An application for bail of Raipura Police Station Case No. 3(4)06 corresponding to G.R. Case No. 72/06


Raipura Police Station Case No. 3(4)06


Raipura 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



  1. A1, son of late AA (Accused No. 9 in F.I.R.)
  2. B1, son of late AA (Accused No. 11 in F.I.R.)
  3. C1, son of late BB (Accused No. 12 in F.I.R.)
  4. D1, son of late BB (Accused No. 13 in F.I.R.)
  5. E1, son of CC (Accused No. 21 in F.I.R.)
  6. F1, son of DD (Accused No. 22 in F.I.R.)
  7. G1, son of EE (Accused No. 23 in F.I.R.)
  8. H1, son of late FF (Accused No. 24 in F.I.R.)
  9. I1, son of late FF (Accused No. 25 in F.I.R.)
  10. J1, son of late GG (Accused No. 26 in F.I.R.)
  11. K1, son of GG (Accused No. 27 in F.I.R.)
  12. L1, son of late HH (Accused No. 28 in F.I.R.)
  13. M1, son of late HH (Accused No. 29 in F.I.R.)
  14. N1, son of II (Accused No. 30 in F.I.R.)
  15. O1, son of JJ (Accused No. 31 in F.I.R.)
  16. P1, son of KK Q1 (Accused No. 34 in F.I.R.)
  17. Q1, son of LL (Accused No. 35 in F.I.R.)
  18. R1, son of KK Q1 (Accused No. 36 in F.I.R.)
  19. S1, son of T1 (Accused No. 37 in F.I.R.)
  20. T1, son of LL (Accused No. 38 in F.I.R.)
  21. U1, son of late Chan Mia (Accused No. 39 in F.I.R.)
  22. V1, son of MM (Accused No. 40 in F.I.R.)
  23.  W1, son of MM (Accused No. 41 in F.I.R.)
  24. X1, son of NN (Accused No. 42 in F.I.R.)
  25. Y1, son of late OO (Accused No. 43 in F.I.R.)
  26. Z1, son of late OO (Accused No. 44 in F.I.R.)
  27. A2, son of late PP (Accused No. 45 in F.I.R.)
  28. B2, son of A2 Mia (Accused No. 46 in F.I.R.)
  29. C2, son of late QQ (Accused No. 47 in F.I.R.)
  30. D2, son of RR (Accused No. in 48 F.I.R.)
  31. E2, son of RR (Accused No. 49 in F.I.R.)
  32. F2, son of SS (Accused No. 50 in F.I.R.)
  33. G2, son of late TT (Accused No. 51 in F.I.R.)
  34. H2, son of UU (Accused No. 52 in F.I.R.)
  35. I2, son of V (Accused No. 53 in F.I.R.)
  36. J2, son of UU (Accused No. 54 in F.I.R.)
  37. K2, son of late WW (Accused No. 55 in F.I.R.)
  38. L2, son of late WW (Accused No. 56 in F.I.R.)
  39. M2, son of late WW (Accused No. 57 in F.I.R.)
  40. I1, son of late HH (Accused No. 59 in F.I.R.)
  41. N2, son of late XX (Accused No. 60 in F.I.R.)
  42. O2, son of late XX (Accused No. 61 in F.I.R.)
  43. P2, son of A2 Mia (Accused No. 62 in F.I.R.)
  44.  Q2, son of late XX (Accused No. 63 in F.I.R.)
  45. R2, son of late XX (Accused No. 64 in F.I.R.)
  46. S2, son of late YY (Accused No. 65 in F.I.R.)
  47. T2, son of late ZZ (Accused No. 66 in F.I.R.)
  48. U2, son of late ZZ (Accused No. 67 in F.I.R.)
  49.  R1, son of late ZZ (Accused No. 68 in F.I.R.)
  50. Q1, son of late ZZ (Accused No. 69 in F.I.R.)
  51. V2, son of ZA (Accused No. 70 in F.I.R.)
  52. W2, son of late ZB (Accused No. 71 in F.I.R.)
  53. X2, son of W2 (Accused No. 72 in F.I.R.)
  54. Y2, son of W2 (Accused No. 73 in F.I.R.)
  55. Z2, son of late ZC (Accused No. 74 in F.I.R.)
  56. E2, son of Z2 (Accused No. 75 in F.I.R.)
  57. A3, son of Z2 (Accused No. 76 in F.I.R.)
  58. B3, son of late YY (Accused No. 77 in F.I.R.)
  59. C3, son of B3 (Accused No. 78 in F.I.R.)
  60. D3, son of late ZD (Accused No. 80 in F.I.R.)
  61. E3, son of late YY (Accused No. 81 in F.I.R.)
  62. A1, son of E3 (Accused No. 82 in F.I.R.)
  63. F3, son of ZE (Accused No. 84 in F.I.R.)
  64. R1, son of Lutfor (Accused No. 88 in F.I.R.)
  65. G3, son of D SS (Accused No. 89 in F.I.R.)
  66. H3, son of late ZF (Accused No. 90 in F.I.R.)
  67. L2, son of J3 (Accused No. 91 in F.I.R.)
  68. I3, son of K3 Mia (Accused No. 92 in F.I.R.)
  69. J3, son of late ZG (Accused No. 93 in F.I.R.)
  70. K3, son of late ZG (Accused No. 94 in F.I.R.)
  71. L3, son of E3 (Accused No. 95 in F.I.R.)
  72. M3, son of E3 (Accused No. 96 in F.I.R.)
  73. N3, son of T2 (Accused No. 97 in F.I.R.)
  74. G3, son of M1 Mia (Accused No. 98 in F.I.R.)
  75. O3, son of M1 Mia (Accused No. 99 in F.I.R.)
  76. P3, son of ZH (Accused No. 100 in F.I.R.)
  77. Q3, son of ZI (Accused No. 101 in F.I.R.)
  78.  V2, son of ZI (Accused No. 102 in F.I.R.)
  79. R3, son of late ZJ (Accused No. 103 in F.I.R.)
  80. S3, son of late ZJ (Accused No. 104 in F.I.R.)
  81. T3, son of S3 Mia (Accused No. 105 in F.I.R.)

All from village-Gouripur, P.S. Raipura, District- Narsingdi




                     ——————Opposite party



An application for bail

 The accused-petitioners most respectfully


  1. That the accused-petitioners are quite innocent and have got no knowledge regarding the alleged offence.
  1. 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.
  1. 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 pZ1ce, 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.
  1. That the names of the accused-petitioners have not been disclosed in the statement made u/s 161 of the Code of Criminal Procedure by the witnesses.
  1. That there is no specific allegation against the accused-petitioners in the F.I.R. and charge sheet except their name.
  1. That even statement of the victim does not disclose any involvement of the accused-petitioners in the alleged offence.
  1. 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.
  1. 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.
  1. 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.
  1. 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.
  1. That one of the co-accused has been enlarged on bail who stands on the same footing.
  1. 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.