IN THE COURT OF THE CITY CIVIL & SESSIONS JUDGE AT BANGALORE

Crl. Misc. No. Petitioners : -versusRespondent : State of Karnataka By Ulsoor Gate Women Police Station, Bangalore City. of 2011

ALAPATI BABUJEE

INDEX
SL NO 1 Memorandum of Criminal Miscellaneous Petition u/s 438 of Cr Pc. DESCRIPTION OF THE DOCUMENTS PAGE NO

List of Documents i. ii. Copy of the FIR Copy of the complaint

Vakalath

.. Advocate for petitioners. R.L.N.MURTHY & ASSOCIATES Place: Bangalore. Date: 18/7/11.

IN THE COURT OF THE CITY CIVIL & SESSIONS JUDGE AT BANGALORE Crl.Misc.No.of 2011

1. ALAPATI BABUJEE S/o.Govind Raja Rao, Aged about 52 Years, R/at No.12-13-708, Kimtee Colony, Tranaka, Secunderabad-500 01. -/versus/State of Karnataka by ulsoor Gate Women Police, Bangalore.

Petitioners.

Respondent.

MEMORANDUM OF CRIMINAL MISCELLANEOUS PETITION UNDER SECTION 438 OF THE CODE OF CRIMINAL PROCEDURE The petitioners above named begs to submit as follows:-

1.

That for the purpose of services of Notice summons etc.,

the address of the petitioners is shown in the cause title and they can also be served on their counsels

R.L.N.MURTHY & ASSOCIATES, Advocates, No.401/1, Ground Floor, Swastik Complex, Swastik 020. Circle, The S.C. address Road, the

Seshadripuram,

Bangalore-560

complainant is also shown in the cause title. 2. The petitioner submit that, the Ulsoor gate women police have registered criminal case against the petitioners in Crime

No.81/2011 on 01.07.2011 for the offences punishable under section 498A, 506 of IPC and under section 3 and 4 of Dowry

Prohibition Act based on the written complaint given by one Mrs. Anusha w/o. Alapati Ranjeet kumar. The complaint is the daughter in law of the petitioners, Alapati Ranjeeth kumar is the only son of the petitioners. Anushar and Ranjeet kumar married on June 2nd 2010 at Bangalore, and both ware residing at

Vasanth nagar, Bangalore after their marriage.

3. The petitioners are permanent residents of the secunderbad, Andrapradesh state, they deny all the allegation made against them in the complaint and they not have committed any offence, the complainant have falsely impleaded as accused in the criminal case just to harass them. 4. The petitioners submit that, immediately after having

knowledge of the above said criminal case, the petitioner are approaching this Honble court seeking prayer of anticipatory bail in the event of the their arrest, among the following amongst other grounds;5. The petitioners submit that, that they are the permanent

residents of above address. 6. The petitioners submit that, they all are innocent.

7.

That the petitioners are most respect for the laws and all

are law-abiding citizens and having deep roots in the society and have no bad antecedents.

8.

That the complainant has filed the above case falsely just

to harass the petitioners and complainant has bad motive against the petitioners has filed the above false complaint. 9. That the alleged offences leveled against the petitioners is

neither punishable with death or imprisonment for life, hence there is no legal embargo for this Honble Court to enlarge the petitioners on anticipatory bail in the event of arrest of these petitioners. 10. That the petitioners further submitted that all are ready

and willing to join and assist investigation officer whenever summoned and also willing to abide by all the terms and conditions that may be imposed by this Honble Court and they are ready and willing to furnish solvent surety for ensuring their regular appearance before the Honble Court up to the conclusion of trial. However. 11. That the Petitioners are innocent and no useful purpose

would be served by arresting them and keeping them under custody and this is a fit case for grant of anticipatory bail as the Petitioners are being needlessly harassed by the respondent and apprehends arrest. 12. It is further submitted that the petitioners would neither

abscond nor delay the proceedings and would not tamper with the prosecution witnesses. 13. That the petitioners may be permitted to urge any

additional grounds at the time of advancing arguments.

14.

That the petitioners submit that no harm or injury will be

caused to other side if this application is allowed and on the other hand if this application is not allowed the petitioners will be put to hardship and injury. 15. That the Petitioners have not filed any other similar

petition before this or any other Honble Court for grant of anticipatory bail in connection with above criminal case. PRAYER Wherefore, the petitioners above named most humbly prays that, this Honble Court be pleased to enlarge them on anticipatory bail in the event of their arrest in Crime No.81 of 2011 of Ulsoor Gate Police Station, pending before the Honble 6th ACMM court Bangalore City in the interest of justice. .. Advocate for petitioners. R.L.N.MURTHY & ASSOCIATES Place: Bangalore. Date: 18/7/11.

IN THE COURT OF THE CITY CIVIL & SESSIONS JUDGE AT BANGALORE

Crl. Misc. No. Petitioners : -versusRespondent : State of Karnataka By Ulsoor Gate Women Police Station, Bangalore City. of 2011

ALAPATI BABUJEE

LIST OF DOCUMENTS
Sl. No. 1. 2.

Description Copy of the FIR Copy of the complaint

Page No.

.. Advocate for petitioners. R.L.N.MURTHY & ASSOCIATES Place: Bangalore, Date: 18/7/11.