FORMAT ANTICIPATORY BAILAPPLICATION OFFECES

FORGERY & CHEATING

IN THE COURT OF SESSIONS, AT___________
Anticipatory Bail Application No. OF 20__
IN
(_____ Police Station, CR No.__dated_________)
______________________________
)
Aged- __yrs, Occupation Service/Business
)
Residing at________________________
)
________________________________
)
______________________________
) . Applicant
Versus
State of Maharashtra
)
(through - _________ Police Station
) Respondent
Charge Forgery & Cheating
THE HUMBLE APPLICATION OF THE APPLICANT
ABOVENAMED FOR ANTIVIPATORY BAIL U/S 438 CR.P.C
MOST RESPECTFULLY SHOWETH:
On behalf of the Applicant, it is most respectfully and humbly submitted as follows:1. That the abovenamed Applicant is a Businessman at a Resort named______________
and staying at the aforesaid address alongwith his family members, since decades.
2. That the Applicant has a reasonable apprehension that the Applicant may be arrested in
an alleged Non-Bailable Offence i.e. Cheating and Forgery case relating to a Probate
dated ________ (passed vide Petition No.__ of__ by Honourable High Court), by
the______ Police Station, at the instance of his one unauthorized Person named as
___________________.
3. The facts of the case are that:
At the instance of his one authorized Person named as _________________, the
Police Officials of the ____Police Stations feels the Applicant and another 02 or 03
Accused persons had allegedly committed Cheating and Forgery relating to a Probate
dated______________ (which was passed vide petition No.___ of 20__)
4. As Such, the Applicant has a reasonable apprehension that the Applicant may be
implicated in a baseless and meaningless Cheating and Forgery case relating to the
said Probate dated
___________and get him arrested by the ______ Police Station police officials.
Hence, the Applicant has applied for this Anticipatory Bail based on the genuine grounds:
(a) Firstly, the Applicant is not concerned with the said Probate at all because the said
Probate has been issued by Honourable High Court, to Mr./Mrs.

(b)

(c)

(d)

(e)

(f)

(g)

__________________. The Applicant points out that the Applicant personally knows
the said Mr./Mrs. _____________, as he/she is Business Partner of the Applicants
Firm, as Such, the _________Police have falsely implicated the Applicant.
Secondly, the WILL based on which the said Probate ws granted, has been also
issued the said Business Partner, in other words, on _______________, One
Spinster named ___________, who was owner of Agricultural Lands, bearing
No.__/_, __/__, and __/__ of Village _________, Taluka-_______, executed a will in
favour of the said will dated _______________). Thus , the Applicant is not
concerned with the said WILL also.
Thirdly, the Death Certificate dated ___________, relating to the death or the said
Spinster Lady, who expired on __________, has been issued BMC. (Annexed dated
_________). Thus, the Applicant is not concerned with the said Death Certificate
also.
Fourthly, the said Business Partner personally approached the Honourable High
Court alongwith requisite documents and obtained the said Probate vide Petition,
bearing No.__ of 20__ (Ex-A). Thus, the Applicant is not at all concerned with the
said Honourable High Court Petition and Proceedings, also
Fifthly, Subsequently, while the Applicant was in the police custody in C.R. No.
__/__ dated __________ and C.R. No. __/__ dated __________, PI___________ of
_______ Police Station, had made enquiries with the Applicant and the said
Business Partner, about the said alleged Probate Complaint and the Business
Partner gave their respective statements to the said PI ______________, On
____________, that (1) The said Probate has lbeen legally obtained from the
Honourable High Court by Following legal procedures. (2) The Complainant named
Mr. ______________ does not have any Locus Standi to make any complaint or
raise any grievances against the said Probate because the said Complainant
Mr.___________ is not the owner of the said two immovable properties i.e. Hissa
No. __/__ & No. __/__ and in addition, the said complainant Mr.___________ is also
not the Legal Heir of the said Spinster Lady. (3) on _______, the said Complainant
Mr.__________ unsuccessfully tried to get his name entered into the Mutation Entry
in respect of the said Hissa No. __/__ & No. __/__ vide Mutation Entry No. ____ but
on _____ the said name of the said Complainant Mr._________________ was
cancelled alongwith other S. No. __ vide the Mutation entry No._____. (Annexed
herewith and marked as Exhibit-E is a copy of the said Mutation Entry). Thus, the
said Complainant Mr._______ does not have any right to make such false allegation
against the Applicant without any lawful justification. Thus, the Applicant is not
concerned with the case.
Sixthly, as the Applicant had already co-operated with the Police Officials of
________ Police Station i.e. PI _________ and had also given his Statement on
_________ (i.e. before __ months) in the said alleged Probate matter. As such, the
Physical Custody of the Applicant, is not required at all.
Seventhly, the Applicant has made number of Complaints personally and through
his Advocate regarding the harassment and false implication being committed by the
Police Officials of _____ Police Station due to the refusal of the Applicant, to give
regular bribe to them.(Annexed herewith and marked as Exhibit-F Colly. Are the

copies of the said Complaints). As such, the Police Officials of the ____ Police
Station has falsely implicated the Application, in this fabricated Probate matter.
(h) Eighthly, the ______ commissioner of Police has directed enquiry into the
Applicants Complaint dated ________ and enquiry is being handled by PI
_________ of _______ Police Station. As such, the Police Officials of the
_____Police Station has falsely implicated the Applicant, in this fabricated Probate
matter.
(i)
Ninthly, the Respondents did not even think to file F.I.R. in this alleged Probate
case even, through one year had passed from the date of the receipt of the said of
the Applicant in this case, the Respondent has registered the F.I.R. yesterday i.e.
__________, because the Applicant has filed a writ Petition bearing No.__ of 20__
in this same fabricated Probate matter, to save their skin from the complaint of bribe
against them.
5. That the Applicant is a Businessman and a respectable personality in the society and
carrying out his business in _____. Under such a circumstances, if the Applicant is
arrested in the aforesaid baseless and meaningless Extortion case, the Applicant will face
grave humiliation without any lawful justification.
6. That the applicant has no desire to evade the due process of law and shall face the trial,
to vindicate his innocence.
7. That the applicant undertakes to not to misuse the Bail and he also undertakes to abide
by the terms of the Bail Order.
8. That the Applicant crave, leave of this Honourable Court to add, to alter, to amend, to
modify to very and /or to rescind any of the grounds aforesaid.
9. That the Applicant has not filed any other Bail Application under section 438 of the code of
criminal Procedure, in any other court of Law.
10. It is, therefore, most respectfully prayed to this Honourable Court that:
(a) In the event of the arrest of the Applicant, in the said alleged Probate
matter/Complaint as aforesaid, by the Respondent, the Respondent be directed, to
release the Applicant on bail, on such terms and conditions as this Honourable Court
deem fit and proper.
(b) To direct the Police officials of the ________ police Station, to not to arrest the
Applicant, until the Police Officials files their respective Police report in this manner
and till the final disposal of the case, as an interim relief.
(c) To grant interim relief order in the terms of prayer (b) above;
(d) Such other and further relief as this Honourbale Court deems fit and proper Dated this
_______ day of ________, 20__ at ___________.
Applicant
Advocate for the Applicant

VERIFICATION

I, Mr. _______________, the Applicant abovenamed, do hereby state on solemn

affirmation that whatever is stated hereinabove, in the foregoing Paras of the said
Application, are true and correct and I believe the same to be true.
On this ___day of ______________, 20__
Applicant
Advocate for the Applicant