In,

The court of District & Session Judge,

Gaya .

A.B.P. No. / 2018

( Arising out of Paraiya P. S. Case no. 161/18, Gr. No. 6608/18, State
vs Rajendra Paswan & others U/S 323,341,342,307,354,379,456 and
34 of the IPC and 27 Arms Act pending in the court of Additional
Chief Judicial Magistrate IIIrd, Gaya .)

Rajendar paswan,S/O Late Timal Paswan, r/o village – Punakala, P.S.

– Paraiya, Distt – Gaya _________________ Petitioner

Vs

State of bihar ________________________________ Opposite party

That the humble petition for bail on behalf

of petitioner aforesaid U/S 438Cr.P.C. .

Most respectfully showeth:

1. That the petitioner is innocent and he is falsely implicated in

this case.
2. That the earlier no bail petition on the petitioner has been filed
either before this court or before any higher court.
3. That the prosecution story that the informant Pinky Kumari
gave a written report to the S.H.O. Paraiya on 27/10/18 alleged
there in that her son was come after playing the ballthen the
accused persons 1_Rajendra Paswan, 2_Naresh Paswan,
3_Pradeep Paswan, 4_Vinod Paswan, 5_Bangali Paswan and
 6_Arvind Paswan assaulted son Anil Kumar, while her son come
to house then above mentioned accused persons armed with
lathi (clubs) and enter in her house and begun to beat her son
with clubs and slaps and they also assaulted her with clubs and
slaps consequently and then she become unconscious. It is
further alleged that Naresh Paswan and Pradeep Paswan
snatched her jeetiya and chain of gold and destroyed her door.
It is further alleged on her crying co-villagers come there after
Naresh Paswan and Pradeep Paswan begun to fire with their
Arms and they threatened the genesis offence is land disute.
That the husband of the informant and her supports have
assaulted to Sangeeta Devi w/o Pradeep Paswan (Accused no.
3) but her case was not registered by the S.H.O. Paraiya P.S.
rather the S.H.O. Paraiya P.S. has made accused in this case to
the relative of Sangeeta Devi inconvenience by the informant
there after the case of the Sangeeta Devi has been registered
by SC/ST P.S. bearing no 36/18 U/S – 147,149,323,341,354, and
504 of the IPC and SC/ST Act 3(1) T and S.
( The certified copy of the order is
here by annexed with the bail
A.B.Petition and marked as
Annexure – A )

4. That the it is fact that informant wants to save her relatives

from SC/ST P.S. case no. 36/18 so, this is totally false &
concocted story.

(The certified copy of the order is

here by annexed with the
A.B.Petition and marked as
Annexure- B)
5. That all the section is bailable except section 307,379 I.P.C. and
27 Arms Act which are not applicable in this case against the
petitioner.
6. That all injuries are simple in nature.
7. That virtually nothing such as alleged has happens rather a false
story has been devolved to implicated the petitioner.
8. That the petitioner has been made on instigation of villagers.
9. That the petitioner does not bear any criminal antecedent.
10. That the accused petitioner is permanent residence
within your honour jurisdiction.
11. That is no chance of absconding to the petitioner or
tampering with evidences.
12. That the accused petitioner is ready to furnish the bail
bond of any reasonable amount decided by this court.

It is, therefore prayed that your

honour may be graciously
pleased to kindly enlarge the
petitioner on bail.

And for this petitioner shall ever pray