IN THE COURT OF CHIEF JUDICIAL MAGISTRTE, NARSINGDI
Raipura Thana Police Station Case No. _________
IN THE MATTER OF:
Raipura Thana Police Station Case No. 3(4)06 corresponding to G.R. Case No. 72/06 under Sections 143/323/326/307/302/34 of the Penal Code, 1860
IN THE MATTER OF:
1. A, son of late B (Accused No. 1 in F.I.R.)
2. C, son of late D (Accused No. 3 in F.I.R.)
3. E, son of late F (Accused No. 4 in F.I.R.)
4. G, son of late H (Accused No. 5 in F.I.R.)
5. I, son of late H (Accused No. 7 in F.I.R.)
6. J, son of late ___________ (Accused No. 8 in F.I.R.)
7. K, son of late L (Accused No. 14 in F.I.R.)
8. M, son of N (Accused No. 15 in F.I.R.)
9. P, son of N (Accused No. 16 in F.I.R.)
10. Q, son of N (Accused No. 17 in F.I.R.)
11. R, son of N (Accused No. 18 in F.I.R.)
12. S, son of N (Accused No. 19 in F.I.R.)
13. T, son of M (Accused No. 20 in F.I.R.)
14. U, son of O (Accused No. 32 in F.I.R.)
15. V, son of O (Accused No. 33 in F.I.R.)
All from village-Gouripur, P.S. Raipura, District- Narsingdi
IN THE MATTER OF:
An application for bail
The accused-petitioners most respectfully
- That the accused-petitioners are quite innocent and have got no knowledge regarding the alleged offence.
- That defence case was inter alia that there had been fighting between the two groups of people of the village namely Tula Tuli under Raipura thana of the victim and the victim was seriously injured by other group of the same village in consequence of the fighting. But the accused-petitioners were all from Gouripur village which is separated by a river from the Tula Tuli. The victim’s family and relatives had the previous enmity with the accused-petitioners and they also being pressurized by the other group, the said false case was filed against the accused-petitioners just to harass them.
- That although the said Case was filed on 04.04.2006 but the accused-petitioners were being apprehended with the arrest and abuse of the police, could not appear before the learned Court. Recently, the accused-petitioners having been consulted with their lawyer and decided to surrender before the learned Court and defend the false Case filed against them.
- That when the said Case was filed, the offence u/s 302 was not alleged. But the investigation office being biased brought a new allegation u/s. 302 in the charge sheet and colored the alleged allegation which creates serious doubts about the prosecution case.
- That to resolve the long-standing enmity between the victim’s family, relatives and the accused-petitioners which leaded the said false case, a compromise agreement being dated 29.04.2006 was signed between the victim’s father and the accused-petitioners in presence of the then Deputy Speaker of the Jatiya Sangsad, Advocate Md. Abdul Hamid and the then local Parliament member Raji Uddin Ahmed Raju and other local distinguished personalities.
- That the victim’s father executed a Letter of Undertaking being dated 18.09.2007 that he would have no objection even the said Case is withdrawn.
- That the victim’s father is present in the Court today and ready to swear before the learned Court that he has no objection if the accused-petitioners get the bail.
- That one of the co-accused has been enlarged on bail who stands on the same footing.
- That there is no chance of absconsion if the accused-petitioners are enlarged on bail.
Wherefore, it is humbly prayed that your Honour would be graciously pleased to allow the accused-petitioners to go on bail in the interest of justice.