IN THE COURT OF LEARNED SESSION JUDGE

Dhalai District:: AMBASSA

Case No:- Anticipatory Bail ………/2021

In the matter of :- An application under Section 438 of the Code of

Criminal Procedure, 1973 for grant of pre-arrest
bail in favour of the humble accused person
namely -Sri Sailesh Chakraborty at the event
of arrest who may be arrested in connection with
Chailengta P.S case No 03/2021 dated
28.03.2021 registered under section 304(B)/
498(A) and 34 of IPC .

AND

In the matter of :-

Sri Sailesh Chakraborty, S/o:- Late Prabash Chakroborty R/o:- Vill:-

Fishery Para, P.o & P.S:- Chailengta, District:- Dhalai Tripura.
….…Accused Petitioner.
VERSUS
The State of Tripura
.……Prosecution-Respondent
The humble petition of the petitioners above named
MOST HUMBLY BEGS TO SHEWETH :-

1) Your humble accused petitioners is a citizen of India

and permanent resident of the above address, is within the territorial
limits of this Hon'ble Court and therefore, it is most respectfully
submitted that the petitioner has the locus standi to present this
application under Section 438 of the Code of Criminal Procedure,
1973 (hereinafter referred to as the Cr.P.C. for short). The respondent,
impleaded to, in this application is within the territorial limits of this
Hon'ble Court and therefore, it is most humbly submitted that the
same is amenable to Directions/Orders issued by this Hon'ble Court
in exercise of the aforesaid statutory provision.

2) Sans unnecessary details, the facts and circumstances

that led to the presentation of this application are adumbrated
hereinbelow:-

2.1 On one 26/03/2021 the daughter of the complainant died

by committing suicide thereafter the complainant after
laps of two day on the evening of 28/03/2021 filed a written
complain before the chailengta police station stating that
on 13/03/2019 the complainant gave her daughter’s
marriage with the son of the accused petitioner and as per
the version of the FIR the complainant alleged that the
family of the accused petitioner several time harass the
daughter of the complainant( i.e. Sagarika Roy) for the
demand of dowry and also they alleging that the accused
petitioner as well as the family member of the petitioner
jointly murdered the daughter of the complainant.
3. That, at the very outset the Accused person denies the
aforesaid allegations and states that the aforesaid allegations
are false / frivolous and made only to harass the Accused
petitioner.
4. That in the aforesaid Ejahar there is no serious allegation
against the aforesaid accused persons namely Sri Sailesh
Chakraborty.
5. That the complainant give a false complaint and on the basis of
the false complain the police lodge an FIR against the above
named accused person.
6. That from the complaint it is revealed that the FIR is false as
because the complainant stated nothing about the
aforementioned accused person in the FIR.
7. That the accused person are innocent and the accused person
has a good reputation in the society but if the accused person is
arrested in this false case then his reputation was destroyed.
8. That, the instant case is filed due to emotionally and therefore,
the question of granting pre-arrest bail may be considered
liberally by this Hon’ble Court. The Accused Petitioner are not
habitual offenders or criminals and only due to emotional
attachment with their daughter the instant false and frivolous
case has been lodged against the Accused Petitioner.
9. That the FIR was registered on 28/03/2021 and thereafter
some accused was arrested in this case who are now in a
judicial custody and on 01/04/2021 after perusing the CD the
Ld. Sub-Divisional Judicial Magistrate grant bail of the Mother
in law of the deceased daughter of the Complainant but here no
such allegation is there against the above name accused person
namely Sri Sailesh Chakroborty.
10.That at the forwarding report dated 29.03.2021 the
investigating officer stated that the above named accused
petitioner is at fishery Para and the custody of the minor
daughter was given to the grand-father and now the minor
daughter of the deceased Sagarika Roy is in the safe custody of
the Grandfather and Grandmother ( After getting bail )
11.That the accused petitioner is the regular priest in the
chailengta police station Kali Mandir and after proper
investigation the investigating officer could not find any
serious allegation against the accused petitioner and the present
accused petitioner is also aged person.
12.That, the Accused Petitioner is apprehending arrest in
connection with the said case and as such approaches this
Hon’ble Court by way of filing this application U/S 438 of
Criminal Procedure Code.
13.That, the Accused Petitioners is permanent resident of the
above noted address and there is no chance of abscontion of
the Accused Petitioner and the Accused Petitioner also
undertake to comply with all the conditions of bail, if imposed
by this Hon’ble Court. The Accused Petitioner will also not
flout the bail order, if granted by this Hon’ble Court.
14.That, no other application for Anticipatory Bail is pending or
has been filed before this Hon’ble High Court or any other
Court.
15.That, the petition is bona-fide and filed in the interest of
justice.
16.That, the rest would be verbally submitted at the time of
hearing.

Under the circumstances stated above, it is most humbly

and respectfully prayed that this Hon’ble Court would be
graciously pleased to release the Accused Petitioner on
Anticipatory Bail/Pre-Arrest Bail in connection with
Chailengta P.S case No 03/2021 dated 28.03.2021 registered
under section 304(B)/ 498(A) and 34 of IPC.
AND
In the interim, be pleased to release the Accused
Petitioner on Pre-Arrest Bail in connection with aforesaid case
till disposal of the connected application for anticipatory bail.
AND/OR
Pass any other order/ orders as deem fit and proper by
this Hon’ble Court.
AND
For this act of kindness your humble Accused Petitioner
as in duty bound shall ever pray.
Affidavit Follows …….