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AB Muthukumar

The document is a memorandum for an anticipatory bail petition filed by Muthukumar in the High Court of Judicature at Madras, concerning Crime No.24 of 2022. The petitioner claims to have been falsely implicated in a case involving allegations of fraud and threats related to a job offer at Chennai Airport. He seeks bail, asserting his innocence and willingness to comply with any conditions set by the court, while emphasizing that this is his first bail application and no similar petitions are pending elsewhere.

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Suria Narayanan
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5 views3 pages

AB Muthukumar

The document is a memorandum for an anticipatory bail petition filed by Muthukumar in the High Court of Judicature at Madras, concerning Crime No.24 of 2022. The petitioner claims to have been falsely implicated in a case involving allegations of fraud and threats related to a job offer at Chennai Airport. He seeks bail, asserting his innocence and willingness to comply with any conditions set by the court, while emphasizing that this is his first bail application and no similar petitions are pending elsewhere.

Uploaded by

Suria Narayanan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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MEMORANDUM OF CRIMINAL ORIGINAL PETITION

(UNDER SECTION 438 OF Cr.P.C.)

IN THE HIGH COURT OF JUDICATURE AT MADRAS


MADURAI BENCH
(CRIMINAL JURISDICTION)

Crl.O.P.(MD) No. of 2022

in

Crime No.24 of 2022


(On the file of the Inspector of Police,
Bodinayakkanur Town Police Station, Theni District)

Muthukumar, M/A years,


S/o.Kaliyamoorthy,
Sowda Amman Koil Street,
Bodinayakkanur,
Theni District. … Petitioner / Accused No.1

Vs.
State represented by the
Inspector of Police,
Bodinayakkanur Town Police Station,
Theni District
(Crime No.24 of 2022) …. Respondent / Complainant

PETITION FOR ANTICIPATORY BAIL

The address for service of all notices and processes on the


petitioner is that of his Counsels M/s.S.Murugapandi at Plot No.128,
Kasim Residency, Y.Othakadai, Madurai.
The address for service of all notices and process on the
respondents is the same as stated above.

1. The petitioner humbly submits that he has been falsely


implicated for the offences under Sections 417, 420, 294(b), &
506(i) of IPC in Crime No.24 of 2022 on the file of the
Respondent Police.

2. In the complaint the de-facto complainant has alleged that he


has completed Diploma Course for Electronics and Electrical
2

Engineering and the petitioner herein came to the house of the


de-facto complainant and informed the petitioner and his father
that he has acquainted with the higher officials in Chennai
Airport and he would make arrangement for a permanent job at
Cargo Department in Chennai Airport. Thereafter, on
20.8.2020 the petitioner brought the de-facto complainant and
his father to Madurai Airport and introduced the 2nd accused
that through the 2nd respondent he would make arrangement at
Chennai Airport. The petitioner received a sum of
Rs.1,00,000/- from the de-facto complainant and the same was
handed over to the 2nd accused. Thereafter, the petitioner has
shown the alleged appointment order and received a sum of
Rs.2,00,000/- on 26.9.2020 to the petitioner. In the said order,
it has been mentioned that the aspirant has to report the job
within 30 days. Moreover a sum of Rs.5000/- was also
received for making Identity Card. However, no orders was
received by the de-facto complainant and while questioning the
same, the petitioner drag on the issue and while insisting for re-
payment, the petitioner made an undertaking Deed that he will
pay a sum of rs.4,05,000/- within October’30 2021. However,
no amount was paid by the petitioner. On 10.11.2021, while
the de-facto complainant went to the petitioner’s house,and
approached the petitioner and other accused persons, they
abused fiithy language and threatened the de-facto complainant.

3. The Petitioner states that he did not commit the alleged


offences and a false case has been foisted against the Petitioner
with ulterior motives.

4. The petitioner states that he is law abiding citizen and he is


hailing from the respectable family. The Petitioner submits that
he is apprehending arrest by the respondent police. The
petitioner states that he is ready and willing to abide any
3

condition that may be imposed by this Hon'ble Court by


granting anticipatory bail.

5. The Petitioner states that this is the first anticipatory bail


petition before this Hon'ble Court and no similar petition is
pending before any other Courts.

Under these circumstances, it is prayed that this Hon’ble Court


may be pleased to pass an order to release the petitioner on bail in the
event of his arrest in connection with Crime No.24 of 2022 on the file
of the respondent police and thus render justice.

Dated at Madurai on this the 21st day of January, 2022.

Counsel for Petitioner


S.MURUGAPANDI (919/2018)
No.8, Law Chambers, High Court Buildings,
Madurai - 625 023. Mob.No. 8489817596
Madurai Law College 2012-2017

Residence Address:
Plot No.128, Kasim Residency,
Y.Othakadai, Madurai

Note:
1. Bail to the satisfaction of Learned Judicial Magistrate,
Bodinayakkanur, Theni District.

2. This is the first bail application before this Hon'ble Court.


3. No similar petition is pending before any other Courts.

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