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Reply of Bail Cancel

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IN THE HON’BLE COURT OF ADDI.

DISTRICT &
SESSION JUDGE -07 ALIGARH U.P.

IN THE MATTER OF:

STATE VS. ARJUN SINGH & OTR.

FIR NO. 212/2021


U/S: 147/323/325/504/506 IPC
2A/3A MP ACT
P.S.: QUARSI

REPLY TO THE APPLICATION FOR CANCELLATION OF


BAIL OF ARJUN SINGH , DEEPAK , SUMIT AND AMIT.

MOST RESPECTFULLY SHOWETH:

PRELIMINARY OBJECTIONS:

1. That the present application is not

maintainable as at the time of granting

regular bail on 02.03.2021, no specific

conditions were imposed upon the accused

and as such, there is no violation of

such condition. It is submitted that

even the complainant has not

reported/disclosed any such condition in

the instant entire application.

2. That the present application is not

maintainable as the complainant has

concealed the material facts.


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3. That the present application is not

maintainable.

4. That the present application is not

maintainable as the accused/applicant is

neither allegedly tempering with the

evidence nor he is not available for the

trial, which is envisaged in another

judgment of Hon’ble Apex Court titled as

“Bhagirath Singh Vs. State of Gujarat”

1984(1) Crimes 334.

5. That the present application is not

maintainable as the matter section 2A of

medical prevention act of definition of

commit the offence and 3A section of

medical prevention act is commit the

offence shall be punished with the

punishment for a term which may extend

to tree year or with the fine.

REPLY ON MERITS:

1. That para No.1 of the application needs

no reply.
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2. That para No.2 of the application is

wrong and denied.

3. That para No.3 of the application is

partly admitted to the extent that the

applicant/ accused was granted interim

bail on 02.03.2021, but subsequently he

was granted regular bail and no specific

terms and conditions were imposed upon

him and so violation of such condition

is not alleged in the application. It is

submitted that the matter is pending

before the trial court and listed for

the 03.11.2023 on charge. It is

pertinent to mention here at the time of

bail application section 2A of medical

prevention act in FIR when argument on

bail application section 2A of medical

prevention act is the definition of the

commit offence and section 3A of medical

prevention act 2013 is punishment of

alleged offence. Charge sheet has been

filed before the concern court and IO

has been added section 2A/3A of medical

prevention act in the final report.


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4. That para No.4 of the application is

wrong and denied. It is denied that the

accused person grant the bail without

the consider the prosecution facts .it

is pertinent to mention here that on

bail order clear mention that object the

bail application by the prosecutor. And

concern court consider the all facts and

given the proper opportunity of the

both the parties and grant the bail of

the accused person and mention that the

committed offence is less then 7 year of

punishment.

It is, therefore, most respectfully prayed that

the application be dismissed with cost, in the

interest of justice.

ACCUSED

ALIGARH.

DATED: THROUGH

COUNSEL
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IN THE HON’BLE COURT OF ADDI. DISTRICT &


SESSION JUDGE -07 ALIGARH U.P.

IN THE MATTER OF:

STATE VS. ARJUN SINGH & OTR.

FIR NO. 212/2021


U/S: 147/323/325/504/506 IPC
2A/3A MP ACT
P.S.: QUARSI

AFFIDAVIT

I Arjun singh s/o Ram lal R/o village –


ushmanpur khurja nagar , Distt- bulandshar,
U.P. do hereby solemnly affirm and declare
under:-
1.That I am residing above given address.
2.That I am deponent in the above affidavit
and being well conversant with the fact
and circumstance of the affidavit/case and
competent to swear to present affidavit.
3.That the content of said bail application
are not repeated herein for the save
brevity, however the maybe read as part
and this affidavit.
4.That my statement is true and correct.

DEPONENT
VERIFICATION
Verified at Aligarh on ____ day of oct
2023 that the contents of above said affidavit
are true and correct to my knowledge and on the
basis of knowledge received from lawyer and
believed to be correct and nothing is false and
nothing has been concealed from the court.

DEPONENT
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IN THE HON’BLE COURT OF ADDI. DISTRICT &


SESSION JUDGE -07 ALIGARH U.P.

IN THE MATTER OF:

STATE VS. ARJUN SINGH & OTR.

FIR NO. 212/2021


U/S: 147/323/325/504/506 IPC
2A/3A MP ACT
P.S.: QUARSI

AFFIDAVIT

I deepak s/o satish chand R/o village –


ushmanpur khurja nagar , Distt- bulandshar,
U.P. do hereby solemnly affirm and declare
under:-
1.That I am residing above given address.
2.That I am deponent in the above affidavit
and being well conversant with the fact
and circumstance of the affidavit/case and
competent to swear to present affidavit.
3.That the content of said bail application
are not repeated herein for the save
brevity, however the maybe read as part
and this affidavit.
4.That my statement is true and correct.

DEPONENT
VERIFICATION
Verified at Aligarh on ____ day of oct
2023 that the contents of above said affidavit
are true and correct to my knowledge and on the
basis of knowledge received from lawyer and
believed to be correct and nothing is false and
nothing has been concealed from the court.

DEPONENT
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IN THE HON’BLE COURT OF ADDI. DISTRICT &


SESSION JUDGE -07 ALIGARH U.P.

IN THE MATTER OF:

STATE VS. ARJUN SINGH & OTR.

FIR NO. 212/2021


U/S: 147/323/325/504/506 IPC
2A/3A MP ACT
P.S.: QUARSI

AFFIDAVIT

I sumit s/o suresh chand R/o village -karsua


PO-karsua PS -Lodha, Distt-Aligarh, U.P. 202140
do hereby solemnly affirm and declare under:-
5.That I am residing above given address.
6.That I am deponent in the above affidavit
and being well conversant with the fact
and circumstance of the affidavit/case and
competent to swear to present affidavit.
7.That the content of said bail application
are not repeated herein for the save
brevity, however the maybe read as part
and this affidavit.
8.That my statement is true and correct.

DEPONENT
VERIFICATION
Verified at Aligarh on ____ day of oct
2023 that the contents of above said affidavit
are true and correct to my knowledge and on the
basis of knowledge received from lawyer and
believed to be correct and nothing is false and
nothing has been concealed from the court.

DEPONENT
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IN THE HON’BLE COURT OF ADDI. DISTRICT &


SESSION JUDGE -07 ALIGARH U.P.

IN THE MATTER OF:

STATE VS. ARJUN SINGH & OTR.

FIR NO. 212/2021


U/S: 147/323/325/504/506 IPC
2A/3A MP ACT
P.S.: QUARSI

AFFIDAVIT

I amit s/o jogendra R/o village -karsua PO-


karsua PS -Lodha, Distt-Aligarh, U.P. 202140 do
hereby solemnly affirm and declare under:-
1.That I am residing above given address.
2.That I am deponent in the above affidavit
and being well conversant with the fact
and circumstance of the affidavit/case and
competent to swear to present affidavit.
3.That the content of said bail application
are not repeated herein for the save
brevity, however the maybe read as part
and this affidavit.
4.That my statement is true and correct.

DEPONENT
VERIFICATION
Verified at Aligarh on ____ day of oct
2023 that the contents of above said affidavit
are true and correct to my knowledge and on the
basis of knowledge received from lawyer and
believed to be correct and nothing is false and
nothing has been concealed from the court.

DEPONENT
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