The claimant Ms Malkani and seeking bail application

Sir

I am here to represent the claimant Ms Malkani and seeking bail on behalf of her.

Sir

The prosecution raised two objections to bail in this case. Firstly, fail to surrender to custody. Secondly, commit an offence while on bail. However, I will explain them in chronological order.

The objection of failing to surrender while on bail is utterly unacceptable because there is no suggestion that Ms Malkini has ever failed to turn up in the court even in her previous convictions where she pleaded guilty to the serious offences and  anticipated a custodial sentence.

where as in this occasion she was charged with theft of 2 compact discs from Sounds Good Ltd and common assault against the store detective, although she is plannig to plead not guilty against the charges because this time she cant even think that the prosecution have a case against her.

Sir

it will be clear to you if I explain what exactly happened on Wednesday 1st October 2003.

Ms Malkini went to the shop to browse and window shop and so she was looking at other things too. Suddenly,  a strange man was looking at her and continued to follow her. As a result, she was scared and panicked because she has had problems in the past from a stalker so she tried to escape him. Unfortunately, she has no idea that  she came out of the shop although for a second. Then the man grabed her left arm and claiming that she is a thief as she was holding two CDs where as she didn’t even realise whats happening as the whole incidents happened so quickly. However, she has no intention of stealing them in this occasion even they are not kind of music what she likes.

Next, the issue of community ties, She has a secured place to live in Prince Edward’s House in Guildford also sincerely looking for a job somewhere close to her six years old daughter and keen to maitain contact to her as like all mother want to see their children ultimately she is a mother.Sir.

Therefore, it does indicate that she has no intention to abscond.

Sir,

The second objection of committing offence while she will be on bail.

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