereafter it is alleged that the applicant through his

architect produced false documents and grabbed


13

permission from the Municipal Corporation by showing the

plot as an open land and without putting any documents

regarding the tenants and thereby duped the complainant

and other tenants of their rights.

Being aggrieved by the aforesaid

complaint of the complainant and the conduct of the

officers connected with Dindoshi Police Station, the

applicant has approached this Honourable Court by filing

this Application for Anticipatory Bail under Section 438 of

Cr. P. C. as the officers of Dindoshi Police Station have

started calling up the applicant as C. R. No. 220 of 2017 is

registered against the applicant for alleged offences

punishable under Section 406, 420, 120 B, 191, 192, 193,

196, 198, 425 of I. P. C., the applicant is approaching

this Hon’ble Court as he apprehends that he would be

arrested in a false and frivolous case and hence he has

filed this anticipatory bail application with the following

grounds amongst the other grounds which are without

prejudice to each other:

GROUNDS

a. That the Applicant is innocent and he is falsely implicated

in the present case.

b. That the entire story of the complainant is false and

concocted as the complainant has is well aware that the


14

complainant has nothing to do with the land and building

as alleged in the complaint as the entire property is sold

to the accused no. 3 by the present applicant.

c. That it is pertinent to note that the F. I. R. is lodged on

17/03/2017 on the basis the statement dated

17/03/2017 wherein it clearly mentioned that a

statement of the complainant was recorded on

01/02/2016 by the police as the complainant had lodged

a written complaint to the Dindoshi Police Station on

02/12/2016. Therefore it is crystal clear that initial

complaint was the one which is insisted by the

complainant till date and in the complaint dated

02/12/2016 the name of the applicant is not mentioned

nor there are any allegations levelled upon him in that

complaint. Hereto annexed and marked is the complaint

of the complaint dated 02/12/2016 as ANNEXURE ‘B’.

d. That time and again the complainant has himself

repeated and reiterated in his statement dated

01/02/2016 that there were altogether 58 tenants in the

building structure that was previously owned by the

applicants father, but the complainant was never a tenant

and his structure bearing No. 403 never existed in the

building premises which is evident from the assessment

extract wherein there are 58 structure along with

measurements but there is no structure as 403. Hereto


15

annexed and marked is the assessment extract of the year

2006 and 2016 as ANNEXURE “C”.

e. That even in the conveyance that is done between the

father of the applicant and the earlier owner only 58

tenants is mentioned with their bifurcated rent and the

area that the father of the applicant purchased was

999.97 the agreement dated 1st day of January 1997 and

the tenants and the area sold to the Aiyannar Enterprises

by the applicant is also 999.97 with the list of 58 tenants.

Hereto annexed and marked are the copies of the

conveyance deed dated 01/01/1997 and 21/02/2012 as

ANNEXURE “D” Collectively.

f. That the complainant was merely an illegal occupier of

space on the terrace below water tank and was never a

tenant of the applicant or the previous owners. Therefore

he has no right of what so ever nature in the premises

neither the applicant has any liability towards the

complainant.

g. That the structure was dilapidated and the notice was

issued in the year 2003 and the same is evident from the

statement of the complainant and at that time all the

meetings were held with the late Brijkishore Sharma and

all the decisions were taken by him as he was the

managing director of the company and the applicant was


16

mere a director and was not active in decision making as

his father was managing the business.

h. That the meeting about repairing the building took place

between the tenants and the father of the applicant and it

was decided to bear 50:50 expenses by the land lord and

the tenants also it was decided that the landlord would

carry out the repairs only after deposit of the 50% share

of the tenants but the tenants never deposited the monies

with him therefore the repair of the building never took

place.

i. That the dilapidated building had also partly collapsed

which is evident from the fire departments report Bing

house collapse report 39 of 2011/2012. The report dated

1st August 2011 clearly states that on arrival at the scene

of incident it was observed that some portion of the

parapet at the third floor level of a wing of a ground floor

+ 3 upper floor residential building was collapsed and

some portion was hanging precariously. Horizontal and

vertical cracks were developed on the beams, pillars and

walls all over the building and their steel framework was

exposed and rusted complete building was in dilapidated

condition and likely to be collapsed at any moment none

reported injured. Therefore it is clear that the

complainant is forcibly trying to suppress the material

fact and thereby the prosecution and the complainant are


17

trying the level best to forcibly implicate the present

accused in the present FIR and extort huge monies from

the applicant. Hereto annexed and marked is the copy of

the house collapse report issued by the Fire Department

as ANNEXURE “E”.

j. That no order is passed by the honourable high court

directing the applicant to retain the tenants in their

respective tenements in Appeal from order 1064/2011, in

fact the appeal was dismissed by the Honourable High

Court and upheld the order dated 22/07/2011 of the

Honourable City Civil court passed in Notice of Motion

2213 of 2010. That by putting such false statements in

the FIR, the prosecution and the complainant are trying

the frame the accused in the present FIR. Hereto annexed

and marked are the copies of the orders of the

Honourable High Court and the Honourable City Civil

Court as ANNEXURE “F” Colly.

k. That the order dated 22/07/2011 has observations of the

honourable court in regard to the case of the complainant

show the contradiction and the current intention of the

complainant and their cooked up version can be

understood by giving a reading of the order dated

22/07/2011.

l. That therefore the allegation of the applicant getting stuck

and having no option but to sell the entire property to


18

Aiyannar enterprises for a sum of 85,00,000/- falsely

stands no grounds. Also it is pertinent to note that the

allegations made that the person s. shanmugaiiya

solamukttu is merely a worker of the applicant can be

falsified by a registered partnership deed with his partner.

Hereto annexed and marked is the copy of the

partnership registration certificate/deed as ANNEXURE

“G”.

m. That the applicant had handed over the building to the

Aiyannar Enterprises in the year 2012 and thereafter the

building was pulled down by the Municipal Corporation in

July, 2013 therefore it is clear that even after having the

entire knowledge and understanding that the present

applicant is nowhere involved in the demolition of the

building nor he is liable to give any kind of

accommodation to the complainant as he has ceased to

be an owner still the complainant has hidden motives to

implicate the applicant in the present matter.

n. That the applicant has not submitted any plan or

proposal to the municipal corporation for development or

construction of the Rashmi Kunj Building.

o. That the applicant has not given any rent to the

complainant nor has he signed any affidavit to provide

alternate accommodation to the tenants.


19

p. That the building was pulled down by the municipal

corporation and not by the applicant or any of his

workers, therefore promising the permanent alternate

accommodation to the complainant was not possible at

all.

q. That even the suit pending as per the FIR is not against

the applicant but before the present owner who is one of

the partner of the Aiyyanar Enterprises.

r. That the dispute between the complainant and the

applicant is due to exorbitant demands of the tenants

which none of the previous owners were able to fulfil and

the same were not fulfilled by the applicant.

s. That as the plan is not put up by the applicants the

allegations alleged upon him become baseless and void of

merits.

t. That tired of the false complainant and the pressure of

the API Ravi Adane, the applicant had lodged a written

complaint the API Ravi Adane therefore he has gathered

grudge against my client and therefore even though the

name of my client is not appeared in the written

complaint of the complainant he is been roped in the

matter. Hereto annexed and marked is the copy of the

written complaint of the applicant levelling allegation

against the API Adane as ANNEXURE “H”.


20

u. That the present owner of the land over which the

building was erected had given an undertaking before the

building department assuring accommodation to the

tenants. Hereto annexed and marked is the copy of the

undertaking dated 18/05/2015 as ANNEXURE “I”.

v. The malafide intention of the prosecution can be clearly

made out as the information to the prosecution was

received by the prosecution prior registering the FIR in

the form of written complaint, even after having

complaints on record the office bearers of the Dindoshi

Police Station without conducting an impartial inquiry

lodged an FIR against the present applicant.

w. That the prosecution is hand in gloves with the

complainant as it can be clearly made out that even

though prima facie case is not made out against the

applicant he is been roped into the present FIR with

malafide intention to extort monies from the applicant

and his family members.

x. That the prosecution has failed to prove the Prima Facie

case against the applicant whereas the prosecution has

blindly believed the words of the complainant and

arbitrarily lodged the FIR against the applicant.

y. That the entire story of the complainant is concocted and

made with ulterior motives to trap the present applicant

and extort monies from the applicant.


21

z. That the present applicant has visited the Dindoshi Police

station several times and had helped the investigation

agency, but all of sudden without any rhyme or reason

the Dindoshi Police Station are trying to arrest the

present applicant.

aa. That the complainant has not suffered any wrongful loss

neither the applicant gained a penny wrongfully, the

cheating and misappropriation alleged against the

applicant is to the right of tenancy of the complainant,

therefore the alleged tenancy and the alleged room

premises of the complainant cannot be recovered at the

instance of the applicant, Hence the custodial

interrogation in the matter not at all necessary.

bb. That as the complaint is completely false and baseless

hence no fruitful purpose will be served by arresting the

Applicant.

cc.That the Applicant is a permanent resident of the address

mentioned in the cause title, and he will not abscond if

released on anticipatory bail. The copy of the residence

proofs are annexed herewith and marked as ANNEXURE

“J”.

dd. That there is no criminal antecedent against the

Applicant of whatsoever nature to disentitle him bail.

ee. The Applicant undertakes to abide by all the terms and

conditions while being enlarged on anticipatory bail.


22

ff. The Applicant undertakes to furnish sureties to secure

his presence during entire trail of the matter.

gg. The applicant is ready and willing to cooperate with the

investigation agency and is ready to attend the police

station for further enquiry as and when required by the

investigating officer.

hh.That the Complainant having political contacts is taking

undue advantage of the prevailing situation by filing such

false and frivolous complaint and therefore, the Applicant

may be protected from any kind of coercive actions at the

hands of Dindoshi Police Station.

The Applicant craves leave to add, alter or amend any of

the aforesaid grounds with the permission of this

Honourable Court.

That The Applicant has not filed any other Application in

this Hon'ble Court or any other Court, save and except

the present Application.

19. The Applicant, therefore, prays that:

(a) In the event of arrest of the Applicant in C. R.

No. 220 of 2017, registered with Dindoshi Police

Station on the complaint filed by the

Complainant, the Applicant be released on


23

Anticipatory Bail, on such terms and conditions

as this Hon'ble Court may deem fit and proper;

(b) Pending the hearing and final disposal of this

Application, the Respondent be directed not to

arrest the Applicant in connection with C. R. No.

220 of 2017.

(c) Ad-interim relief in terms of prayer clause (b) may

be passed in favor of the Applicants;

(d) Any such other and further reliefs as this Hon'ble

Court may deem fit and proper.

AND FOR THIS ACT OF KINDNESS THE APPLICANTS AS IN


DUTY BOUND SHALL EVER PRAY.

Advocate for the Applicant

Mumbai,
Dated this day of June, 2017
24

VERIFICATION
I, Mr. Arvind Brijkishor Jangid, age 46 years, the Applicant

above named, do hereby solemnly affirm that whatever is

stated in the foregoing paragraphs is true to my own

knowledge and I believe the same to be true and correct.

Solemnly affirmed at Mumbai )

This day of June 2017 )

Before me,

Identified by me,

Advocates for the Applicant

Adv. Kshitij R. Mehta

Adv. Sunny Aaron Waskar

“11, Chotu Bhai Compound,

Kedarmal Road, Malad –East,

Mumbai –400 097.

Cell - 9833049999
25

BEFORE THE HON'BLE SESSIONS COURT AT DINDOSHI,

BORIVALI DIVISION, MUMBAI

ANTICIPATORY BAIL APPLICATION NO. OF 2017

DIST. MUMBAI

Mr. Arvind Brijkishore Jangid .. Applicant

Versus

The State of Maharashtra .. Respondent

INDEX

Sr. Particulars Page Nos.


No.

1 Roznama

2 Memo of Criminal Anticipatory Bail Application.

3 ANNEXURE “A”
Copy of the FIR dated 17th March, 2017

4 ANNEXURE “B”
Initial complaint of the complainant dated
02/12/2016
5 ANNEXURE “C”
Assessment extract from the MCGM of the
property of the year 2006 and 2016.
6 ANNEXURE “ D ”
Conveyance deed dated 01/01/1197
Conveyance deed dated 21/02/2012
7 ANNEXURE “E”
House Collapse report issued by the Fire
Department.
8 ANNEXURE « F »
The copies of the orders of the Honorable High
Court and the Honorable City Civil Court.

9 ANNEXURE « G »
Partnership registration certificate/deed
26

10 ANNEXURE « H »
Written complaint of the applicant against the
API Adane.

11 ANNEXURE « I »
The copy of the undertaking dated
18/05/2015.

12 ANNEXURE « J »
Residential Proofs.

Vakalatnama

Advocate for the Applicant

Mumbai,
Dated this day of June, 2017
27

BEFORE THE HON'BLE SESSIONS COURT


AT DINDOSHI, BORIVALI DIVISION, MUMBAI
ANTICIPATORY
BAIL APPLICATION NO. OF
2017
In C. R. No. 46 of 2017
DIST. MUMBAI

Mr. Arvind Brijkishore Jangid.


. … Applicant
Versus
The State of Maharashtra
.. Respondent

ANTICIPATORY BAIL APPLICATION

Dated this day of June, 2017

Adv. Kshitij R. Mehta


Adv. Sunny Aaron Waskar

For the applicant.

“11, Chotu Bhai Compound,

Kedarmal Road, Malad –East,

Mumbai –400 097.

Cell – 9833049999

Anda mungkin juga menyukai