Bail Application Builder

IN THE COURT OF SESSIONS JUDGE AT NEW DELHI

IN THE MATTER OF:
RAJESH KUMAR
S/o Late Sh. Ram Prakash
Aged about 38 Years,
R/o H.No. 42, Pocket-B, Mayur Vihar, Phase-II, New Delhi - 110091
                                                  ...APPLICANT / ACCUSED
                               VERSUS
STATE (NCT OF DELHI / GOVT. OF STATE)
Through Station House Officer,
P.S. Kalyanpuri, East District, New Delhi
                                                  ...RESPONDENT

APPLICATION FOR GRANT OF REGULAR BAIL UNDER SECTION 483 / SECTION 480 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 (BNSS)
IN FIR NO. 142/2026
P.S.: KALYANPURI
UNDER SECTIONS: SECTIONS 316(2), 318(4), 3(5) BNS (FORMERLY 406, 420, 34 IPC)

MOST RESPECTFULLY SHOWETH:

1. That the Applicant is a law-abiding citizen of India, residing at the aforementioned address with his family, and has deep roots in society.

2. That the Applicant has been falsely implicated in the above-captioned FIR No. 142/2026 registered at P.S. Kalyanpuri for alleged offences under Sections 316(2), 318(4), 3(5) BNS (formerly 406, 420, 34 IPC).

3. That the Applicant was arrested / apprehended on 14.10.2026 and has been in custody since then, fully cooperating with the investigating agency.

4. BRIEF FACTS AND CIRCUMSTANCES OF THE CASE:
1. That as per the prosecution allegations in FIR No. 142/2026 registered at P.S. Kalyanpuri, it is alleged that the accused entered into a commercial transaction for supply of building material worth Rs. 14,50,000/- and post-dated cheques were dishonoured upon presentation.
2. That the true facts and circumstances are that the transaction was purely contractual and civil in nature, with civil recovery and Section 138 NI Act proceedings already initiated. The accused never had any fraudulent inducement at the inception of the contract.
3. That all tax invoices, delivery challans, and bank statements are already in the custody of the investigating officer, and no custodial interrogation or recovery of any incriminating article is warranted from the applicant.

5. GROUNDS FOR BAIL:
   (a) That Falsely implicated due to previous enmity / civil dispute given criminal colour.
   (b) That Permanent resident with roots in society; zero flight risk.
   (c) That Investigation substantially complete; custodial interrogation no longer warranted.
   (d) That Clean antecedents with no prior criminal convictions or pending trials.
   (e) That Undertakes to cooperate fully with io and not tamper with evidence or witnesses.
   (f) That The dispute arose out of a purely commercial transaction regarding supply of construction material for which civil recovery proceedings are already pending.

6. That the Applicant is ready and willing to abide by any terms and conditions that this Hon'ble Court may deem fit to impose and will not tamper with prosecution evidence, intimidate witnesses, or flee from justice.

7. That the Applicant is ready and willing to furnish sound and solvent local surety to the satisfaction of this Hon'ble Court. The Applicant's real brother Sh. Suresh Kumar, a government employee residing at the same address, is ready and willing to furnish solvent surety.

8. That no other similar bail application has been filed before or dismissed by this Hon'ble Court or any higher court, except as placed on record.

PRAYER:
Wherefore, in the light of the facts and circumstances stated hereinabove, it is most respectfully prayed that this Hon'ble Court may be pleased to:

a) Release the Applicant on regular bail in connection with FIR No. 142/2026, P.S. Kalyanpuri, under Sections 316(2), 318(4), 3(5) BNS (formerly 406, 420, 34 IPC), on such terms and conditions as this Hon'ble Court may deem just and proper; and

b) Pass any other or further order(s) as this Hon'ble Court may deem fit and proper in the interest of justice.

AND FOR THIS ACT OF KINDNESS, THE APPLICANT AS IN DUTY BOUND SHALL EVER PRAY.

APPLICANT
THROUGH COUNSEL

Advocate for the Applicant
Enrolment No.: _____________________
Chamber / Office: __________________
Mobile: ____________________________
Place: East District
Date: 06/11/2026

VERIFICATION:
Verified at East District on this 6 day of November, 2026, that the contents of paragraphs 1 to 8 of the above application are true and correct to my knowledge, and no material fact has been concealed therefrom.

DEPONENT