In The Court of Hon'Ble Sessions Judge, at Nanded

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Accused In MCR
IN THE COURT OF HON’BLE SESSIONS JUDGE,

AT NANDED
IN SESSIONS CASE NO. 142 OF 2022
(State of Maharashtra V/s Sarjerao & Others)
Applicant : 1) Pavan S/o Manikrao Dakhore

Age : 22 Yrs., Occu. : Education
R/o : Palasgaon Tq. Basmath
Dist Hingoli
2) Raju S/o Eknath Chavan

Age : 2 Yrs., Occu. : Education
R/o : Khandegaon Tq. Basmath
Dist Hingoli
V/s.
Respondent : State Of Maharashtra
Through : Police Station, Limgaon
Tq. Nanded Dist Nanded
In Cr. No. 21/2022 Dt.22/02/2022
Charge : U/sec. 395 of I.P.C. & 3/25 of Arms Act
Date of Incident : 22/02/2022
Date of MCR : 12/04/2022

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MAY IT PLEASE YOUR HONOUR
By way of present Application under Sec. 439 of

Criminal Procedure Code, 1973 Applicants i.e accused no.3 and 4
are approaching before this Hon’ble Court, thereby seeking first
successive regular bail application after filing of Charge-sheet in
bearing Crime No. 21/2022 Dtd .22/02/2022 under Sections
U/sec. 395 of I.P.C. & 3/25 of Arms Act registered with Police
Station, Limbgaon Tq. Nanded Dist Nanded.
The Applicants i.e. accused No. 3 & 4 submiting the application

U/s 439 of Cr.P.C as under:
1. That, As per reported by the Maroti Prabhakar Kale the
present F.I.R. came in to existence U/sec.393 of I.P.C. againt
the unknown persons .
2. That, In the present matter charge-sheet has been filed
before this hon’ble court.
3. That, Applicants are in M.C.R. From Dt.12/04/2022 till
today.
4. That, in the present matter accused no. 1 namely
Sarjerao S/o Rohidas Holpade has been already enlarge
on bail by this Hon’ble court bearing Cri. Bail Appln.
No.335/2022 on Dt. 01/07/2022.

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5. That, the nothing seized by police from the present
Applicants i.e. cash amount, any type of vehicle or any type
of weapon from the present applicants. The concern police
themselves had confusion that the act of arrested persons
what sections leveled against them but the incidence narrated
by the complainant nor more than section attracted i.e. 392,
393 of I.P.C. which is trible by J.M.F.C. court and the
conviction is not more than 7 year. But intentionally the
police concerned leveled the offence against the Applicants
which is trible by court of session i.e. 395 of I.P.C.
considering the records, submission and say filed by the
prosecution. The applicant entitled for bail.
6. That, the Applicants are innocent from the alleged offence
they has not made any kind of offence. The Applicant has no
knowledge about this case.
7. That, the charges leveled against the Applicants is false
and futile one.
8. That, the Applicants are innocent persons they has been
falsely involved in this crime.
9. That, Applicants are student as well as doing job on
general stores as a labor. If they behind the bar then the

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entire families will suffered from financial loss. The
Applicants are “Karta” of their families and all family
members are depend upon the income of Applicant’s.
10. That, the Applicants having movable and immovable
properties therefore question of absconding is not arises.
11. That, in the present matter accused no. 1 namely
Sarjerao S/o Rohidas Holpade has been already enlarge
on bail by this Hon’ble court, In such circumstances Rule Of
Parity is applicable to present Applicants.
12. That, The Applicant no 1 is permanent resident of village
Palasgaon tq. Basmath Dist Hingoli and The Applicant no 2
is permanent resident of village Khandegaon tq. Basmath
Dist Hingoli there is no any possibility of absconding of the
Applicants or tempering with the prosecution witnesses.
13. That, Applicants are also ready to abide any condition
imposed by Hon’ble Court and the Applicants are ready to
furnish surety to satisfaction of this Hon’ble court .
PRAYER
It is therefore prayed that,
1) The application may kindly be allowed;

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2) The Applicants may kindly be release on bail in connection with
Crime No. 21/2022 Dtd .22/02/2022 under Sections U/sec. 395 of
I.P.C. & 3/25 of Arms Act registered with Police Station,
Limbgaon Tq. Nanded Dist Nanded.in the interest of justice and
oblige.
Date : 29/07/2022 Petitionar
Through
1) Pavan S/o Manikrao Dakhore
Adv.R.G.Paralkar R/o : Palasgaon Tq. Basmath Dist Hingoli
2) Raju S/o Eknath Chavan

Adv.R.S.Deshmukhe R/o : Khandegaon Tq. BasmathDist Hingoli

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Page 1 of 5

IN THE COURT OF HON’BLE SESSIONS JUDGE,

Applicant : 1) Pavan S/o Manikrao Dakhore

2) Raju S/o Eknath Chavan

Charge : U/sec. 395 of I.P.C. & 3/25 of Arms Act

Date of Incident : 22/02/2022

Date of MCR : 12/04/2022

MAY IT PLEASE YOUR HONOUR

By way of present Application under Sec. 439 of

The Applicants i.e. accused No. 3 & 4 submiting the application

1. That, As per reported by the Maroti Prabhakar Kale the

present F.I.R. came in to existence U/sec.393 of I.P.C. againt

the unknown persons .

2. That, In the present matter charge-sheet has been filed

before this hon’ble court.

3. That, Applicants are in M.C.R. From Dt.12/04/2022 till

4. That, in the present matter accused no. 1 namely

Sarjerao S/o Rohidas Holpade has been already enlarge

on bail by this Hon’ble court bearing Cri. Bail Appln.

No.335/2022 on Dt. 01/07/2022.

5. That, the nothing seized by police from the present

Applicants i.e. cash amount, any type of vehicle or any type

of weapon from the present applicants. The concern police

themselves had confusion that the act of arrested persons

what sections leveled against them but the incidence narrated

by the complainant nor more than section attracted i.e. 392,

393 of I.P.C. which is trible by J.M.F.C. court and the

conviction is not more than 7 year. But intentionally the

police concerned leveled the offence against the Applicants

which is trible by court of session i.e. 395 of I.P.C.

considering the records, submission and say filed by the

prosecution. The applicant entitled for bail.

6. That, the Applicants are innocent from the alleged offence

knowledge about this case.

7. That, the charges leveled against the Applicants is false

and futile one.

8. That, the Applicants are innocent persons they has been

falsely involved in this crime.

9. That, Applicants are student as well as doing job on

general stores as a labor. If they behind the bar then the

entire families will suffered from financial loss. The

Applicants are “Karta” of their families and all family

members are depend upon the income of Applicant’s.

10. That, the Applicants having movable and immovable

properties therefore question of absconding is not arises.

11. That, in the present matter accused no. 1 namely

Sarjerao S/o Rohidas Holpade has been already enlarge

on bail by this Hon’ble court, In such circumstances Rule Of

Parity is applicable to present Applicants.

12. That, The Applicant no 1 is permanent resident of village

Palasgaon tq. Basmath Dist Hingoli and The Applicant no 2

is permanent resident of village Khandegaon tq. Basmath

Dist Hingoli there is no any possibility of absconding of the

Applicants or tempering with the prosecution witnesses.

13. That, Applicants are also ready to abide any condition

imposed by Hon’ble Court and the Applicants are ready to

furnish surety to satisfaction of this Hon’ble court .

1) The application may kindly be allowed;

2) The Applicants may kindly be release on bail in connection with