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BEFORE THE HON’BLE COURT OF DISTRICT & SESSION

JUDGE AT SRINAGAR

In the case of:-


Tabasum Bilal
W/o Bilal Ahmad Pandith
R/o Zawoora Lasjan Srinagar

Petitioner …

V\S

State through SHO Police Station


Panthachowk, Srinagar.

Respondent…..

In the matter of:- Petition under section 438 Cr.PC for


grant of anticipatory bail in favour of
the petitioner named above.

May it please your Honour,

That the petition of the Petitioner is submitted as


under:-

1. That the Petitioner named above is a citizen of

India domiciled in the Union Territory of J&K and

as such is entitled and competent to invoke the

jurisdiction of this Hon’ble Court for the

protection of her Fundamental Rights, especially

Right to Personal Liberty, as guaranteed by the

Constitution of India.

2. That petitioner is receiving phone calls from the

concerned police station and thus has

apprehension that she might get arrested in some

false and frivolous case.


3. That the Petitioner has no desire to evade due

process of law and shall face the trial to vindicate

their innocence, in the aforesaid case.

4. That the petitioner is a peace-loving and law-

abiding citizens of the Union territory and has

not committed any offence whatsoever to the best

of his knowledge and belief.

5. That the Petitioner has behaved as law abiding

citizen of the country and has never been

indulged in any anti-national activities till date

that will be prejudicial to the security of the

country in order to make any hurdle for making

law and order .

6. That the Petitioner undertakes that she will not

misuse the bail and shall abide by all the terms

and conditions fixed by the Hon’ble Court.

7. That in so far as the bail in anticipation U/S 438

Cr.PC is concerned it has been held in various

pronouncements of the Supreme Court as well as

the High Court of the J&K that the liberty of a

person is most precious and its curtailment is an

exception when law warrants the arrest of a

person thus the petitioner have invoked the

jurisdiction of this Hon’ble Court u/s 438 Cr.PC

in order to get bail in anticipation in their favour

so that the liberty of a person be protected.


8. That the petitioner craves leave to table more
grounds at the time of arguments.

9. That this petition is supported by an affidavit.

IN THE PREMISES, it is therefore, humbly prayed

that that the petitioner may kindly be granted

bail in anticipation of arrest, in the interest of

justice, equity and good conscience on such

conditions as this Hon’ble Court deems fit and

proper.

Petitioner Through Counsel


BEFORE THE HON’BLE COURT OF DISTRICT & SESSION
JUDGE AT SRINAGAR

In the case of:- Tabasum Bilal

Petitioner …

V\S

State through SHO Police Station


Panthechowk, Srinagar.

In the matter of: Affidavit in support of the Application.


I, Tabasum Bilal W/o Bilal Ahmad Pandith R/o Zawoora
Lasjan Srinagar
solemnly affirm on oath are as under: -

That the averments made in the petition annexed herewith


are true and correct to the best of my knowledge and belief
and nothing has been concealed therein.

De
ponent
Verification:

Verified on 19th day of JUNE 2024 at Srinagar that the


averments made in the affidavit are true and correct to the
best of my personal knowledge and belief and nothing has
been concealed therein.

Deponent

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