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That the applicant has falsely been implicated in Case
Crime No. 81 of 2021 under Sections 2/3 of U.P.
Gangster and Anti-Social Activities (Prevention)
Act, 1986 at Police Station – Sangipur, District
– Pratapgarh on 09.05.2021 at 22.34 hours against
the applicant and one other person. The certified
copy/ typed copy of the first information report
dated 09.05.2021 is being annexed herewith as
Annexure No. 1 to this Affidavit.
That prior to lodging the first information report the
gang chart has been approved by the District
Magistrate, Pratapgarh on 16.04.2021. The photo/
typed copy of the gang chart approved on
16.04.2021 is being annexed herewith as Annexure
No. 2 to this Affidavit.
That according to the First Information Report, which
has been lodged by Shri Tushar Dutt Tyagi, the
then S.H.O., Police Station – Sangipur, District
– Pratapgarh (hereinafter referred to as
‘informant’), the prosecution story is in
nutshell that the Santosh Singh is the gang
leader of a gang, and the applicant is the active
member of the gang. The gang is committing the
offences in organized manner regularly as they
are habitual, for their economic benefit and due
to their terror no one can dare to speak against
them.
That the aforesaid case crime has been lodged against
the applicant on basis of the one case i.e. Case
Crime No. 172 of 2019 under Sections 419, 420,
467, 468, 471, 272, 273 of IPC and 60, 60A, U.P.
Excise Act and 63 of Copyright Act registered at
Police Station – Sangipur, District – Pratapgarh,
in which the applicant has been granted bail by
the learned court below on 22.09.2019. The
photocopy of the bail order dated 22.09.2019
passed by the learned court below is being
annexed herewith as Annexure No. 3 to this
Affidavit.
That the name of the applicant is shown at serial No.
02 in the accused column first information report
dated 09.05.2021.
That the informant falsely implicates the applicant, in
the said crime for ulterior motive, which is
baseless and illegal as the applicant is not
involved in any criminal activity as alleged
against him.
That the informant in order to showing his good and
hard work, falsely implicate the applicant in
some case crimes.
That the applicant does not committed any offence
for his economical and physical benefit. The
applicant is not convicted previously in any case
crime. The allegations against the applicant are
false and fabricated.
That the applicant has no concerned with any gang in
any manner as such the under Sections 2/3 of U.P.
Gangster and Anti-Social Activities (Prevention)
Act, 1986 have not applicable against him.
That the applicant is falsely implicated in several
cases lodged against the applicant, which the
applicant has not committed any offense. The
details of the case, which are lodged against the
applicant, as per best knowledge of the applicant
are as under:-
Case Crime No. 229 of 2012 under Sections 419,
420, 467, 468, 471, 272, 273 of IPC and 103,
104 of Trade and Merchandise Marks Act and 63
Copyright Act, 60(2)/63 Excise Act registered
at Police Station – Sangipur, District –
Pratapgarh, in which nothing has been found
against the applicant as such his name has been
dropped from the investigation on 17.09.2020.
Case Crime No. 13 of 2021 under Sections 419,
420, 467, 468, 471, 272, 273 of IPC and 103,
104 of Trade and Merchandise Marks Act and 63
Copyright Act, 60(2)/63 Excise Act registered
at Police Station – Sangipur, District –