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{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"name\": \"Smt. Chanar Devi\",\n \"age\": \"50 years\",\n \"address\": \"Village – Gadiyani, Manraunda, District – Prayagraj (earlier Allahabad)\",\n \"occupation\": \"Housewife\",\n \"contact_information\": \"Not mentioned\",\n \"other_relevant_personal_details\": \"Wife of Late Ram Fer, illiterate\",\n \"current_case_fir_details:\": [],\n \"case_number\": \"Case Crime No. 200 of 2023\",\n \"sections\": \"363, 366 of I.P.C.\",\n \"date\": \"04.11.2023\",\n \"police_station\": \"Dilippur, District – Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"bail_application_number\": \"3178 of 2023\",\n \"court\": \"Additional District Judge/ Special Judge, (POCSO), Pratapgarh\",\n \"date_of_rejection\": \"07.02.2023\",\n \"correction_order\": \"22.02.2024\",\n \"certified_copy\": \"Annexure No. 06 to the affidavit\",\n \"key_facts_of_the_case:\": [\n \"The applicant was working in the village of the opposite party No. 2 and met with the victim, and they fell in love and decided to marry.\",\n \"The victim belongs to another religion, and after coming to know about the relationship, her family threatened the applicant to face consequences.\",\n \"The victim left her house and went with the applicant to solemnize the marriage and resided with the applicant.\",\n \"The concerned police recovered the victim from Mauaima, Prayagraj, when the victim was with the applicant.\",\n \"The whole story was cooked by the opposite party No. 2 and their family members on narration of the concerned police against the applicant.\"\n ],\n \"custody_status:\": [\n \"The victim was recovered by the concerned police on 04.11.2023 and her custody was given to the opposite party No. 2.\",\n \"In the statement given under Section 164 of Cr.P.C., the victim stated that she herself called her mother i.e. opposite party No. 2 when she was thrown by the applicants.\"\n ],\n \"supporting_documents_and_details:\": [\n \"ID Proof of the deponent (Smt. Chanar Devi)\",\n \"Photo affidavit slip issued by the Oudh Bar Association\",\n \"Certified/typed copy of the first information report dated 04.11.2023 (Annexure No. 01)\",\n \"Typed copy of the statement of the opposite party No. 2 dated 04.11.2023 (Annexure No. 02)\",\n \"Typed copy of the statement of the victim dated 04.09.2023 (Annexure No. 03)\",\n \"Typed copy of the medical report of the victim along with the supplementary medical report (Annexure No. 04)\",\n \"Typed copy of the statement of the victim recorded under Section 164 of Cr.P.C. (Annexure No. 05)\",\n \"Certified copy of the bail rejection order dated 07.02.2023 passed by the court below along with the correction order dated 22.02.2024 (Annexure No. 06)\"\n ],\n \"medical_report:\": [\n \"The medical examination of the victim was conducted on 06.11.2023 by the doctor concerned, and neither any injury was found on her body nor any other incriminating findings were mentioned in the medical examination of the victim.\",\n \"The radiological age of the victim has been ascertained as 18 years vide report supplementary medical report.\"\n ],\n \"statement_recorded:\": [\n \"The statement of the victim was recorded under Section 161 of Cr.P.C. on 04.09.2023, in which she stated that she is aged about 19 years and also she herself went with the applicant and another to marry with the applicant.\",\n \"The statement of the victim was recorded under Section 164 of Cr.P.C. on 08.11.2023, in which she changed her version of the statement given under Section 161 of Cr.P.C. and stated that she is aged about 17 years and the applicant, another kidnapped her on 01.11.2023 and committed rape with her.\"\n ],\n \"grounds_for_bail:\": [\n \"The statement of the victim is unbelievable and beyond the imagination, once the victim admitted the relationship with the applicant in her statement given under Section 161 of Cr.P.C. and later on in the statement of the 164 of Cr.P.C., she changed her statement under the pressure of her family members.\",\n \"The prosecution case is unworthy of any credit.\",\n \"There are several material contradictions shown between the first information report and the statements recorded under Sections 161 & 164 of Cr.P.C. of the victim regarding the manner of commission of the alleged crime.\",\n \"The victim has been residing almost around four days with her own WILL house but never raised any alarm at any point of time, and the prosecution story as narrated therein is highly improbable, improper and unnatural, and unbelievable for a prudent man.\",\n \"The story of the prosecution is based on only presumption and concerned police avoiding the truth of the case, and there is no evidence against the applicant.\",\n \"There is no credible evidence on record that could show that the applicant is guilty or committed the crime in question, and the evidence available on the record itself show that no prima-facie offense under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 is made out against the applicant.\"\n ],\n \"criminal_history:\": [\n \"The applicant has no criminal history except the aforesaid false case.\"\n ],\n \"undertakings_and_assurances:\": [\n \"The applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 200 of 2023 under Sections 363, 366 of I.P.C. (lodged on 04.11.2023)\",\n \"* 2. Case Crime No. 294 of 2020 under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 (lodged on 08.12.2023)\",\n \"* 3. Case No. 3178 of 2023 (bail application rejected by Additional District Judge/ Special Judge, (POCSO), Pratapgarh on 07.02.2023, with a correction order passed on 22.02.2024)\"\n ],\n \"grounds_for_bail\": [\n \"The instant matter is not related to CBI/Prevention of Corruption Act/Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc.\",\n \"The statement of the victim is unbelievable and beyond the imagination, as she admitted the relationship with the applicant in her statement given under Section 161 of Cr.P.C. and later on in the statement of the 164 of Cr.P.C., she changed her statement under the pressure of her family members.\",\n \"There are several material contradictions shown between the first information report and the statements recorded under Sections 161 & 164 of Cr.P.C. of the victim regarding the manner of commission of the alleged crime.\",\n \"The prosecution case is unworthy of any credit.\",\n \"The victim has been residing almost around four days with her own WILL house but never raised any alarm at any point of time and prosecution story as narrated therein is highly improbable, improper and unnatural, and unbelievable for a prudent man.\",\n \"According to the prosecution story, it clearly reveals that the story of the prosecution is based on only presumption and concerned police avoiding the truth of the case and there is no evidence against the applicant.\",\n \"There is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima-facie offense under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 is made out against the applicant.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "I, Smt. Chanar Devi aged about 50 years wife of Late Ram Fer resident of Village – Gadiyani, Manraunda, District – Prayagraj (earlier Allahabad), Education– Illiterate, Occupation – Housewiefe, do hereby solemnly affirm and state on oath as under:-"
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent is the mother/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such dhe is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and a photo affidavit slip issued by the Oudh Bar Association is affixed to the affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to her as such she conversant with the facts of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc."
},
{
"label": "APPLICANT DETAILS",
"content": "That this is the first bail application of the applicant before this Hon'ble Court. No other bail application is pending before this Hon'ble High Court or rejected by this Hon'ble High Court."
},
{
"label": "F.I.R DETAILS",
"content": "That the brief facts of the case are that a first information report was lodged against the applicant on 04.11.2023 by opposite party No. 2 bearing Case Crime No. 200 of 2023 under Sections 363, 366 of I.P.C., regarding the incident dated 01.11.2023. The certified/typed copy of the first information report dated 04.11.2023 is being annexed herewith as Annexure No. 01 to this affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That according to the first information report opposite party No. 2 stated in her first information report that on 01.11.2023, her 19-year-old daughter, abaducted by the applicant and another accused."
},
{
"label": "F.I.R DETAILS",
"content": "That the alleged incident which was taken place on 01.11.2023 but the first information report was lodged on 04.11.2023 hours, without giving any explanation with regard to the 4 days delay caused in lodging the first information report, which is already questionable and doubtful as the opposite party No. 2 lodged aforesaid first information after legal advice."
},
{
"label": "F.I.R DETAILS",
"content": "That on the very same day i.e. on 04.11.2023, the statement of the opposite party No. 2 was recorded by the concerned police under Section 161 of Cr.P.C., in which she almost repeated the version of her first information report with improved facts to falsely implicate the applicant. The typed copy of the statement of the opposite party No. 2 dated 04.11.2023 is being annexed herewith as Annexure No. 02 to this affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That the statement of the victim was recorded by the concerned police under Section 161 of Cr.P.C. on 04.09.2023 in which she stated that she is aged about 19 years and also she herself went with the applicant and another to marry with the applicant. The typed copy of the statement of the victim is being annexed herewith as Annexure No. 03 to this affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That here it is relevant to mention that the age of the victim was mentioned as 19 years in the first information report and statements of the opposite party No. 2 & victim."
},
{
"label": "Facts of the Case",
"content": "That the medical examination of the victim was conducted on 06.11.2023 by the doctor concerned, therein neither any injury was found on her body nor any other incriminating findings were mentioned in the medical examination of the vicitm. The radiological age of the victim has been ascertained as 18 years vide report supplementary medical report. The photo/typed copy of the medical report of the victim along with the supplementary medical report is being annexed herewith as Annexure No. 04 to this affidavit."
},
{
"label": "Facts of the Case",
"content": "That the statement of the victim was recorded under Section 164 of Cr.P.C. by the court concerned on 08.11.2023, in which she changed her version of the statement given under Section 161 of Cr.P.C. and stated that she is aged about 17 years and the applicant, another kidnapped her on 01.11.2023 and committed rape with her. The typed copy of the statement of the victim recorded under Section 164 of Cr.P.C. is being annexed herewith as Annexure No. 05 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the statement of the victim is unbelievable and beyond the imagination, once the victim admitted the relationship with the applicant in her statement given under Section 161 of Cr.P.C. and later on in the statement of the 164 of Cr.P.C., she changed her statement under the pressure of her family members."
},
{
"label": "CUSTODY STATUS",
"content": "That the victim was recovered by the concerned police on 04.11.2023, which is mentioned in the Sr. No. 8 of CD No. 1 dated 04.11.2023 and her custody was given to the opposite party No. 2 however, in the statement given under Section 164 of Cr.P.C., stated that she herself called her mother i.e. opposite party No. 2 when she was thrown by the applicants."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there are several material contradictions shown between the first information report and the statements recorded under Sections 161 & 164 of Cr.P.C. of the victim regarding the manner of commission of the alleged crime. The prosecution case is unworthy of any credit."
},
{
"label": "F.I.R DETAILS",
"content": "That without proper investigation, the investigating officer submitted a charge sheet No. 294 of 2020 against the applicant under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 against the applicant, his brother, father and another on 08.12.2023."
},
{
"label": "Facts of the Case",
"content": "That the real fact of the case is that the applicant was working in the village of the opposite party No. 2, and met with the victim and they fallen in love and decided to marry."
},
{
"label": "Facts of the Case",
"content": "That the victim is belongs to another religion as such after coming to know regarding the relationship of the applicant and victim, her family threatened the applicant to face consiquences of the same."
},
{
"label": "Facts of the Case",
"content": "That on 01.11.2023, the victim left her house and went with the applicant to solemnized the marriage and residing with the applicant."
},
{
"label": "Facts of the Case",
"content": "That on 04.11.2023, the concerned police recovered the victim from Mauaima, Prayagraj, when the victim was with the applicant."
},
{
"label": "Facts of the Case",
"content": "That when the victim returned to her home thereafter the information report has been lodged against the applicant and another."
},
{
"label": "Facts of the Case",
"content": "That the whole story was cooked by the opposite party No. 2 and their family members on narration of the concerned police against the applicant, which has been explained by the concerned police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the victim has been residing almost around four days with her own WILL house but never raised any alarm at any point of time and prosecution story as narrated therein is highly improbable, improper and unnatural, and unbelievable for a prudent man."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story, it clearly reveals that the story of the prosecution is based on only presumption and concerned police avoiding the truth of the case and there is no evidence against the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima-facie offense under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 is made out against the applicant."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant moved bail application bearing No. 3178 of 2023 before Additional District Judge/ Special Judge, (POCSO), Pratapgarh and his bail application was rejected by the court concerned on 07.02.2023. A error was occured in the order and after moving the correction application, the free certified copy of the bail order was returned back to the court below for correction and correction order passed on 22.02.2024 and no free copy issued to the applicant. The certified copy of the bail rejection order dated 07.02.2023 passed by the court below along with the correction order dated 22.02.2024 is being annexed herewith as Annexure No. 06 to this affidavit."
},
{
"label": "CRIMINAL HISTORY",
"content": "That the applicant has no criminal history except the aforesaid false case. the applicant has been languishing in jail since 15.11.2023."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of the applicant absconding or tempering with the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 200 of 2023 under Sections 363, 366, 376(D), 342, 506 of I.P.C. and 5G, 6 of The Protection of Children from Sexual Offences Act, 2012 registered at Police Station – Dilippur, District – Pratapgarh, in the interest of justice."
},
{
"label": "APPLICANT DETAILS",
"content": "Date :\t .2024"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"case_file:_rakesh_yadav_vs._state\": [],\n \"applicant_details:\": [],\n \"**name\": \"** Rakesh Yadav\",\n \"**age\": \"** 36 years\",\n \"**address\": \"** Ramganj, Ramganj, District - Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Not mentioned\",\n \"**religion\": \"** Hindu\",\n \"**education\": \"** Literate\",\n \"**relationship_with_applicant\": \"** Brother/Pairokar (authorized representative)\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** Case Crime No. 206 of 2022\",\n \"**sections\": \"**\",\n \"**date\": \"** Not mentioned\",\n \"**police_station\": \"** Aaspur Devsara, District Pratapgarh\",\n \"bail_rejection_order_details:\": [\n \"Not mentioned in the document\"\n ],\n \"key_facts_of_the_case:\": [\n \"The applicant, Rakesh Yadav, has been in jail for approximately 9 months without committing any offense.\",\n \"The applicant's father is suffering from acute depression and has a history of heart disease.\",\n \"The applicant's father recently had a major heart attack and is currently in the hospital.\",\n \"The applicant's family members, including the father, are suffering due to the non-disposal of the bail application.\",\n \"The applicant is suffering irreparable loss and injury due to the false implication by the opposite party.\"\n ],\n \"custody_status:\": [\n \"The applicant's bail application is still pending before the Hon'ble High Court for consideration since its filing.\"\n ],\n \"supporting_documents_and_details:\": [\n \"ID proof of the applicant's representative (deponent) is enclosed with the affidavit.\",\n \"Photograph of the deponent is affixed on the affidavit.\"\n ],\n \"medical_report:\": [\n \"Not mentioned in the document\"\n ],\n \"statement_recorded:\": [\n \"The deponent (applicant's representative) has recorded a statement in support of the application, stating that he is fully conversant with the facts of the case and has deposed as under.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 206 of 2022 under sections 354 (Kha), 504, 506, IPC and 7/8 of The Protection of Children from Sexual Offences Act, 2012 and 67 of Information Technology Act, registered at Police Station - Aaspur Devsara, District Pratapgarh.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant is in jail for around 9 months without committing any offense.\",\n \"The applicant's father is in deep mental trauma and suffering from acute depression due to the applicant's prolonged imprisonment.\",\n \"The applicant's father has a pre-existing heart disease and recently suffered a major heart attack, and the applicant's continued imprisonment may lead to his father's death.\",\n \"The non-disposal of the bail application is causing suffering to the applicant and his family members.\",\n \"The applicant is suffering irreparable loss and injury due to the false implication by the opposite party in the case.\",\n \"The applicant is suffering mentally and physically due to the pendency of the bail application.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Rakesh Yadav aged about 36 years son of Shri Kanhaiyalal resident of Ramganj, Ramganj, District - Pratapgarh, Religion – Hindu, Education – Literate, Occupation – _________, deponent do hereby solemnly affirm and state as under:-"
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent is the brother/pairokar of the applicant and duly authorized by him and as such he is fully conversant with the facts of the case and deposed as under. The photograph of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit."
},
{
"label": "CUSTODY STATUS",
"content": "That it is relevant to mention here that the present application of bail is still pending before this Hon'ble High Court for consideration since its filing."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is in jail around 9 months without committing any offense as such the father of the applicant is in deep mental trauma and suffering from acute depression."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the father of the applicant also had heart disease and recently he was admitted to hospital after a major heart attack, if the applicant is not released on bail, the father of the applicant would die."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That due to the non-disposal of the instant bail application, which is liable to be allowed in view of the facts and circumstances of the case, the applicant and family members are suffering."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That due to the non-disposal of the bail application filed by the applicant, the applicant is suffering irreparable loss and injury which cannot be compensated in any manner as the opposite party No. 2 falsely implicates the applicant in said case crime."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That due to the pendency of the aforesaid bail, the applicant is also suffering a lot as mentally and physically."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That for the facts, reasons and circumstances stated hereinabove, it is most respectfully prayed that this Hon’ble Court may kindly be pleased to enlarge the applicant on bail in connection with Case Crime No. 206 of 2022 under sections 354 (Kha), 504, 506, IPC and 7/8 of The Protection of Children from Sexual Offences Act, 2012 and 67 of Information Technology Act, registered at Police Station - Aaspur Devsara, District Pratapgarh, in the interest of justice."
},
{
"label": "APPLICANT DETAILS",
"content": "Date : .2024\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"**name\": \"** Prema Devi\",\n \"**age\": \"** 50 years\",\n \"**address\": \"** Village – Manau Ka Purva Hamlet of Mauli, Police Station - Kunda, District – Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Agriculture\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** Literate\",\n \"**relationship_to_the_applicant\": \"** Mother of the applicant and doing pairvi of the applicant in the above-noted case\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** Crime No. 23 of 2015\",\n \"**sections\": \"** 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961\",\n \"**date\": \"** 15.01.2015\",\n \"**police_station\": \"** Kunda, District – Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"**order_date\": \"** 11.09.2015\",\n \"**court\": \"** Additional Sessions Judge/F.T.C., Pratapgarh\",\n \"**reason_for_rejection\": \"** Insufficient grounds\",\n \"key_facts_of_the_case:\": [\n \"The applicant was falsely implicated in the case.\",\n \"The informant, Shri Shri Algu Ram, lodged the FIR after a compromise was taken place between the applicant and the deceased on 11.01.2010.\",\n \"The informant delayed lodging the FIR for three days after the incident and gave a false statement to the police.\",\n \"The post-mortem report revealed that the cause of death was \\\"asphyxia as a result of anti-mortem drowning.\\\"\",\n \"The injuries found on the body of the deceased were simple and caused during falling in the well, not by beating as alleged by the informant.\",\n \"The applicant and the deceased were married in 2007 and had a child in 2009. They had a compromise in 2010, and their life was running smoothly until the incident.\",\n \"The applicant informed the police and the informant about the incident, and the informant was present at the time of the inquest report.\"\n ],\n \"custody_status:\": [\n \"The applicant/accused is in jail since 17.01.2015.\"\n ],\n \"supporting_documents_and_details:\": [\n \"Photocopy of ID proof of the deponent (Prema Devi)\",\n \"Photocopy of the first information report (FIR) dated 15.01.2015 (Annexure No. 1)\",\n \"Photocopy of the inquest report dated 13.01.2015 (Annexure No. 2)\",\n \"Photocopy of the post-mortem report dated 13.01.2015 (Annexure No. 3)\",\n \"Photocopy of the statement of the informant (Annexure No. 4)\",\n \"Certified copy of the bail rejection order dated 11.09.2015 (Annexure No. 5)\"\n ],\n \"medical_report:\": [\n \"The post-mortem report revealed that the cause of death was \\\"asphyxia as a result of anti-mortem drowning.\\\"\"\n ],\n \"statement_recorded:\": [\n \"The informant's statement was recorded by the police under section 161 Cr.P.C., and he repeated his first information report version in another manner but with the same soul.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 23 of 2015 under Sections 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh on 15.01.2015.\"\n ],\n \"grounds_for_bail\": [\n \"This is the first bail application on behalf of the applicant before the court, and no other bail application is pending before any court of law on his behalf.\",\n \"The prosecution story is based on presumption and the concerned police have avoided the truth of the case.\",\n \"There is no evidence against the applicant/accused.\",\n \"The applicant has no motive to commit the crime in question.\",\n \"The informant has lodged the first information report after legal consultation, and the marriage of the deceased with the applicant was solemnized in 2007, not 5 years ago as alleged.\",\n \"There is no credible evidence on record to show that the applicant is guilty or committed the crime in question.\",\n \"The evidence available on record shows that no prima-facie offence under section 302 I.P.C. is made out against the applicant.\",\n \"The applicant has no motive to commit the alleged crime, and the false motive given in the case is cooked and fabricated by the concerned police.\",\n \"The applicant has not committed any offence as alleged but has been falsely implicated in the case by the informant in malafide intention.\",\n \"The applicant has no reason to murder the deceased.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant has no criminal history except the aforesaid false case and is not likely to commit any offence in the future.\",\n \"There is no chance of the applicant absconding or tampering with the prosecution witnesses.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Prema Devi aged about 50 years wife of Sri Ram Badan resident of Village – Manau Ka Purva Hamlet of Mauli, Police Station - Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is mother of applicant and also doing pairvi of applicant in the above noted case duly authorized by him and as such she is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That this is first bail application on behalf of the applicant before the and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant have falsely been implicated in case crime No. 23 of 2015 under Sections 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh on 15.01.2015 at 18:30 hours, against the applicant and one other person namely Ram Badan, who is the father of the applicant. The first information report is lodged by father of the deceased namely Shri Shri Algu Ram. The true photo/type copy of the first information report dated 15.01.2015 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the informant stated in his first information report that the marriage of the applicant and his daughter Geeta Devi (hereinafter referred to as deceased) was solemnized around five years ago and the family members of the applicant were tortured on his daughter for dowry. Thereafter a compromise was taken place between the applicant and deceased on 11.01.2010 as they would live happily but on 12.01.2015, the applicant along with his father murdered his daughter and his body throw in well."
},
{
"label": "Facts of the Case",
"content": "That the informant also stated as the body of deceased was recovered in presence of him by the concerned police on 12.01.2015 but after three days after consultation with his well-wishers, he lodged a first information report against the applicant/accused and his father on 15.01.2015 on wrong and baseless facts, without giving any explanation for delay."
},
{
"label": "Facts of the Case",
"content": "That the informant was present at the time of the preparation of the inquest report, which was prepared by the concerned police on 13.01.2015 and all “Panchan” given their opinion as the deceased has been died due to drowning, in said inquest the informant himself present and appointed as “Panchan”. The photo/type copy of the inquest report dated 13.01.2015 is being annexed herewith as Annexure No. 2 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the applicant himself informed to the concerned police in regard to said incident on 13.01.2015 and also he was appointed as “Panchan”."
},
{
"label": "Facts of the Case",
"content": "That the body of the deceased was send for the post mortem on 13.01.2015 at District Hospital, Pratapgarh wherein the post mortem was done by doctors. The photo/type copy of the post mortem report dated 13.01.2015 is being annexed herewith as Annexure No. 3 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That according to the post mortem report the three injuries found on the body of the deceased as below:"
},
{
"label": "Facts of the Case",
"content": "Contusion of 1.5cmX1cm midline of fore head, 7cm above just of nose."
},
{
"label": "Facts of the Case",
"content": "Abrasion of .08cmX0.7cm I front of left knee joint."
},
{
"label": "Facts of the Case",
"content": "Multiple abrasion in area of 4cmX3cm in front of left leg, just below left …………."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That as per post mortem report the cause of death is “asphyxia as a result of anti-mortem drowning.” By bare perusal of the post mortem report it is crystal clear that the nature of the injuries caused over the body of the deceased were simple and caused during falling in the well not by beaten as alleged by the informant."
},
{
"label": "F.I.R DETAILS",
"content": "That the statement of the informant has been recorded by the concerned police under section 161 Cr.P.C. and therein the informant repeated his first information report version in another manner but soul of the first information report in his statement. That the photocopy of the statement of the informant is being annexed herewith collectively as Annexure No. 4 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the real fact is this, marriage of the applicant with deceased solemnized in year 2007 and after wedlock of both, the deceased born a child in year of 2009, thereafter some misunderstanding were arisen and same has been resolved and a compromised has been executed 11.01.2010 between the parties concerned."
},
{
"label": "Facts of the Case",
"content": "That after said compromise everything was good and life the of applicant and deceased smoothly running but on 12.01.2015 around 7-8PM the deceased went to well to drinking water when she took more time, then applicant came out then he saw, in meantime the deceased was fallen down in well when she was pulling the water from the well, when the alarm was raised by him then the villagers were come at incident spot and the after that the deceased was pullout from the well but there was too late, she was died."
},
{
"label": "Facts of the Case",
"content": "That informant was informed by the applicant in regard to misshaping and the informant along with other persons come at the house of the applicant and they are also present at time of inquest report and he was himself become “Panchan”."
},
{
"label": "Facts of the Case",
"content": "That the investigating officer submitted the charge sheet before the court concerned on 27.02.2015 bearing No. 05 of 2015 under Sections 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961 without considering the fact and reality of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that story of the prosecution is based on only presumption and concerned police avoiding the truth of case and there is no an evidence against the applicant/accused."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That neither the applicant has motive nor has any motive been assigned to him to commit the crime in question, when he was happy with the deceased and no any issue between the deceased and applicant in regard to dowry as alleged by the informant."
},
{
"label": "F.I.R DETAILS",
"content": "That the first information report has been lodged by the informant after legal consultation in result of same the marriage of the deceased with applicant tried to established around 5 years old whereas the marriage of the applicant with deceased solemnized in year 2007."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under section 302 I.P.C. is made out against the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no motive to commit the alleged crime and false motive which given in case, is cooked and fabricated by the concerned police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That no any involvement in the said case as alleged in first information report, the applicant has no reason to murder the deceased."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is common man of the society. He has never involved in any criminal activities ever."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no criminal history except the aforesaid false case and not likely to hope in future to commit any offence."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this ."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant/accused is in Jail since 17.01.2015."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that they will not misuse the liberty of bail if so granted by this ."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the may deems fit and proper in the circumstances of the case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant had applied for bail but the same has been rejected by the Additional Sessions Judge/F.T.C., Pratapgarh on insufficient grounds vide order dated 11.09.2015. The certified copy of bail rejection order dated 11.09.2015 is annexed herewith as Annexure No. 5 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2016\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"**name\": \"** Babban Singh\",\n \"**age\": \"** 25 years\",\n \"**address\": \"** Dadauli, Post – Raghauli, Police Station – Manikpur, District – Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Agriculture\",\n \"**qualification\": \"** High School\",\n \"**religion\": \"** Hindu\",\n \"**relationship_to_the_applicant\": \"** Relative of Applicant No. 2 and Pairokar of the applicant\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** Crime No. 07 of 2014\",\n \"**sections\": \"** 302 I.P.C.\",\n \"**date\": \"** 25.01.2014\",\n \"**police_station\": \"** Manikpur, District – Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"**order_date\": \"** 17.05.2014\",\n \"**court\": \"** Sessions Judge, Pratapgarh\",\n \"**reason_for_rejection\": \"** Insufficient grounds\",\n \"key_facts_of_the_case:\": [\n \"The applicant was falsely implicated in the case.\",\n \"The FIR was lodged by the brother of the deceased, Dev Prasad Patel.\",\n \"The FIR was registered on 25.01.2014.\",\n \"The prosecution story is that the deceased was shot multiple times and found dead in his own vehicle.\",\n \"The investigation officer filed the charge sheet against the applicant and two other persons on 05.05.2014.\",\n \"The prosecution's story has several contradictions and inconsistencies.\"\n ],\n \"custody_status:\": [\n \"The applicant surrendered before the C.J.M., Pratapgarh on 24.03.2014.\",\n \"The applicant has been in jail since 13.02.2014.\"\n ],\n \"supporting_documents_and_details:\": [],\n \"annexure_no._1\": \"True photo/type copy of the first information report dated 25.01.2014\",\n \"annexure_no._2\": \"Type copy of the statement of complaint under section 161 Cr.P.C.\",\n \"annexure_no._3\": \"True photo/type copy of the post mortem report dated 26.01.2014\",\n \"annexure_no._4\": \"Type copy of the further statement (Mazeed Bayan) dated 27.01.2014\",\n \"annexure_no._5\": \"Type copy of the statement of brother of the deceased dated 27.01.2014\",\n \"annexure_no._6\": \"Type copy of the statement of son of the deceased Krishna Kumar dated 27.01.2014\",\n \"annexure_no._7\": \"Type copy of the statement of so-called eye witness Dinesh Kumar alias Babloo dated 29.01.2014\",\n \"annexure_no._8\": \"Certified copy of bail rejection order dated 29.05.2014\",\n \"medical_report:\": [\n \"Not mentioned\"\n ],\n \"statement_recorded:\": [\n \"The applicant has recorded his statement before the deponent, stating that he is a relative of Applicant No. 2 and Pairokar of the applicant, and is fully conversant with the facts of the case.\"\n ],\n \"grounds_for_bail:\": [\n \"The prosecution story has several contradictions and inconsistencies.\",\n \"There is no eye witness to the case.\",\n \"The case is a case of forged and planted eyewitness and evidence.\",\n \"The applicant has not committed any crime as alleged in the FIR.\",\n \"The applicant has no criminal history.\",\n \"The applicant is a respectable person of the society.\",\n \"The applicant is willing to cooperate with the trial and will not tamper with the prosecution witnesses.\"\n ],\n \"undertakings_and_assurances:\": [\n \"The applicant undertakes to cooperate with the trial and will not tamper with the prosecution witnesses.\",\n \"The applicant undertakes not to misuse the liberty of bail if so granted by the court.\",\n \"The applicant is ready and willing to file adequate surety as the court may deem fit and proper in the circumstances of the case.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 07 of 2014 under section 302 I.P.C. registered at Police Station – Manikpur, District – Pratapgarh on 25.01.2014.\"\n ],\n \"grounds_for_bail\": [\n \"The prosecution story clearly reveals that no one saw the occurrence and there is no any eye witness of the case.\",\n \"The case is a forged and planted eyewitness and evidence.\",\n \"There is no evidence against the applicant/accused.\",\n \"The applicant has not committed any crime as alleged in the first information report and he has no concern.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant is a respectable person of the society and has never involved in any criminal activities and has no any criminal history.\",\n \"There is no chance of applicant absconding or tampering with the prosecution witnesses.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Babban Singh aged about 25 years son of Samar Bahadur Singh resident of Dadauli, Post – Raghauli, Police Station – Manikpur, District – Pratapgarh, Religion – Hindu, Qualification – High School, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is relative of applicant No. 2 and Pairokar of the applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of Voter ID of the deponent is being annexed with this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That this is first bail application on behalf of the applicant before the and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant have falsely been implicated in case crime No. 07 of 2014 under section 302 I.P.C. registered at Police Station – Manikpur, District – Pratapgarh on 25.01.2014. The first information report is lodged by the brother of deceased namely Dev Prasad Patel. The true photo/type copy of the first information report dated 25.01.2014 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the according the First Information Report the prosecution story is, the deceased has Tata Magic registration No. UP 32 DN – 3659 and same was operated by the deceased. When on 24.01.2014 the deceased was not come to home then the complaint start searching him. Next morning i.e. 25.01.2014 at 05.30 AM the body of complaint’s brother was found on the seat of driver of his own vehicle at Bhadchak – Dandauli road near Mahauta. There were multiple gun shots injuries shown on the body of the deceased and blood was oozing and some gun shots are also found on front of vehicle."
},
{
"label": "F.I.R DETAILS",
"content": "That the complaint lodge the first information report on the suspicious ground due to old enmity with the father of applicant and another person namely Kamlesh."
},
{
"label": "F.I.R DETAILS",
"content": "That the first information report lodge against the applicant and three other persons on the suspicious and baseless ground."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statement of complaint recorded under section 161 Cr.P.C. on the same day. The compliant supported the first information report version. The type copy of the statement of the complaint under section 161 Cr.P.c. is being annexed herewith as Annexure No. 2 to this Affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the post mortem of the deceased done on 26.01.2014 at , Pratapgarh. As per post mortem report the cause of death of the deceased is comuama and hammarage and shock as a reamly of Antimortem fire arms injury. The true photo/type copy of the post mortem report dated 26.01.2014 is being annexed herewith as Annexure No. 3 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That after two days on 27.01.2014, after lodging the first information and giving the statement under section 161 Cr.P.C., the complaint recorded his further statement (Mazeed Bayan) before the investigation officer and build a new prosecution story and stated, time of the incident, one witness namely Dinesh Kumar alias Babloo (brother-in-law of the brother of deceased namely Krishna Kumar Patel) is present and see the incident."
},
{
"label": "Facts of the Case",
"content": "That as per information given by the Dinesh Kumar alias Babloo the compliant stated in his further statement that at the time of incident, when the multiple gun shots are fired by the accused persons, at the same time one accused had also injured by the gun shot during the firing but the Dinesh Kumar alias Babloo not identified the injured accused, while the Dinesh Kumar alias Baloo indentified the all four accused by name. The type copy of the further statement (Mazeed Bayan) dated 27.01.2014 is being annexed herewith as Annexure No. 4 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the brother of the deceased namely Krishna Kumar Patel also recorded his statement under section 161 Cr.P.C. before the authority concerned on 27.01.2014 and stated on 24.01.2014 at the incident place, the deceased and all four accused person are chatting with together and when he ask to the deceased about the meeting then the deceased replies everything is fine and supporting the further statement of the complaint. The type copy of the statement of brother of the deceased dated 27.01.2014 is being annexed herewith as Annexure No. 5 to this Affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the son of the deceased namely Amarjeet Patel also recorded his statement before the investigating officer on 27.01.2014 under section 161 Cr.P.C. and also supported the statement of his uncle statement namely Krishna Kumar Patel. There was no any change in the both statements except style of stating his statements. The type copy of the statement of son of the deceased Krishna Kumar dated 27.01.2014 is being annexed herewith as Annexure No. 6 to this Affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the so called eye witness namely Dinesh Kumar alias Babloo recorded his statement before the investigation officer on 29.01.2014 under section 161 Cr.P.C.. The so called eye witness stated in his statement, he was present at the time of the incident i.e. 08.30 PM of 24.01.2014. The so called eye witness identified the accused persons. The type copy of the statement so called eye witness dated 29.01.2014 is being annexed herewith as Annexure No. 7 to this Affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the so called eye witness stated in his statement, the applicant has been shouting/encourage to other accused for killing to the deceased."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant is surrendered before the C.J.M., Pratapgarh on 24.03.2014 and applicant sent to jail."
},
{
"label": "F.I.R DETAILS",
"content": "That the first information report lodged against the four persons. After the investigation, the investigation officer filed the charge sheet against the applicant and two other persons in court concerned on 05.05.2014."
},
{
"label": "Facts of the Case",
"content": "That the no any specific roll was assigned by the prosecution against the applicant or any accused."
},
{
"label": "Facts of the Case",
"content": "That a contradiction in the statement of the so called eyewitness and informant’s statement, according the eyewitness he was seeing the incident at the time of occurrence and he was not informed to police or the informant at that time."
},
{
"label": "Facts of the Case",
"content": "That the so called eyewitness has seen the incident at the dark and foggy night of the cold weather, which is highly suspicious."
},
{
"label": "Facts of the Case",
"content": "That the so called eyewitness is not disclose the about the incident to anyone till the crimination of the deceased, this is also highly suspicious and same is planted eyewitness after the post mortem of the deceased."
},
{
"label": "Facts of the Case",
"content": "That the investigation officer recovered the Rifle only showing the good work of the police department."
},
{
"label": "Facts of the Case",
"content": "That the recovery of the Rifle is highly suspicious and contradictory because of the aforesaid Rifle is licensed to the mother of the applicant and the same was never used by the applicant."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is student and perusing his B.A.."
},
{
"label": "Facts of the Case",
"content": "That the so called eyewitness is stated in his statement he identified the accused persons and during the firing the one accused was injured. But all accused presently in District Jail, Pratapgarh and has not received any fire arm injury. This is unbelievable as the eyewitness stated in his statement."
},
{
"label": "Facts of the Case",
"content": "That the so called eyewitness stated in his statement he saw the incident in the front light of the Tata Magic but he not reveal which accused fired his fire arm on the deceased."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has not committed any crime as alleged in the first information report and he has no concern."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicants are respectable persons of the society. He has never involved in any criminal activities and has no any criminal history."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this ."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicants are in Jail since 13.02.2014."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that they will not misuse the liberty of bail if so granted by this ."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the may deems fit and proper in the circumstances of the case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant had applied for bail before the Sessions Judge, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 17.05.2014. The certified copy of bail rejection order dated 29.05.2014 is annexed herewith as Annexure No. 8 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2014\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"**name\": \"** Durgesh Pratap Singh\",\n \"**age\": \"** 38 years\",\n \"**address\": \"** Pure Purviyan Ka Purwa, Police Station - Kunda, District - Pratapgarh\",\n \"**qualification\": \"** Literate\",\n \"**occupation\": \"** Agriculture\",\n \"**relationship_with_the_applicant\": \"** Brother/Pariokar (authorized by the applicant to file the application)\",\n \"**contact_information\": \"** Not mentioned\",\n \"**other_relevant_personal_details\": \"** Father's name: Shri Brijendra Pratap Singh, has a 10-month-old baby with the applicant\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** 386 of 2023\",\n \"**sections\": \"** 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961\",\n \"**date_of_fir\": \"** 23.10.2023\",\n \"**police_station\": \"** Kunda, District - Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"**bail_application_number\": \"** Bail Application No. 3522 of 2023\",\n \"**court\": \"** Sessions Judge, Lucknow\",\n \"**order_date\": \"** 19.01.2024\",\n \"**reason_for_rejection\": \"** Insufficient grounds\",\n \"key_facts_of_the_case:\": [\n \"The applicant's marriage with the deceased, Anjali Singh, was solemnized two years ago.\",\n \"The informant, Kamlesh Singh, lodged an FIR against the applicant and his family members, alleging that the applicant and his family members physically assaulted and murdered the deceased by strangulation.\",\n \"The informant's statement under Section 161 Cr.P.C. revealed that he planned and falsely implicated the applicant and his family members to get financial benefit.\",\n \"The inquest report prepared by the police on 23.10.2023 stated that the deceased committed suicide.\",\n \"The post-mortem report dated 24.10.2023 confirmed that the cause of death was 'Anti-mortem hanging' with no injuries found on the body.\",\n \"The informant's mother's statement under Section 161 Cr.P.C. on 07.11.2023 repeated the informant's version and tried to falsely implicate the applicant and his family members.\",\n \"The applicant and his family members were exonerated from all charges during the investigation.\",\n \"The investigating officer submitted a charge sheet against the applicant and others under Sections 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 on 17.11.2023.\"\n ],\n \"custody_status:\": [\n \"The applicant has been in jail since 25.10.2023 without committing any crime.\"\n ],\n \"supporting_documents_and_details:\": [],\n \"annexure_no._1\": \"Certified copy of the first information report dated 23.10.2023\",\n \"annexure_no._2\": \"Photo/typed copy of the inquest report dated 23.10.2023\",\n \"annexure_no._3\": \"Photo/type copy of the post-mortem report dated 24.10.2023\",\n \"annexure_no._4\": \"Typed copy of the statement of the informant dated 24.10.2023\",\n \"annexure_no._5\": \"Photocopy of the statement of the mother of the deceased dated 07.11.2023\",\n \"annexure_no._6\": \"Photocopy of the charge sheet dated 17.11.2023\",\n \"annexure_no._7\": \"Free certified copy of the bail rejection order dated 19.01.2024\",\n \"medical_report:\": [\n \"Not mentioned\"\n ],\n \"statement_recorded:\": [\n \"The informant's statement under Section 161 Cr.P.C. on 24.10.2023\",\n \"The informant's mother's statement under Section 161 Cr.P.C. on 07.11.2023\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 386 of 2023 lodged under Sections 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh on 23.10.2023.\"\n ],\n \"grounds_for_bail\": [\n \"The instant matter is not related to CBI/Prevention of Corruption Act/Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc.\",\n \"This is the first bail application on behalf of the applicant before the Hon'ble Court and no other bail application is pending before in any court of law on his behalf.\",\n \"The informant planned and falsely implicated the applicant and his family members to get financial benefit.\",\n \"The first information report has been lodged against the applicant and his family members on wrong and baseless facts.\",\n \"The informant has lodged the first information report against the applicant and others for his self-satisfaction.\",\n \"The informant is well aware that his daughter herself committed suicide for her own reasons.\",\n \"The prosecution story is based on only presumption and concerned police avoiding the truth of the case and there is no evidence against the applicant/accused.\",\n \"The applicant is being the husband of the deceased falsely implicated in the said case crime by the informant along with his family while the deceased committed suicide for her own reasons.\",\n \"The informant due to extraneous reasons named the brother & sister-in-law of the applicant in the case, and during the Investigation Office, they have been exonerated from all charges.\",\n \"There is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima facie offense is made out against the applicant.\",\n \"The applicant has no motive to commit the alleged crime and a false motive which was given in the case, is cooked and fabricated by the concerned police.\",\n \"Since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant with malafide intention.\",\n \"No involvement in the said case as alleged in the first information report, the applicant has no reason to murder the deceased.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant is ready and willing to file adequate surety as the Hon'ble Court may deem fit and proper in the circumstances of the case.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of the first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Durgesh Pratap Singh aged about 38 years son of Shri Brijendra Pratap Singh resident of Pure Purviyan Ka Purwa, Police Station - Kunda, District - Pratapgarh, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under:-"
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent is the brother/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to her as such he conversant with the facts of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That this is the first bail application on behalf of the applicant before the Hon'ble Court and no other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant has falsely been implicated in case crime No. 386 of 2023 lodged under Sections 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh on 23.10.2023 at 19.30 hours, against the applicant, his brother and his sister-in-law (Bhabhi). The first information report is lodged by Shri Kamlesh Singh son of Shri Tribhuwan Singh resident of Village - Sarai Taluke Sahavpur, Dahiyavan, Bazar Soravan, Ganga Nagar, Prayagraj (hereinafter referred to as ‘informant’). The certified copy of the first information report dated 23.10.2023 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the informant stated in his first information report that the marriage of the applicant and his daughter namely Anjali Singh (hereinafter referred to as ‘deceased’) was solemnized before two years. On 22.10.2023 the deceased was physically assutled and was murdered by the applicant and two others by strangulation."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That it is relevant to mention here that the informant planned and falsely implicated the applicant and his family members to get financial benefit. Thereafter on the basis of legal advice, the first information report has been lodged against the applicant and his family members on wrong and baseless facts."
},
{
"label": "Facts of the Case",
"content": "That the inquest report was prepared by the concerned police on 23.10.2023 in the presence of the Panchan and also in the presence of the informant and applicant, in which they unanimously stated that the deceased committed suicide herself. The photo/typed copy of the inquest report dated 23.10.2023 is being annexed herewith as Annexure No. 2 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That the body of the deceased was sent for the post-mortem on 24.10.2023 at District Hospital, Pratapgarh wherein the post-mortem was done by doctors, and the cause of death was ascertained as ‘Anti-mortem hanging”. And no any injury was found on the body of the deceased. The photo/type copy of the post-mortem report dated 24.10.2023 is being annexed herewith as Annexure No. 3 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That according to the post-mortem report, the time of death of the deceased was about one day back, which is also not collaborated with the prosecution story."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statement of the informant was recorded by the concerned police under section 161 Cr.P.C. on 24.10.2023 and therein the informant repeated his first information report version in another manner and tried to develop his prosecution story to fill the loopholes of the prosecution story to send the applicant behind the bar merely being the husband of the deceased. The typed copy of the statement of the informant dated 24.10.2023 is being annexed herewith as Annexure No. 4 to this Affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statement of the mother of the deceased was also recorded by the concerned police under section 161 Cr.P.C. on 07.11.2023 in which she repeated the version of the informant in her own words and tried their best to falsely implicate the applicant and his family members in said case crime. The photocopy of the statement of the mother of the deceased dated 07.11.2023 is being annexed herewith as Annexure No. 5 to this affidavit."
},
{
"label": "Facts of the Case",
"content": "That the real fact of the case is that the marriage of the applicant and the deceased was solemnized according to the Hindu rituals."
},
{
"label": "Facts of the Case",
"content": "That nothing has been demanded from the applicant and his family from the informant and his family as dowry prior to and after the marriage as alleged against the applicant and others."
},
{
"label": "Facts of the Case",
"content": "That initially the relationship between the applicant and the deceased was good enough and there was no dispute between the applicant and the deceased."
},
{
"label": "Facts of the Case",
"content": "That later on, the deceased wanted to live separately from the other family members of the applicant and after creating a regular nuisance in the family by the deceased therefore to avoid family disputes with the deceased, the applicant started to live separately with other family members but thereafter the demands of the deceased increase day by day."
},
{
"label": "Facts of the Case",
"content": "That after the separation from the brother & sister-in-law, the deceased was not happy and she started pressruzing the applicant for shifting to another district and finding a job at that place, for which the applicant was not ready."
},
{
"label": "Facts of the Case",
"content": "That due to the denial of leaving the village, the deceased was annoyed and stopped talking with the applicant and also did not properly take care of little son."
},
{
"label": "Facts of the Case",
"content": "That prior to that incident, the deceased several times locked herself in the room but always opened the door within a couple of hours. The applicant and other family members of the applicant were well aware of the short-tempered nature of the deceased thus the applicant was rest assured that the door would open soon."
},
{
"label": "Facts of the Case",
"content": "That due to her shot-tempered nature, committed suicide due to her own reasons but the informant has lodged the first information report against the applicant and others for his self-satisfaction."
},
{
"label": "Facts of the Case",
"content": "That here it is relevant to mention that the deceased was a short-tempered lady and she became more aggressive and also not in a position to make good decisions due to her anger and committed suicide."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the informant due to extraneous reasons lodged the first information against the applicant and his family members after getting legal advice just for his satisfaction while he is well aware that his daughter herself committed suicide for her own reasons."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story, it clearly reveals that the story of the prosecution is based on only presumption and concerned police avoiding the truth of the case and there is no evidence against the applicant/accused."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is being the husband of the deceased falsely implicated in the said case crime by the informant along with his family while the deceased committed suicide for her own reasons."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the informant due to extraneous reasons named the brother & sister-in-law of the applicant in the case, and during the Investigation Office, they have been exonerated from all charges."
},
{
"label": "F.I.R DETAILS",
"content": "That the investigating officer without proper investigation of the case crime submitted the charge sheet against the applicant and others under bearing Charge Sheet on 17.11.2023 under Sections 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961. The photocopy of the charge sheet dated 17.11.2023 submitted in case crime is being annexed herewith as Annexure No. 6 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima facie offense is made out against the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no motive to commit the alleged crime and a false motive which was given in the case, is cooked and fabricated by the concerned police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant with malafide intention."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That no involvement in the said case as alleged in the first information report, the applicant has no reason to murder the deceased."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "CRIMINAL HISTORY",
"content": "That the applicant has no criminal history except the aforesaid case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of the applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant/accused is in jail since 25.10.2023 without committing any crime."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper with the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that they will not misuse the liberty of bail if so granted by this Hon’ble Court."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is the father of the 10 months baby, who is presently residing with the deponent."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deem fit and proper in the circumstances of the case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant had applied for bail application bearing Bail Application No. 3522 of 2023 but the same has been rejected by the Sessions Judge, Lucknow on insufficient grounds vide order dated 19.01.2024. The free certified copy of the bail rejection order dated 19.01.2024 is being annexed herewith as Annexure No. 7 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 386 of 2023 under Sections 498-A, 304-B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh, during the pendency of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2024\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"case_file_analysis:\": [],\n \"1._applicant_details:\": [],\n \"**name_and_age\": \"** Mohd. Naseem, aged about 27 years\",\n \"**address\": \"** Mauli, Police Station - Kunda, District – Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Self-Employed (running a vegetable shop)\",\n \"**religion\": \"** Muslim\",\n \"**education\": \"** Literate\",\n \"**relationship_with_deceased\": \"** Cousin Brother\",\n \"2._current_case_fir_details:\": [],\n \"**case_number\": \"** Not mentioned\",\n \"**sections\": \"** 498A, 304B I.P.C. and 3/4 The Dowry Prohibition Act\",\n \"**date_of_fir\": \"** 18.12.2013\",\n \"**police_station\": \"** Kunda, District – Pratapgarh\",\n \"3._bail_rejection_order_details:\": [],\n \"**date_of_rejection\": \"** 12.12.2014\",\n \"**order\": \"** The bail application of the applicant was rejected by the court concerned.\",\n \"**document\": \"** Annexure No. 04 to the application\",\n \"4._key_facts_of_the_case:\": [\n \"The applicant's marriage with the deceased was solemnized on 07.01.2013.\",\n \"The deceased was a short-tempered lady who demanded to leave the applicant's house and family.\",\n \"The applicant refused to leave his house and family, citing financial constraints.\",\n \"The deceased committed suicide on 17.12.2013, and the applicant was falsely implicated in the case.\",\n \"The investigating officer found no evidence against the other accused.\",\n \"The informant's story was based on false facts, and the applicant was innocent.\"\n ],\n \"5._custody_status:\": [\n \"The applicant has been in jail since 10.01.2014.\",\n \"He has no criminal history.\",\n \"He has not absconded or tampered with prosecution witnesses.\"\n ],\n \"6._supporting_documents_and_details:\": [\n \"ID Proof of the deponent (cousin brother of the applicant)\",\n \"Photograph of the deponent\",\n \"Photocopy of the first information report (Annexure No. 01)\",\n \"Photocopy of the post-mortem report (Annexure No. 02)\",\n \"Type copy of the statement of the informant (Annexure No. 03)\",\n \"Copy of the order dated 12.12.2014 passed by the court concerned (Annexure No. 04)\"\n ],\n \"7._medical_report:\": [],\n \"post-mortem_was_done_on_the_body_of_the_deceased_on_18.12.2013_at_4\": \"45 PM in District Hospital, Pratapgarh.\",\n \"8._statement_recorded:\": [\n \"The statement of the informant was recorded by the investigating officer on 18.12.2013, wherein the informant repeated the version of her first information report in detail.\"\n ],\n \"grounds_for_bail:\": [\n \"The applicant belongs to a poor family and earns a living by running a vegetable shop.\",\n \"The informant's story is unbelievable, and the applicant was falsely implicated in the case.\",\n \"The applicant has no motive to commit the alleged crime.\",\n \"The investigating officer found no evidence against the applicant.\",\n \"The applicant has no criminal history and is not likely to commit any offense in the future.\",\n \"The applicant is ready to furnish security and bond and undertake not to misuse his liberty on bail.\"\n ],\n \"criminal_history\": [\n \"* 1. Charge sheet filed by the investigation officer on 12.02.2014 against the applicant including his mother under section 498A, 304B I.P.C. and 3/4 The Dowry Prohibition Act.\",\n \"* 2. The applicant has been surrendered before the court on 10.01.2014 and moved the bail application before the court concerned, which has been rejected by the court concerned on 12.12.2014.\",\n \"* 3. The applicant has been in jail since 10.01.2014 and has no criminal history except the aforesaid false case.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant belongs to a very poor family and runs a vegetable shop on footpath to earn a living.\",\n \"The informant's allegation of the applicant and his family demanding a motorcycle and Rs. 50,000/- is unbelievable.\",\n \"The applicant was running a vegetable shop for the survival/livelihood of his family members but the deceased always pressurized him to bring her to another place.\",\n \"The economic status of the applicant did not allow him to bring the deceased to another place.\",\n \"There is no evidence found by the investigating officer in regard of demand of the dowry.\",\n \"The informant lodged the first information report on the wrong facts.\",\n \"The applicant is innocent and has been falsely implicated in the case by the informant in malafide intention.\",\n \"There is no any involvement in the said case as alleged in the first information report, the applicant has no reason to murder the deceased.\",\n \"A false story has been cooked up by the concerned police and informant as the applicant committing the aforesaid case crime.\",\n \"The applicant has no motive to commit the alleged crime and a false motive, for the money, has been fabricated by the concerned police.\",\n \"The applicant has no criminal history except the aforesaid false case and is not likely to hope in future to commit any offence.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "I, Mohd. Naseem aged about 27 years son of Khaleel Ahamad resident of Mauli, Police Station - Kunda, District – Pratapgarh, Religion – Muslim, Education – Literate, Occupation – Self Employed, do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the deponent is the cousin brother of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That this is the first bail application before this . No any other bail application pending before this or rejected by this ."
},
{
"label": "F.I.R DETAILS",
"content": "That brief facts of the case is that a first information report has been lodged against applicant and three family members of the applicant on 18.12.2013 on 09:15 hours by the mother of the deceased namely Shahnaz Bano, under section 498A, 304B I.P.C. and 3/4 The Dowry Prohibition Act on the basis of wrong facts, mentioning the incident took place on 18.12.2013. The photocopy of the first information report dated 18.12.2013 is being annexed as Annexure No. 01 to this application."
},
{
"label": "Facts of the Case",
"content": "That the informant stated in the first information report, the marriage of daughter of informant namely Nashreen Bano was solemnized with applicant on 07.01.2013 in District – Pratapgarh and expend the money according her capacity. Just after marriage, the applicant and his family member was demanding dowry as one Motorcycle and Rs. 50,000/- and when the demand of the applicant and his family members hav not fulfilled in result of that they brutally murdered his daughter."
},
{
"label": "Facts of the Case",
"content": "That the after the marriage the deceased came in house of the applicant and she was short tempered lady, just after few days of marriage the deceased requested to the applicant to leave his house with him and residing separately with deceased because the applicant has sole bread earner of the family and his income was not much as the deceased think. When they leave the family then the earning of the applicant is little bit better for the deceased."
},
{
"label": "Facts of the Case",
"content": "That the applicant always denied for leaving his house and family members because he was sole bread earner of the family and without him the family members of the applicant has been ruined but the deceased always quarreled with the applicant for leaving the family member of the applicant and wants to settle with the applicant another place."
},
{
"label": "Facts of the Case",
"content": "That the when the applicant not ready to leave his house and family member, the deceased became annoyed and starts quarreled with mother and sisters of the applicant, who is also named in first information report. The deceased having the relation with another person, the applicant always stopping her for such type activity but she was not stopping, even always chatting over her mobile phone."
},
{
"label": "Facts of the Case",
"content": "That when the deceased has not stopped therefore the applicant destroyed the mobile phone of the deceased, then in her safeguard and public defamation of applicant and his family members, the deceased always shouting and rumoring as the applicant and his family members were demanding the dowry from the deceased."
},
{
"label": "Facts of the Case",
"content": "That the deceased day by day became aggressive and on 17.12.2013 the deceased demanded the mobile phone of the applicant to make call but the applicant denied for same and after taken food, he was go to sleep. The deceased as she was short tempered lady, she committed suicide in her room."
},
{
"label": "Facts of the Case",
"content": "That the inquest report was prepared by the concerned police on 18.12.2013 before Panchat and all are opined as the deceased was died due to hanging but for proper investigation the post mortem is necessary."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the post mortem was done on body of the deceased on 18.12.2013 in District Hospital, Pratapgarh at 4.45 PM. The photocopy of the post mortem report dated 27.07.2014 is being annexed as Annexure No. 02 to this application."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statement of the informant has been recorded by the investigating officer on 18.12.2013 wherein the informant repeated the version of her first information report in detail. The type copy of the statement of informant dated 18.12.2013 is being annexed as Annexure No. 03 to this application."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant belongs to very poor family and running vegetable shop on footpath, by which he earns only for livelihood money but the informant alleged the applicant and his family demanded one Motorcycle and Rs. 50,000/- same is unbelievable."
},
{
"label": "CRIMINAL HISTORY",
"content": "That charge sheet filed by the investigation officer on 12.02.2014 against applicant including his mother under section 498A, 304B I.P.C. and 3/4 The Dowry Prohibition Act."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant has been surrendered before the court 10.01.2014 and moved the bail application before the court concerned and his bail application has been rejected by the court concerned on 12.12.2014. The copy of the order dated 12.12.2014 passed by court concerned is being annexed as Annexure No. 04 to this application."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant in jail since 10.01.2014 and has no criminal history."
},
{
"label": "Facts of the Case",
"content": "That investigating officer has not found any evidence against the other accused on the basis of statements of the spot witnesses."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant was running vegetable shop for the survival/livelihood of his family members but the deceased always pressurized him to bring her to another and the deceased was always quarreled for this issue with the applicant but the economic status of the applicant has not allowed bringing the deceased to another place."
},
{
"label": "Facts of the Case",
"content": "That on date of incident i.e. 17.12.2013, the deceased was start quarreling with applicant and demanding the mobile phone after dined for same she run away in room and locked from inside and committed suicide."
},
{
"label": "Facts of the Case",
"content": "That on basis of said issue the deceased committed suicide and nothing was done by the applicant as alleged by the informant and proved the concerned police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no issue with the deceased in his life except above mentioned but the informant has lodged first information report on the wrong facts."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no any evidence found by the investigating officer in regard of demand of the dowry. After suicide of the deceased the informant cooked this story overnight."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is innocent and due to take revenge with informant falsely implicated in the aforesaid case crime."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no any evidence against the applicant to connect him with the aforesaid case crime and the only evidence against the applicant in regard of alleged offence is only false story and baseless ground, which was by the informant and the police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That no any involvement in the said case as alleged in first information report, the applicant has no reason to murder the deceased."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That a false story cooked up by the concerned police and informant as the applicant committing the aforesaid case crime."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no motive to commit the alleged crime and false motive, for the money, has been fabricated by the concerned police."
},
{
"label": "CRIMINAL HISTORY",
"content": "That the applicant has no criminal history except the aforesaid false case and not likely to hope in future to commit any offence."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That there is no chance of the applicant absconding or tempering with the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "Date :\t\t 2015\t\t\t\t\t Deponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"**name_and_age\": \"** Jai Prakash Pushapar, aged about 48 years\",\n \"**address\": \"** Village – Gayaspur, Police Station – Kunda, District – Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Gardner\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** Literate\",\n \"**relationship_with_the_applicant\": \"** Brother-in-law (sala) of the applicant and doing pairvi of Applicant in the above-noted case\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** Bail Application No. 1552 of 2021\",\n \"**sections\": \"** 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957, and 103, 104 of The Trade and Merchandise Marks Act, 1958\",\n \"**date\": \"** 17.08.2021\",\n \"**police_station\": \"** Hathigawan, District – Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"**court\": \"** Sessions Judge, Pratapgarh\",\n \"**reason_for_rejection\": \"** Not mentioned\",\n \"key_facts_of_the_case:\": [\n \"The applicant has been falsely implicated in the case due to political reasons by some villagers.\",\n \"The applicant and his family members were not supporting a candidate of the Village Pradhan, who had good political approach, money, and men power.\",\n \"The applicant was threatened by the village Pradhan candidate to give his support, but the applicant denied.\",\n \"The applicant has been in jail since 24.06.2021 without committing any offense as alleged against him.\",\n \"The informant and Excise Inspector were not assured that the recovered liquor was adulterated.\",\n \"There were no witnesses of the raid conducted by the informant, which creates doubts upon the story of the informant.\",\n \"The applicant has no concern with the recovered adulterated liquor in any manner.\"\n ],\n \"custody_status:\": [\n \"The applicant is in jail since 24.06.2021 without committing any offense as alleged against him.\"\n ],\n \"supporting_documents_and_details:\": [\n \"Photocopy of ID proof of the deponent (Annexure No. 1)\",\n \"Certified copy/typed copy of the first information report dated 03.04.2021 (Annexure No. 1)\",\n \"Photocopy of bail rejection order dated 17.08.2021 passed by the court concerned (Annexure No. 2)\",\n \"Photocopy of the order dated 14.07.2021 passed by the court concerned (Annexure No. 3)\",\n \"Photocopy of the supplementary charge sheet filed by CBI (Annexure No. 4)\"\n ],\n \"medical_report:\": [\n \"Not mentioned\"\n ],\n \"statement_recorded:\": [\n \"Not mentioned\"\n ],\n \"undertakings_and_assurances:\": [\n \"The applicant will cooperate with the trial and will not tamper with the prosecution witnesses.\",\n \"The applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon'ble Court.\",\n \"The applicant is ready and willing to file adequate surety as the Hon'ble Court may deem fit and proper in the circumstances of the case.\"\n ],\n \"criminal_history\": [\n \"* 1. Case No. RC-2 (S) 2013/C.B.I./SC-1/New Delhi under Section 302, 147, 148, 149, 323, 332, 353, 506 and 201 of IPC read with 149 of IPC and 27 Arms Act, in which nothing has been found against the applicant and he has been exonerated from the charges.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant is a common man of society and has no concern with the adulterated liquor.\",\n \"The applicant was not present at the place of incident during the raid.\",\n \"The applicant surrendered before the court concerned on 24.06.2021.\",\n \"The applicant was falsely implicated in the case due to political reasons by some villagers.\",\n \"The applicant and his family members were not supporting a candidate of the Village Pradhan, who had a good political approach and money and men power.\",\n \"The applicant was threatened by the village Pradhan candidate to give his support along with his family, but the applicant denied.\",\n \"The applicant was threatened by the village Pradhan candidate to face consequences of the denial and said that he will ensure that the applicant is sent to jail soon.\",\n \"The first information report was lodged by the concerned police due to extraneous consideration.\",\n \"The Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned.\",\n \"The informant and Excise Inspector were not assured that the recovered liquor is adulterated.\",\n \"There were no witnesses of the raid conducted by the informant.\",\n \"The prosecution story reveals that no one saw the occurrence and there are no independent eye witnesses of the said recovery.\",\n \"The applicant has no concern with the recovered adulterated liquor in any manner.\",\n \"The Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not followed the applicant.\",\n \"The applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1552 of 2021, which was rejected by the court concerned without going to fact and records.\",\n \"Another accused Anoop Singh of the aforesaid case crime has been granted bail by the learned court below on 14.07.2021 in similar sections.\",\n \"Till date, there is no any chemical report stating that the recovered liquor was obnoxious or spurious for human consumption.\",\n \"The applicant has not committed any crime as alleged in the first information report by the informant and he has no concern.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant has no chance of absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon'ble Court.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Jai Prakash Pushapar aged about 48 years son of Shri Chiraunhi Lal resident of Village – Gayaspur, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Gardner, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is brother-in-law (sala) of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant has falsely been implicated in case crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh on 03.04.2021 at 23.52 hours against the applicant and several other accused persons. The certified copy/ typed copy of the first information report dated 03.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That according to the First Information Report, which has been lodged by Shri Doodhnath Singh Yadav, Station House Officer, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’), the prosecution story is in nutshell that the informant lodged a first information report against the applicant and several other persons on 03.04.2021 about 23.52 hours and stated that the informant and his team was on patrolling of area on 02.04.2021 and that time the team of Surveillance Cell, Prayagraj Zone met with the informant and informed that his team got information from his informant (eq[kfcj), who told the all 19 names of the accused and stated that from Parsipur Cowshed they are involved in the smuggling the adulterated liquor."
},
{
"label": "Facts of the Case",
"content": "That the raid has been conducted by the informant along with his team on 02.04.2021 around 16.40 hours at alleged place of occurrence and seized lot of adulterated liquor and no anyone arrested by the concerned police at time raid."
},
{
"label": "Facts of the Case",
"content": "That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to the raid and he was not present there and on basis of which the applicant is named in the first information report."
},
{
"label": "F.I.R DETAILS",
"content": "That the name of the applicant is shown at serial No. 14 in the accused column impugned first information report dated 03.04.2021."
},
{
"label": "F.I.R DETAILS",
"content": "That the impugned first information report dated 03.04.2021 is lodged after one day delayed i.e. on 03.04.2021 by the concerned police without giving any reason for delay."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant were not present at the place of incident. When the applicant came into knowledge that the concerned police searching the applicant in aforesaid case crime, then the applicant has surrendered before the court concerned on 24.06.2021."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the real fact is that the applicant are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for the ulterior motive."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant and his family members were not supporting to a candidate of the Village Pradhan, who has good political approach, who has money & men power."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant was threatened by the village pradhan candidate to give his support alongwith his family but the applicant has denied for the same."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That therefore the applicant has threatened by the village Pradhan candidate to face consequences of the denial and said that he will ensured that the applicant send to jail soon."
},
{
"label": "F.I.R DETAILS",
"content": "That on 03.04.2021, a first information report has been lodged by the concerned police due extraneous consideration, the applicant has been falsely implicated in the case crime."
},
{
"label": "Facts of the Case",
"content": "That it further relevant to mention that the Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned and even prior to information regarding said liquor, while the Excise Inspector was present at time of alleged raid, even the informant and Excise Inspector were themselves not assured that the recovered liquor is adulterated."
},
{
"label": "Facts of the Case",
"content": "That on bare perusal of the first information report, it is also evident that there were no witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant is in jail since 24.06.2021 without committing any offense as alleged against them."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that no one saw the occurrence and there are no any independent eye witnesses of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not followed him."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1552 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 and when Section 60A of U.P. Excise Act, 1910, which has been rejected by the court concerned without going to fact and records. The free certified copy of bail rejection order dated 17.08.2021 passed by the court concerned is annexed herewith as Annexure No. 2 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That another accused Anoop Singh of aforesaid case crime has been granted bail by the learned court below on 14.07.2021 in similar sections. The photocopy of the order dated 14.07.2021 passed by the court concerned is annexed herewith as Annexure No. 3 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That till date there is no any chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption."
},
{
"label": "CRIMINAL HISTORY",
"content": "That the applicant has a criminal history except this false case and detail of the said case is as under:"
},
{
"label": "CRIMINAL HISTORY",
"content": "Case No. RC-2 (S) 2013/C.B.I./SC-1/New Delhi under Section 302, 147, 148, 149, 323, 332, 353, 506 and 201 of IPC read with 149 of IPC and 27 Arms Act, in which nothing has been found against applicant and he has been exonerated from the charges."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "The photocopy of the supplementary charge sheet filed by CBI is annexed herewith as Annexure No. 4 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh during pendency of trial."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2021\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"case_file:_pappu_saroj_vs._state\": [],\n \"applicant_details:\": [],\n \"**name\": \"** Pappu Saroj\",\n \"**age\": \"** 24 years\",\n \"**address\": \"** Govind Rasoolpur, Police Station - Sangramgarh, District – Pratapgarh\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** High School\",\n \"**occupation\": \"** Agriculture\",\n \"**contact_information\": \"** Not mentioned\",\n \"**other_relevant_details\": \"** Son of Shri Ram Lakhan, brother of the applicant, and doing pairvi of the applicant in the above-noted case.\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** Crime No. 222 of 2014\",\n \"**sections\": \"** 419, 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act, and 103/104 Trade Mark Act\",\n \"**date\": \"** 01.11.2014\",\n \"**police_station\": \"** Sangramgarh, District – Pratapgarh\",\n \"**first_information_report_(fir)_lodged_by\": \"** SHO Shri Amit Pandey\",\n \"bail_rejection_order_details:\": [],\n \"**order_date\": \"** 24.11.2014\",\n \"**court\": \"** Additional Sessions Judge (Gangster), Court No. 5, Pratapgarh\",\n \"**reason_for_rejection\": \"** Insufficient grounds\",\n \"key_facts_of_the_case:\": [\n \"The applicant was falsely implicated in the case.\",\n \"The FIR was lodged by SHO Shri Amit Pandey on 01.11.2014.\",\n \"The applicant was arrested with 4 boxes of \\\"King Krazy Dry Gin\\\" and 3 boxes of \\\"Kingfisher Strong Premium Beer\\\".\",\n \"The prosecution story is that the applicant was the driver of the vehicle in which the illegal liquor was recovered.\",\n \"The applicant was also found with Rs. 150/- at the time of arrest.\",\n \"The police persons allegedly tried to use the applicant's vehicle free of cost, and when the applicant denied, they falsely implicated him in the case.\"\n ],\n \"custody_status:\": [\n \"The applicant has been in jail since 01.11.2014.\"\n ],\n \"supporting_documents_and_details:\": [\n \"Photocopy of ID proof of the deponent (Pappu Saroj)\",\n \"Certified copy of bail rejection order dated 24.11.2014 (Annexure No. 2)\",\n \"True photo/type copy of the first information report dated 01.11.2014 (Annexure No. 1)\"\n ],\n \"medical_report:\": [\n \"Not mentioned in the document\"\n ],\n \"statement_recorded:\": [\n \"The deponent (Pappu Saroj) has recorded a statement on oath, stating that he is the brother of the applicant and is doing pairvi of the applicant in the above-noted case. He has also stated that he is fully conversant with the facts of the case.\"\n ],\n \"undertakings_and_assurances:\": [\n \"The applicant undertakes to cooperate with the trial and not tamper with the prosecution witnesses.\",\n \"The applicant undertakes not to misuse the liberty of bail if granted.\",\n \"The applicant is ready and willing to file adequate surety as the court may deem fit and proper in the circumstances of the case.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 222 of 2014 under section 419, 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act registered at Police Station – Sangramgarh, District – Pratapgarh on 01.11.2014 at 18:15 hours.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant is a poor person and belongs to the scheduled caste.\",\n \"The police persons always try to use the applicant's vehicle free of cost, and when the applicant denied, they falsely implicated him in the case.\",\n \"There is no concern with the recovered illegal liquor.\",\n \"The police offered to move some household material from one place to another, and the applicant's brother went with them with the vehicle, but they falsely implicated the applicant in the case after demanding fare for transportation.\",\n \"According to the prosecution story, no one saw the occurrence, and there is no independent eye witness of the said recovery, making it a case of forgery, fabrication, and false.\",\n \"The applicant has not committed any crime as alleged in the first information report and has no concern with it.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant is a common man of the society, has never been convicted in any case, and not involved in any criminal activities ever.\",\n \"There is no chance of the applicant absconding or tampering with the prosecution witnesses, and they are willing to offer bail to the satisfaction of the court.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Pappu Saroj aged about 24 years son of Shri Ram Lakhan resident of Govind Rasoolpur, Police Station - Sangramgarh, District – Pratapgarh, Religion – Hindu, Qualification – High School, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is brother of applicant and doing pairvi of applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That this is first bail application on behalf of the applicant before the and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant have falsely been implicated in case crime No. 222 of 2014 under section 419, 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act registered at Police Station – Sangramgarh, District – Pratapgarh on 01.11.2014 at 18:15 hours against the applicant/accused and 3 named persons and 4-5 unknown persons. The first information report is lodged by SHO Shri Amit Pandey, Police Station – Sangramgarh, District – Pratapgarh. The true photo/type copy of the first information report dated 01.11.2014 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That according to the First Information Report the prosecution story is, on 30.10.2014 when the informant and his team (other police persons) on routine patrol, during patrolling he got information in regard of transportation of illegal liquor. On basis of above information the informant and his team arrested the applicant with 4 boxes of “King Krazy Dry Gin for sale in Arunachal Pradesh only, Maura Distilleries and Bottlers (P. Ltd.)” each boxes contained 48 bottle of 180ML and 3 boxes of Deshi bear of “Kingfisher Strong Premium Bear 500 ML for sale in Haryana only not for sale Uttar Pradesh” each box contained 24 bottle."
},
{
"label": "Facts of the Case",
"content": "That according to the first information report allegation against the applicant is driver of the vehicle, in which the above mentioned illegal liquor was recovered and at the time of arresting Rs. 150/- was also recovered from pocket of the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is poor persons and belongs to schedule caste, for livelihood the applicant purchased the vehicle Tata Ace on finance. The police persons always try to use the vehicle of the applicant free of cost when the applicant denied for same. Thereafter being aggrieved the concerned police persons falsely implicates the applicant in above noted case crime."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no concerned with recovered illegal liquor. On 31.10.2014 the concerned police contacted to the applicant and offered to move some household material from one place to another, on his request the brother of the applicant go with them with the vehicle. When his brother not came at home within time than applicant approached to the concerned police. Thereafter they falsely implicated in said case crime after demand of fare for transportation."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant/accused in jail from 01.11.2014."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant/accused."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has not committed any crime as alleged in the first information report and he has no concern."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that they will not misuse the liberty of bail if so granted by this ."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the may deems fit and proper in the circumstances of the case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant had applied for bail before the Additional Sessions Judge (Gangster), Court No. 5, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 24.11.2014. The certified copy of bail rejection order dated 24.11.2014 is annexed herewith as Annexure No. 2 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2014\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details\": [],\n \"**name_and_age\": \"** Dharendra Pratap Singh, aged about 37 years\",\n \"**address\": \"** Rautapur, District – Raebareli\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Agriculture\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** Literate\",\n \"**relationship_with_the_applicant\": \"** Brother-in-law (Sala) of the applicant and doing pairvi of Applicant\",\n \"current_case_fir_details\": [],\n \"**case_number\": \"** Bail Application No. 2058 of 2021\",\n \"**sections\": \"** 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957, and 103, 104 of The Trade and Merchandise Marks Act, 1958\",\n \"**date\": \"** 30.09.2021\",\n \"**police_station\": \"** Kunda, District – Pratapgarh\",\n \"bail_rejection_order_details\": [],\n \"**court\": \"** Sessions Judge, Pratapgarh\",\n \"key_facts_of_the_case\": [\n \"The applicant was falsely implicated in the case by the informant due to political vendetta.\",\n \"The informant is working for the present local Member of the Parliament of the ruling party.\",\n \"The applicant's wife was elected as Village Pradhan in the last local body election held in year 2015.\",\n \"The applicant opposed the present local Member of Parliament (i.e. ruling party) in the year 2017, which led to enmity between them.\",\n \"The applicant was threatened by the present Member of Parliament to support his candidate contesting for Zila Panchyat in local body elections, but the applicant denied.\",\n \"The present local Member of Parliament is misusing the District Administration/authorities against the applicant and lodged the impugned first information report.\",\n \"The informant falsely implicated the applicant in the said crime for ulterior motive, which is baseless and illegal.\"\n ],\n \"custody_status\": [\n \"The applicant has been in jail since 04.06.2021 without committing any offense as alleged against them.\",\n \"The applicant has been in police custody remand on 30.06.2021 from 10.00 AM to 06.00 PM.\",\n \"The applicant is the father of two small children and during this global pandemic, they are left alone, and the life of the applicant is also in danger in jail as the Covid-19 spreading is too high in jails.\",\n \"The applicant is suffering from Chronic Liver Disease (70% liver is infected), high diabetic, and heart disease and was under treatment.\"\n ],\n \"supporting_documents_and_details\": [\n \"Photocopy of ID proof of the deponent\",\n \"Photocopy of the first information report dated 05.04.2021 (Annexure No. 1)\",\n \"Photocopy of the alleged statement of the applicant recorded on 18.06.2021 (Annexure No. 2)\",\n \"Photocopy of the recovery memo dated 30.06.2021 (Annexure No. 3)\",\n \"Photocopy of the medical prescription of the applicant (Annexure No. 4)\",\n \"Photocopies of the bail order granted by the court concerned (Annexure No. 5)\",\n \"Photocopies of the bail order passed by the court below (Annexure No. 6)\",\n \"Free copy of bail rejection order dated 30.09.2021 (Annexure No. 7)\"\n ],\n \"medical_report\": [\n \"The applicant is suffering from Chronic Liver Disease (70% liver is infected), high diabetic, and heart disease and was under treatment.\"\n ],\n \"statement_recorded\": [\n \"The applicant's statement was recorded by the investigating officer under Section 161 of Cr.P.C. in jail on 18.06.2021. The type copy of the alleged statement of the applicant recorded on 18.06.2021 is being annexed herewith as Annexure No. 2 to this Affidavit.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh on 05.04.2021.\",\n \"* 2. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh.\",\n \"* 3. Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District - Pratapgarh.\",\n \"* 4. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh.\",\n \"* 5. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh.\",\n \"* 6. Case Crime No. 51 of 2021 under section 60, 63 of U.P. Excise Act, Police Station - Hathigawan District - Pratapgarh.\",\n \"* 7. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh.\",\n \"* 8. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60A, 60 U.P. Excise Act registered Police Station – Gossainganj, District – Ayodhya.\",\n \"* 9. Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh.\",\n \"* 10. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh.\",\n \"* 11. Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned.\",\n \"* 12. Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant.\",\n \"* 13. Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned.\",\n \"* 14. Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case.\",\n \"* 15. Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case.\",\n \"* 16. Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned.\",\n \"* 17. Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant.\",\n \"* 18. Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant.\"\n ],\n \"grounds_for_bail\": [\n \"The informant has falsely implicated the applicant in the case due to political vendetta.\",\n \"The informant is working for the local Member of Parliament of the ruling party.\",\n \"The applicant has no connection with the alleged adulterated liquor.\",\n \"The first information report (FIR) is anti-dated, and the raid was conducted on 03.04.2021, but the FIR was lodged on 05.04.2021 without giving any reason for the delay.\",\n \"There are no witnesses of the raid conducted by the informant.\",\n \"The applicant has not committed any offense as alleged against him.\",\n \"The prosecution story reveals that no one saw the occurrence, and there are no independent eye witnesses of the said recovery.\",\n \"The recovered liquor was not sent for chemical analysis, and there is no report stating that the liquor was obnoxious or spurious for human consumption.\",\n \"The applicant has been falsely implicated in several cases lodged against him, which he has not committed.\",\n \"The applicant has no connection with the recovered adulterated liquor in any manner.\",\n \"The applicant has been granted bail in several cases in the past.\",\n \"The applicant has not committed any crime as alleged in the FIR by the informant.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant is a common man of the society and has never been convicted in any case and not involved in any criminal activities ever.\",\n \"There is no chance of the applicant's absconding or tampering with the prosecution witnesses.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Dharendra Pratap Singh aged about 37 years son of Shri Jagdish Babadur Singh resident of Pure Gauran, Rautapur, District – Raebareli, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is brother-in-law (Sala) of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application."
},
{
"label": "APPLICANT DETAILS",
"content": "That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant has falsely been implicated in Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh on 05.04.2021 at 02.09 hours against the applicant and 12 other persons. The certified copy/ typed copy of the first information report dated 05.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That according to the First Information Report, which has been lodged by Sub Inspector Shri Pramod Kumar Singh, Inchare SWAT Team, District – Pratapgarh (hereinafter referred to as ‘informant’) stated therein that the informant and his team was on patrolling of area on 03.04.2021 and that time the informant got information from his informer (eq[kfcj) with regard to huge adulterated liquor stored."
},
{
"label": "Facts of the Case",
"content": "That the raid has been conducted by the informant along with his team on 03.04.2021 at alleged place of the applicant and seized lot of adulterated liquor."
},
{
"label": "Facts of the Case",
"content": "That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to raid and on basis which the applicant is named in the case crime."
},
{
"label": "F.I.R DETAILS",
"content": "That the name of the applicant is shown at serial No. 01 in the accused column in the first information report dated 05.04.2021."
},
{
"label": "Facts of the Case",
"content": "That the first report dated 05.04.2021 is anti dated as the raid was conducted on 03.04.2021 but the first information report lodged on 05.04.2021 by the concerned police without giving any reason for delay, which creates doubt upon the prosecution story."
},
{
"label": "APPLICANT DETAILS",
"content": "That the real fact is that the applicant is a common man of the society and running his own business and also managing the business of his wife. The business of the wife of the applicant is in the name of Sarvto Bhadra Traders, which is dealing in house building material and also have a brick field."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no concerned with the said allegation regarding illegal adulterated liquor as alleged by the informant. The informant working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime."
},
{
"label": "APPLICANT DETAILS",
"content": "That the wife of the applicant was elected as Village Pradhan in last local body election held in year 2015."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That it is further relevant to mention that in year 2017 during the State Legislation election the applicant opposed the present local Member of Parliament (i.e. ruling party) due to which he has enmity with the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant was threatened by the present Member of Parliament to support his candidate contesting for Zila Panchyat in local body elections otherwise he would be suffer a lot but the applicant denied for the same as he is follower of the other party, which is not ruling and contesting against the present ruling party."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That due to aforesaid reasons for building pressure upon the applicant and his family, the present Member of Parliament is misusing the District Administration/ authorities against the applicant and lodged the impugned first information report."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in result of the above, 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."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the informant falsely implicates the applicant, in the said crime, on the instructions of the present Member of Parliament, which is baseless and illegal due to ulterior motive."
},
{
"label": "Facts of the Case",
"content": "That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner by the informant."
},
{
"label": "Facts of the Case",
"content": "That on bare perusal of the first information report, it is also evident that there were no witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant has surrendered before the court concerned on 04.06.2021 in case crime No. 48 of 2021 registered at Police Station – Hathigawan, District – Pratapgarh."
},
{
"label": "CUSTODY STATUS",
"content": "That after 12 days of the surrender of the applicant, the investigating officer of the aforesaid case crime moved an application on 16.06.2021 for taking judicial custody of the applicant in case crime 124 of 2021, which was allowed."
},
{
"label": "CUSTODY STATUS",
"content": "That the investigating officer recorded the statement of the applicant under Section 161 of Cr.P.C. in jail on 18.06.2021, while the investigating officer has not recorded statement as given by the applicant. The type copy of the alleged statement of the applicant recorded on 18.06.2021 is being annexed herewith as Annexure No. 2 to this Affidavit."
},
{
"label": "CUSTODY STATUS",
"content": "That thereafter the investigating officer of the case crime No. 124 of 2021 has moved an application before the court concerned to take police custody remand on 28.06.2021. The police custody remand application has been allowed by the court concerned on 29.06.2021 and the applicant sent to police custody remand on 30.06.2021 from 10.00 AM to 06.00 PM."
},
{
"label": "CUSTODY STATUS",
"content": "That after taking in police custody remand by the investigating officer on 30.06.2021, a false and fabricated recovery memo has been prepared by the concerned police mentioning therein that on pointing out of the applicant, 33 bottles of 750ml English liquor was recovered from an open place near his house. The typed copy of the recovery memo dated 30.06.2021 is being annexed herewith as Annexure No. 3 to this Affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the concerned police without proper investigation and under the pressure of the local politician against 12 accused persons including the applicant, filed the charge sheet No. 228 of 2021 on 11.09.2021 without receiving the Forensic Science Lab report."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That for the extraneous reasons, the applicant falsely implicated in said case crime for showing good work of the police and while as per best knowledge of the applicant till date the Forensic Science Lab report not received by the investigating officer."
},
{
"label": "F.I.R DETAILS",
"content": "That under the political influence, after alleged raid on 03.04.2021, two first information reports lodged i.e. 124 of 2021 and Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Kunda, District – Pratapgarh by the SHO, Kunda against the applicant and other named and unknown persons, for preparing the criminal history against the applicant."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant is in jail since 04.06.2021 without committing any offense as alleged against them."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that no one saw the occurrence and there are no any independent eye witnesses of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has no concerned with recovered adulterated liquor in any manner as such the under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 have not applicable against him."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That till date there is no any chemical report received from the alleged recovery dated 30.06.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant is the father of the two small children and during this global pandemic they are left alone and the life of the applicant is also in danger in jail as the Covid-19 spreading is too high in jails."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant having severe Chronic Liver Disease (70% liver is infected) and high diabetic & also suffering from heart disease and was under treatment. After surrender of the applicant, there is no proper treatment is being given to the applicant due to which his life is in danger. The photocopy of the medical prescription of the applicant is being annexed herewith as Annexure No. 4 to this Affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "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:-"
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District - Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 51 of 2021 under section 60, 63 of U.P. Excise Act, Police Station - Hathigawan District - Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60A, 60 U.P. Excise Act registered Police Station – Gossainganj, District – Ayodhya. In this case the name of the applicant came in light from the statements of the accused persons."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "Another case has been lodged against the applicant, when he is jail, under the influence of the local politician on 14.10.2021 bearing Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh."
},
{
"label": "CRIMINAL HISTORY",
"content": "The aforesaid 9 cases are recently lodged under the political pressure of the local politician against the applicant."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant."
},
{
"label": "CRIMINAL HISTORY",
"content": "Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "The photocopies of the bail order granted by the court concerned and other related documents are being annexed herewith as Annexure No. 5 to this application."
},
{
"label": "CRIMINAL HISTORY",
"content": "That apart of abovementioned cases, there is no criminal history against the applicant."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the maximum accused of the case crime No. 124 of 2021 have been granted bail by the court below. The photocopies of the bail order passed by the court below are being annexed herewith as Annexure No. 6 to this application."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2058 of 2021 in Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 30.09.2021 passed by the court concerned is annexed herewith as Annexure No. 7 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh during pendency of trial."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .2021\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"case_file:_sanjay_kumar_singh_vs._state\": [],\n \"applicant_details:\": [],\n \"**name\": \"** Sanjay Kumar Singh\",\n \"**age\": \"** 32 years\",\n \"**address\": \"** 741/16, New Rana Nagar, District – Rae Bareilly\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** B.A.\",\n \"**occupation\": \"** Agriculture\",\n \"**contact_information\": \"** (Not provided)\",\n \"**other_relevant_personal_details\": \"** Son of Shri Raj Bux Singh\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** 15 of 2016\",\n \"**sections\": \"** 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act, and 103/104 Trade Mark Act\",\n \"**date\": \"** 01.02.2016\",\n \"**police_station\": \"** Maheshganj, District – Pratapgarh\",\n \"bail_rejection_order_details:\": [],\n \"**order_date\": \"** 14.04.2016\",\n \"**order_number\": \"** Not provided\",\n \"**court\": \"** Additional Sessions Judge, Room No. 5, Pratapgarh\",\n \"**reason_for_rejection\": \"** Insufficient grounds\",\n \"key_facts_of_the_case:\": [\n \"The applicant, Sanjay Kumar Singh, was falsely implicated in a case of illicit liquor manufacturing and sale.\",\n \"The FIR was lodged by Shri Sunil Kumar Dubey, In-charge, Surveillance Cell, on 01.02.2016.\",\n \"The applicant was arrested on the spot along with 14 other persons during a raid at a rice mill in Purmai Sultanpur.\",\n \"The liquor recovered was not sent for Tanki test until 04.03.2016, and the forensic test report is still pending.\",\n \"The prosecution story is based on a false and fabricated case.\"\n ],\n \"custody_status:\": [\n \"The applicant has been in jail since 01.02.2016.\"\n ],\n \"supporting_documents_and_details:\": [],\n \"annexure_no._1\": \"True photo/type copy of the first information report dated 01.02.2016\",\n \"annexure_no._2\": \"Photocopy of the parcha No. 9 dated 04.03.2016 of the case diary of the case crime\",\n \"annexure_no._3\": \"Photocopy of the Tanki test dated 23.03.2016\",\n \"annexure_no._4\": \"Certified copy of bail rejection order dated 14.04.2016\",\n \"medical_report:\": [\n \"Not provided\"\n ],\n \"statement_recorded:\": [\n \"Not provided\"\n ],\n \"undertakings_and_assurances:\": [\n \"The applicant undertakes to cooperate with the trial and not tamper with the prosecution witnesses.\",\n \"The applicant undertakes not to misuse the liberty of bail if granted.\",\n \"The applicant is ready and willing to file adequate surety as the court may deem fit and proper.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 35 of 2016 under Sections 420, 467, 471, 272, 273 I.P.C. and under Sections 60, 72 of the U.P. Excise Act and under Section 62 Copy Right Act, 1957, registered at Police Station – Shivkuti, District – Allahabad.\",\n \"* 2. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act, registered at Police Station – Maheshganj, District – Pratapgarh.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant is a poor person who came from West Bengal for livelihood and was working as a labor at a Mineral Water Plant near the rice mill.\",\n \"There is no concern with the recovered illegal liquor in any manner with the applicant as he was not arrested on the crime spot as stated by the concerned police in the first information report.\",\n \"The police falsely implicated the applicant in the said case crime.\",\n \"The recovered liquor has neither been sent for the Tanki test nor is a forensic test, as admitted by the investigating officer in his parcha No. 9 dated 04.03.2016 of the case diary of the case crime.\",\n \"The Tanki test conducted on 23.03.2016 found nothing obnoxious or spurious in the recovered liquor.\",\n \"The sample of the alleged illicit liquor has been sent to the forensic lab for testing, but the report is still awaiting.\",\n \"Without proper investigation of the case, the investigating officer filed a charge sheet against the applicant and others.\",\n \"According to the prosecution story, no one saw the occurrence, and there is no independent eyewitness of the said recovery, making it a case of forgery, fabrication, and false.\",\n \"The applicant has no concern with the recovered illicit liquor in any manner, and the sections mentioned in the charge sheet do not apply to him.\",\n \"The applicant has not committed any crime as alleged in the first information report and has no concern.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution.\",\n \"The applicant is a poor man of the society, has never been convicted in any case, and has not been involved in any criminal activities ever.\",\n \"There is no chance of the applicant absconding or tampering with the prosecution witnesses, and they are willing to offer bail to the satisfaction of the court.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Sanjay Kumar Singh aged about 32 years son of Shri Raj Bux Singh resident of 741/16, New Rana Nagar, District – Rae Bareilly , Religion – Hindu, Qualification – B.A., Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "Facts of the Case",
"content": "That the deponent is pairokar of applicant and doing pairvi of applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit."
},
{
"label": "APPLICANT DETAILS",
"content": "That this is first bail application on behalf of the applicant before the and not other bail application is pending before in any court of law on his behalf."
},
{
"label": "Facts of the Case",
"content": "That the facts giving rise to the present case are being stated in brief hereinafter."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant has falsely been implicated in case crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act registered at Police Station – Maheshganj, District – Pratapgarh on 01.02.2016 at 14:00 hours against the applicant/accused and along with other 14 named persons. The first information report is lodged by Shri Sunil Kumar Dubey, In-charge, Surveillance Cell. The true photo/type copy of the first information report dated 01.02.2016 is being annexed herewith as Annexure No. 1 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That according to the First Information Report the prosecution story is, in nutshell, that one Shri Sunil Kumar Dubey, In-charge, Surveillance Cell recovered some illicit country made liquor within the limits of Police Station – Shivkuti, District – Allahabad on 31.01.2016 in a surprised raid conducted by him and a first information report was registered at Police Station – Shivkuti, District – Allahabad bearing case crime No. 35 of 2016 under Sections 420, 467, 471, 272, 273 I.P.C. and under Sections 60, 72 of the U.P. Excise Act and under Section 62 Copy Right Act, 1957. One accused person at Police Station – Shivkuti, District – Allahabad told that the illicit liquor was being prepared at the old rice mill of the Sudhakar Singh & Diwakar Singh sons of Shri Kunj Bihari Singh resident of Village – Purmai Sultanpur, Police Station – Maheshganj, District – Pratapgarh and it is supplied from there by certain other persons."
},
{
"label": "Facts of the Case",
"content": "That on 01.02.2016, Shri Sunil Kumar Dubey, In-charge, Surveillance Cell and his team (other police personnel) got information in regard of huge Adulterated liquor, rapper and equipment for packaging/making liquor in rice mill of said Sudhakar Singh & Diwakar Singh and his team raid at said rice mill where the 15 persons are arrested on the spot including the applicant, they were working with the adulterated liquor."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant is poor person and belongs came from West Bengal for livelihood he was working as labor at Mineral Water Plant which was beside of the said rice mill and during the raid, the concerned police arrested the applicant without any reason and falsely implicate in said case crime for showing good work of the police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no concerned with recovered illegal liquor in any manner with the applicant as he was not arrested on the crime spot as stated by the concerned police in first information report, the police concerned falsely implicated in said case crime."
},
{
"label": "Facts of the Case",
"content": "That it is very strange as till 04.03.2016, the recovered liquor has neither sent for the Tanki test nor is forensic test, this fact admitted by the investigating officer of the said case crime by his parcha No. 9 dated 04.03.2016 of the case diary of the case crime. The photocopy of the parcha No. 9 dated 04.03.2016 of the case diary of the case crime is being annexed herewith as Annexure No. 2 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That thereafter on 23.03.2016, the Tanki test has been conducted by the Excise Inspector, Circle – III, Kunda, Pratapgarh on the both liquor i.e. country made and foreign and nothing has been found in recovered liquor which was obnoxious or spurious for human consumption. The photocopy of the Tanki test dated 23.03.2016 is being annexed herewith as Annexure No. 3 to this Affidavit."
},
{
"label": "Facts of the Case",
"content": "That thereafter on 06.04.2016, the sample of the alleged illicit liquor has been sent to the forensic lab for testing and till date the report is awaiting from the forensic lab."
},
{
"label": "Facts of the Case",
"content": "That without proper investigation of the case crime, the investigating officer filed charge sheet No. 09 of 2016 dated 08.04.2016 under Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act against the applicant/accused and others 14 persons."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant/accused in jail from 01.02.2016."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant/accused."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant/accused has no concerned with recovered illicit liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act have not followed him."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the applicant has not committed any crime as alleged in the first information report and he has no concern."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution."
},
{
"label": "APPLICANT DETAILS",
"content": "That the applicant is poor man of the society. He has never convicted in any case and not involved in any criminal activities ever."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant will cooperate with the trial and will not tamper the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that they will not misuse the liberty of bail if so granted by this ."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready and willing to file adequate surety as the may deems fit and proper in the circumstances of the case."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant had applied for bail before the Additional Sessions Judge, Room No. 5, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 14.04.2016. The certified copy of bail rejection order dated 14.04.2016 is annexed herewith as Annexure No. 4 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "Date : .2016\t\t\t\t\t\tDeponent"
}
] |
{
"instruction": "You are an expert legal documents drafter and editor specializing in criminal laws and bail application drafting. I will describe a case summary and the case details.I will provide you with examples of my bail application drafting so you can understand the style and tone I use. Your task is to:\n1. Read and analyze the following details {content} to synthesize the style in which they are written.\n2. Describe the style, tone, and key characteristics of the content based on your analysis.\n3. Edit the provided text to ensure it is grammatically correct, maintains a consistent tone of voice as described, and retains the key points and messages.",
"context": "{\n \"applicant_details:\": [],\n \"**name\": \"** Pankaj Kumar Yadav\",\n \"**age\": \"** 23 years\",\n \"**address\": \"** Village – Paschim Ka Purwa, Sahjani, Police Station – Manikpur, District – Pratapgarh\",\n \"**contact_information\": \"** Not mentioned\",\n \"**occupation\": \"** Agriculture\",\n \"**religion\": \"** Hindu\",\n \"**qualification\": \"** Literate\",\n \"**relationship_to_the_applicant\": \"** Brother of the applicant\",\n \"current_case_fir_details:\": [],\n \"**case_number\": \"** 100 of 2017\",\n \"**sections\": \"** 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961\",\n \"**date\": \"** 30.07.2017\",\n \"**police_station\": \"** Manikpur, District – Pratapgarh\",\n \"other_relevant_details:\": [],\n \"**fir_lodged_by\": \"** Badelal Yadav (Informant)\",\n \"**reason_for_fir\": \"** Allegations of demand of dowry and stated that the applicants and his family members murdered the deceased\",\n \"bail_rejection_order_details:\": [],\n \"**first_bail_application\": \"** Rejected by Hon'ble Shri Anant Kumar “J” on 11.04.2019 (Criminal Case No. 6434 of 2018)\",\n \"**second_bail_application\": \"** Rejected by learned Session Judge/F.T.C., Pratapgarh in bail application No. 62 of 2018 vide order dated 09.02.2018\",\n \"**third_bail_application\": \"** Rejected by Hon’ble Shri Anant Kumar “J” on 11.04.2019 (Criminal Case No. 6434 (B) of 2018)\",\n \"key_facts:\": [\n \"The applicant is in jail since 15.07.2017 without any fault of his.\",\n \"The applicant has no criminal history except for this present case.\",\n \"The applicant's family members were enlarged on bail by this Hon'ble Court vide order dated 20.12.2017 & 31.05.2018.\",\n \"The deceased committed suicide due to her own reasons, i.e., after knowing that she will never become mother even after treatment.\",\n \"The applicant and his family members tried their best to explain the deceased but being hypersensitive with regard to child.\"\n ],\n \"custody_status:\": [\n \"The applicant is in jail since 15.07.2017 without any fault of his.\",\n \"The other co-accused of the case crime i.e. mother and father of the applicant have been enlarged on bail by this Hon'ble Court vide order dated 20.12.2017 & 31.05.2018.\"\n ],\n \"supporting_documents_and_details:\": [],\n \"annexure_no._1\": \"Certified/Typed copy of the first information report dated 30.07.2017\",\n \"annexure_no._2\": \"Photo/Typed copy of the panchayatnama\",\n \"annexure_no._3\": \"Photo/Typed copy of the post mortem report\",\n \"annexure_no._4\": \"Type copy of the statement of the informant\",\n \"annexure_no._5\": \"Typed copies of the statements of the uncle of the deceased Amrit Lal and her grandfather Chhedi Lal\",\n \"annexure_no._6\": \"Typed copies of the statements of the relative of the deceased\",\n \"annexure_no._7\": \"Type copies of the statements of the Bahubal and Chandrapal\",\n \"annexure_no._8\": \"Photo/Typed copy of the charge sheet dated 23.10.2017\",\n \"annexure_no._9\": \"Photocopy of the medical report of the deceased dated 27.07.2017\",\n \"annexure_no._10\": \"Photocopy of the bail order of this Hon'ble Court on 20.12.2017 & 31.05.2018\",\n \"annexure_no._11\": \"Photocopy of the bail rejection order dated 09.02.2018 passed by the court concerned\",\n \"annexure_no._12\": \"Photocopy of the order dated 11.04.2019 passed by this Hon'ble High Court\",\n \"annexure_no._13\": \"Photocopies of the statement and cross of the witnesses of the trial\",\n \"annexure_no._14\": \"Photo/Typed copy examination of the doctor conducted the post mortem of the deceased\",\n \"medical_report:\": [\n \"The post mortem was conducted on 30.07.2017 about 04.48 PM\",\n \"The deceased was burned 95% and smell of kerosene oil was present.\",\n \"The death of deceased caused by shock as a result of ante mortem burn injuries.\"\n ],\n \"statement_recorded:\": [\n \"The applicant's brother has recorded a statement under Section 161 Cr.P.C. in support of the applicant's bail application.\"\n ],\n \"criminal_history\": [\n \"* 1. Case Crime No. 100 of 2017 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 at Police Station – Manikpur, District – Pratapgarh.\"\n ],\n \"grounds_for_bail\": [\n \"The applicant is innocent and has been falsely implicated by the Informant due to malafide intention of the Informant and on the ill advice of his relative.\",\n \"The applicant or his family had never demanded any dowry nor had tortured the deceased for the alleged demand of dowry.\",\n \"The entire allegations as alleged in the first information report are false and frivolous.\",\n \"There was neither any demand of dowry nor the deceased was harassed in any manner.\",\n \"The relation between the applicant and his family members are very sweet with the deceased.\",\n \"The deceased committed suicide due to her own reasons i.e. after knowing that she will never become mother even after treatment.\",\n \"The first information report has been lodged afterthought and after consultation, in order to falsely implicate the applicant and other accused persons.\",\n \"The first information report has been lodged in connivance with the police personnel.\",\n \"The deceased was brought to the hospital by the family members of the applicant in an emergent situation and when the deceased declared dead then the hospital authority informed to the concerned police and police authority came and stated proceeding of the inquest as such the inquest report has not contained the case crime.\",\n \"The trial of the case has been initiated and statements and cross of the informant and other witnesses have recorded by the court concerned in which they all are stand with their statements under Sections 161 of Cr.P.C., with malafide intention to prove guilty the applicant.\",\n \"On bare perusal of the aforesaid statements of the witnesses of the ongoing trail, there are several contradictions in the all statements, which are not corroborated with the prosecution story.\",\n \"The deceased committed suicide for her own reasons, which has been discussed hereinabove but the informant and his family members falsely implicated the applicant and his family in said case with malafide intention.\",\n \"The state of the Doctor has also examined on 02.07.2019 by the court concerned in which he stated that there was no external and internal injury found on the body of the deceased.\",\n \"The doctor further stated that the soot particle found in the trachea of the deceased, which shows it is clear that the deceased burned herself and she was freely breathing at the time of burn.\",\n \"There is no possibility of the applicant's conviction because he has not committed the crime in question as alleged by the Informant.\"\n ]\n}"
} | [
{
"label": "APPLICANT DETAILS",
"content": "(In support of first bail application)"
},
{
"label": "APPLICANT DETAILS",
"content": "I, Pankaj Kumar Yadav aged about 23 years son of Shri Dadan Babu Yadav resident of Village – Paschim Ka Purwa, Sahjani, Police Station – Manikpur, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and state on oath as under :-"
},
{
"label": "APPLICANT DETAILS",
"content": "That the deponent is brother of the applicant and doing pairvi in the above noted case and also duly authorized by him. The deponent further declares that the contents of this instant application explained by the counsel of the applicant as such he is fully conversant with the facts of the case deposed herein under."
},
{
"label": "CRIMINAL HISTORY",
"content": "That this is second bail application. First bail application No. 6434 of 2018 has been rejected by Hon’ble Shri Anant Kumar “J” on 11.04.2019. No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court."
},
{
"label": "F.I.R DETAILS",
"content": "That the applicant in jail on the basis of first information report lodged by the Informant, Badelal Yadav on 30.07.2017 at 14.30 hours against the five persons including the applicant vide case crime No. 100 of 2017 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 at Police Station – Manikpur, District – Pratapgarh. The certified/ typed copy of the first information report dated 30.07.2017 is being annexed herewith as Annexure No. 1 to this affidavit."
},
{
"label": "F.I.R DETAILS",
"content": "That according to the prosecution story, it was alleged in the impugned first information report dated 30.07.2017 that the informant solemnized the marriage of his daughter namely Manju (hereinafter referred as to ‘deceased’) with the applicant with lot of dowry. But the all accused of the case crime demanded Rs. 2 Lacs from the daughter of the informant and for same they were tortured her. On 27.07.2017, the informant visited her daughter’s house then he was informed that the accused of the case crime had set the deceased ablaze. When the informant reached hospital, he found dead body of the deceased in car."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That as a matter of fact the applicant is innocent and he has been falsely implicated by the Informant due to malafide intension of the Informant and on the ill advice of his relative."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That as a matter of fact the applicant or his family had never demanded any dowry nor had tortured the deceased for the alleged demand of dowry."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the applicant never demanded any dowry from the deceased or her family members and after this unfortunate incident’s information was given by this applicant to the family members of the deceased as well as Informant and they were present at the time of Panchayatnama. The photo/ typed copy of the panchayatnama is being annexed herewith as Annexure No. 2 to this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That it is relevant to mention that as the deceased was brought to the hospital by the family members of the applicant in imergent situation and when the deceased declared dead then the hospital authority informed to the concenred police and police authority came and stated proceeding of the inquest as such the inquest report has not contained the case crime."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the post mortem was conducted on 30.07.2017 about 04.48 PM and as per post mortem report the deceased was burned 95% and smell of kerosene oil was present. The death of deceased caused by shock as a result of ante mortem burn injuries. The photo/ typed copy of the post mortem report is being annexed herewith as Annexure No. 3 to this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statement of the informant was recorded under Section 161 Cr.P.C. by the concerned police on 30.07.2017, in which he almost repeated his first informant report. The type copy of the statement of the informant is being annexed herewith as Annexure No. 4 to this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That the statements of the uncle of the deceased Amrit Lal and her grandfather Chhedi Lal were also recorded under Section 161 Cr.P.C. by the concerned police, in which they have also supported the version of the first information report. The typed copies of the statements of the Amrit Lal and Chhedi Lal are being annexed herewith collectively as Annexure No. 5 to this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That some other statements have been recorded by the concerned police, who are the interested witnesses of the case i.e. the statements of the brother of the deceased Manoj Kumar, mother of deceased Smt. Rajkali, sister of the deceased Madhu Devi, brother-in-law of the deceased Shiv Bhavan Yadav and other relatives were recorded under Section 161 of Cr.P.C.. All the interested witnesses and unanimously stated that the marriage of the deceased and application was solemnized on 22.04.2015 and levelled general allegations of demand of dowry and stated that the applicants and his family members murdered the deceased. The typed copies of the statements of the relative of the deceased are being annexed herewith collectively as Annexure No. 6 to this affidavit."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That on 07.09.2017, the investigation of the case crime recorded the statements of the some independent witnesses under Section 161 of Cr.P.C., in which they specifically stated that the brother & sister of the applicant namely Sachin & Sonam, who were named in the first information report, were not involved in the alleged incident. The type copies of the statements of the Bahubal and Chandrapal are being annexed herewith collectively as Annexure No. 7 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That on basis of the statements of the independent witnesses, the name of the brother & sister of the applicant namely Sachin & Sonam were dropped during the investigation and they were exonerated."
},
{
"label": "F.I.R DETAILS",
"content": "That without proper investigation of the case crime, the investigating officer of the case crime, filed the charge sheet against the applicant and his mother & father on 23.10.2017 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961. The photo/typed copy of the charge sheet dated 23.10.2017 is being annexed herewith as Annexure No. 8 to this affidavit."
},
{
"label": "Facts of the Case",
"content": "That on perusal of the charge sheet, it is clear that the informant has named the accused persons in alleged case crime, in a very casual manner and without ascertaining the facts."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That prior to the date of incident neither deceased nor informant has filed any complaint or police report was never filed either with the police or any other competent authority for any cruelty or demand of dowry, which creates doubts upon the prosecution story."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no credible evidence on record, which could show that the applicant is guilty or committed this crime in question and the evidence available on record, itself shows that no prima facie offence under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 is made out against the applicant."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant is in jail since 15.07.2017 without any of his fault."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That no crime made out against the applicant as alleged in the impugned first information report lodged by the Informant."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That neither any evidence was found against the applicant nor has any motive been assigned to the applicant in the present case."
},
{
"label": "CRIMINAL HISTORY",
"content": "That the applicant has no criminal history at all except to this present case."
},
{
"label": "Facts of the Case",
"content": "That entire allegations as alleged in the first information report is false and frivolous. There was neither any demand of dowry nor the deceased was harassed in any manner."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That real fact of the case is that the relation between the applicant and his family members are very sweet with the deceased."
},
{
"label": "Facts of the Case",
"content": "That the deceased could not conceive due to medical reasons, due to which she was not happy. The deceased was under treatment with Dr. Ishar Ahmad at Maniikpur. On 27.07.2017 itself, the ultrasound scan was performed at Allahabad and in the report it revealed that the deceased never conceived even after her treatment. The photocopy of the medical report of the deceased dated 27.07.2017 is being annexed herewith as Annexure No. 9 to this affidavit."
},
{
"label": "Facts of the Case",
"content": "That the deceased was very upset by knowing the fact that she will never conceived even after her treatment. The deceased was in deep depression since then. The applicant and his family members tried their best to explain the deceased but being hypersensitive with regard to child."
},
{
"label": "Facts of the Case",
"content": "That on 30.07.2017, when no anyone at house of the applicant as the family member of the applicant went to paddy field for routine work of caring the crop at that time the deceased committed suicide by setting herself ablaze as she was too dipressed after knowing that she will never become mother even after treatment."
},
{
"label": "Facts of the Case",
"content": "That whent the family members of the applicant informed with regard to fire in their house by the villager then then returned to home and found that the deceased burned herself by using kerosene oil."
},
{
"label": "Facts of the Case",
"content": "That the applicant was also out of house and immediate incident the family member of the applicant brought the deceased the hospital and due to painic situation they have not informed to the concerned police with regard to said incident."
},
{
"label": "Facts of the Case",
"content": "That just after incident occurred, the in-laws of the deceased were informed and deceased brought to the hospital, where she was declared brought dead. Thereafter the informant and other persons were reached to the hospital and lodged the first information against the applicant and other persons on the basis of the incorrect facts."
},
{
"label": "F.I.R DETAILS",
"content": "That the first information report has been lodged afterthought and after consultation, in order to falsely implicate the applicant and other accused persons."
},
{
"label": "F.I.R DETAILS",
"content": "That the first information report has been lodged in connivance with the police personnel because as per the inquest report, the informant was at CHC during inquest proceeding from 13.45 to 14.45 hours of 30.07.2017, however as per the first information report dated 30.07.2017, it was lodged at 14.30 hours, which is not possible and creates doubt upon the prosecution."
},
{
"label": "Facts of the Case",
"content": "That the deceased committed suicide due to her own reasons i.e. after knowing that she will never become mother even after treatment."
},
{
"label": "CUSTODY STATUS",
"content": "That the other co-accused of the case crime i.e. mother and father of the applicant have been enlarged on bail by this Hon'ble Court vide order dated 20.12.2017 & 31.05.2018. The case of the applicant is identical and he is languishing in jail on the ground of being husband only. The photocopy of the bail order of this Hon'ble Court on 20.12.2017 & 31.05.2018 are being annexed herewith as Annexure No. 10 to this affidavit."
},
{
"label": "CUSTODY STATUS",
"content": "That the bail application of the applicant has been rejected by learned Session Judge/F.T.C., Pratapgarh in bail application No. 62 of 2018 vide order dated 09.02.2018. The photocopy of the bail rejection order dated 09.02.2018 passed by the court concerned is being annexed herewith as Annexure No. 11 to this affidavit."
},
{
"label": "CUSTODY STATUS",
"content": "That the applicant has filed first bail application before this Hon'ble Court as Criminal Case No. 6434 (B) of 2018 has been rejected by Hon’ble Shri Anant Kumar “J” on 11.04.2019. The photocopy of the order dated 11.04.2019 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 12 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the trial of the case has been initiated and statements and cross of the informant and other witnesses have recorded by the court concerned in which they all are stand with their statements under Sections 161 of Cr.P.C., with malafide intension to prove guilty the applicant. The photocopies of the statement and cross of the witnesses of the trial are being annexed herewith collectively as Annexure No. 13 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That on bare perusal of the aforesaid statements of the witnesses of the ongoing trail, there are several contradiction in the all statements, which are not collobrated with the prosecution story."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That all are the interested witnesses as such merely on basis of their statements and testimony, the applicant would not be pleaded guilty."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the deceased committed suicide for her own reasons, which has been discussed hereinabove but the informant and his family members falsely implecated the applicant and his family in said case with malafide intension."
},
{
"label": "SUPPORTING DOCUMENTS",
"content": "That state of the Doctor has also examined on 02.07.2019 by the court concerned in which he stated that there was no external and enternal injury found on the body of the deceased. The doctor further state that the soot particle found in the trachea of the deceased, which shows it is clear that the deceased burned herself and she was freely breating at time of burn. The photo/typed copy examination of the doctor conducted the post mortem of the deceased is being annexed herewith as Annexure No. 14 to this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That the during the argument of the first bail application, the government advocate opposed the bail by satying that the incident had taken place in inside of the house of the applicant and he had not informed to the police, so far this averment of the government counsel it is relevant to mention that when the deceased put her on ablaze then the applicant and his family brought the deceased to hospital in said imergent situation, the first priority was there the treatment of the deceased not the information given to the concerned police."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That merely on basis of the said averment of the government counsel this Hon'ble High Court rejected the first bail application of the applicant while he is entitled to enlarge on bail in view of the aforesaid averments made in this affidavit."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That there is no possibility of the applicant’s conviction because he has not committed the crime in question as alleged by the Informant."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Court."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That there is no chance of the applicant absconding or tempering with the prosecution witnesses."
},
{
"label": "UNDERTAKINGS & ASSURANCES",
"content": "That the applicant is ready to furnish personal bond and sureties to the entire satisfaction before the court, if the bail is granted to him."
},
{
"label": "GROUNDS FOR BAIL",
"content": "That in view of the above noted fact, it is clear that the applicant is innocent and his is in jail since 15.07.2017 as such it is expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of his trial."
},
{
"label": "GROUNDS FOR BAIL",
"content": "Date : .07.2020\t\t\t\t\tDeponent"
}
] |
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