Draft of an Application for Plea Bargaining

IN THE HON’BLE COURT OF SH………………………………………………………

LD. M.M, DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

STATE                                  Versus                                    AB …………. (Accused)

                                                                                  FIR NO.:    

                                                                                 U/S    :

                                                                                  P.S.   :

APPLICATION ON BEHALF OF APPLICANT/ACCUSED [Name]……………….. UNDER SECTION 265-B OF CHAPTER XXI-A OF THE Cr.P.C FOR PLEA BARGAINING

MOST RESPECTFULLY SHOWETH:

  1. That the above mentioned matter is pending before this Hon’ble Court and is fixed for hearing on i.e. __.__.20__.
  2. That a report under section 173 Cr.P.C has since been filed against the applicant/accused person which is pending trial before this Hon’ble Court and is at the stage of appearance of accused.
  3. That as per charge sheet, the accused person alleged to have committed offence punishable as above.
  4. That the applicant person has preferred this application voluntarily after understanding the nature of allegation against them and the extent of punishment provided under the law for offence in question.
  5. That the applicant person is an old aged ailing person and have not been previously convicted by any court in any case in which he had been charged with the same offence.

PRAYER

It is, therefore, most humbly and respectfully prayed to this Hon’ble Court may graciously be pleased to consider the present application of the applicant person as per the provisions of Section 265-A Cr.P.C, in the interest of justice.

Pass any other or further order which this Hon’ble Court deems fit and proper in favour of the applicant/ accused person.

PLACE:

DATED:                 

APPLICANT/ACCUSED

THROUGH

                                            ADVOCATE

IN THE HON’BLE COURT OF SH………………………………………………………

LD. M.M, DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

STATE                                  Versus                                    AB …………. (Accused)

                                                                                  FIR NO.:    

                                                                                 U/S    :

                                                                                  P.S.   :

AFFIDAVIT

I,……………………………………… S/o ……………………………………, R/o ………………………do hereby solemnly affirm and declare as under:

  1. That I am the applicant in the above said matter and well conversant with the facts and circumstances of the case, as such competent to swear the present affidavit.
  2. That the accompanying application has been drafted by my Counsel under my instruction. The same has been read over and explained to me in vernacular and the same is true and correct to the best of my knowledge and belief.
  3. That the contents of the accompanying application may kindly be read as part and parcel to this affidavit as the same have not been repeated herein for the sake of brevity.

DEPONENT

VERIFICATION:

 Verified at ………….………… on this ………th day of August, ………… that the contents of my above affidavit are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

DEPONENT

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