Bail Petition before a Magistrate in a Pending Case under section 437, Cr PC

In the Court of Bombay 	

............................The State	
             versus
...........................Accused AB son of TZ, Village: Thana	

In the matter of petition for bail of accused AB
The humble petition of AB the accused in the above case

MOST RESPECTFULLY SHEWETH:
1. That your petitioner was arrested by the police on 5th April 2010 on suspicion. That he was not named in the FIR nor was he identified by any inmate of the house, where the burglary is said to have taken place during the identification parade by Mr. JM, a Judicial Magistrate.
2. That nothing incriminating was found in the house on search by the police.
3. That your petitioner is a family man and is not likely to abscond.
4. Your petitioner be granted bail inasmuch as there is no valid ground for continued detention and the trial is not likely to be completed within the near future.

Prayer
Your petitioner prays that after issuing the notice to the State and hearing both sides Your Honour may be pleased to pass Order for releasing your petitioner on bail.
And your petitioner as in duty bound, shall ever pray.
Advocate	AB

Verification
I, AB, son of MN, aged about 30 years, by occupation business, residing at....................do hereby solemnly affirm and say as follows:
1. I am the petitioner above-named and I know the facts and circumstances of this case.
2. The statements in paragraphs 1 to 4 in the foregoing petition are true and correct to the best of my knowledge and belief.
3. I sign this verification on this 20th day of June 2010.

Solemnly affirmed by the said AB
on 20th day of June 2010 at the
Court House at Mumbai 
AB Before me Notary/Magistrate