IN THE COURT OF SESSIONS FOR GREATER BOMBAY CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO. OF 2001
ABC S/o PQR
Indian inhabitant
residing at …….. Petitioner
V/s
- State of Maharashtra at the instance of The Inspector of Police In-charge of ________Police Station …….. Respondent CRIMINAL ANTICIPATORY BAIL APPLICATION UNDER SECTION 438 OF THE CRIMINAL PROCEDURE CODE, 1973.
To THE HON’BLE PRINCIPAL JUDGE AND HIS COMPANION JUDGES OF THIS HON’BLE COURT.THE HUMBLE PETITION OF THE PETITIONER ABOVENAMED:MOST RESPECTFULLY SHEWETH: - The petitioner is a citizen of India. The petitioner is about years old and is unmarried. The petitioner is a permanent resident of Mumbai, residing at the address as mentioned in the cause title since birth. The petitioner is the son of ___, who is the co-owner of the aforesaid premises. The petitioner’s father shares the said premises amongst others with one of the petitioner’s uncle named LMN. The petitioner’s father and the said LMN are also partners in a firm called M/s. _ situated at ___________.
- The petitioner’s father and the said LMN are involved in various civil disputes relating to the said partnership firm, the residential premises and other commonly held properties. There are many cases and proceedings pending in different courts in Mumbai relating to the same. The said LMN has also time and again dragged the petitioner’s father and his family to the Criminal courts and/or police station. However on each of the occasions the said LMN has met with no success but continues to harass the petitioner, his parents and other family members by lodging false, frivolous and mischievous complaints one after the other….
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