Title Draft Crl.Pet-483-Javeed Pasha-395.docx ✅

2 IN THE HON'BLE HIGH COURT OF KARNATAKA, AT BENGALURU (Memorandum of Criminal Petition for bail under Section 439 of the Code of Criminal Procedure, 1973) Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023) Criminal Petition No. /2025 BETWEEN: 1. Sri. Javed Pasha @ Moulisab S/o Chan Pasha, Aged about 33 years, Resident of Govindapura, Arabic College Post, Bengaluru– 560 045 2. Sri. Mukhtar Pasha @ Muja, S/o Chan Pasha, Aged about 21 years, Bengaluru 3. Sri. Salim Pasha @ Sikandar, S/o Chan Pasha, Aged about 21 years, Bengaluru Petitioner No.2 & 3 are R/at Kabbalahalli Village, Tekal Post, Malur Taluk, Kolar District – 563 137 … Petitioners (Petitioners are in Judicial Custody) Versus State by Jalahalli Police, Represented by State Public Prosecutor, High Court, Bengaluru– 560 001 … Respondent
3 MEMORANDUM OF CRIMINAL PETITION FOR BAIL UNDER SECTION 439 OF THE CODE OF CRIMINAL PROCEDURE, 1973 SECTION 483 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023) The Petitioners submit as follows: 1. The address of the Petitioners for the purpose of service of notice etc., from this Hon’ble Court, is that of their Counsel ____________, No.______, 2 nd Floor, ____________ Complex, 5 th Main, Gandhinagar, Bengaluru – 560 009. 2. The address of the Respondent for the aforesaid purposes is as shown in the cause title and also that of State Public Prosecutor, High Court, Bengaluru. 3. The Petitioners are in judicial custody in Crime No.120/2019 on the file of VIII A.C.M.M, Bengaluru, for the offence punishable under Section 395 of the Indian Penal Code, 1860 Section 310 (2) of the Bharatiya Nyaya Sanhita, 2023. The Respondent Police have arrayed the Petitioners as Accused No.3 to 5 in the said crime. The Petitioners have filed this Petition seeking bail on the following facts and grounds: BRIEF FACTS OF THE CASE 4. The Respondent police, based on the complaint given by one Sri.Santosh Kumar, have registered a case in Crime No.120/2025, on 27.07.2019, for the offence punishable under Section 395 of the Indian Penal Code, 1860, Section 310 (2) of the Bharatiya Nyaya Sanhita, 2023, against unknown persons. The Respondent Police, based on the said complaint, have arrested these Petitioners along with other accused persons under the suspicion that the accused persons are involved in the said crime. 5. The case of the prosecution is that they have received a complaint on 27.07.2025 at about 3.30 pm, from the Complainant, Sri. Santosh Kumar has registered a case against unknown persons in the said crime No.120/2025. That, based on the alleged voluntary statement of one of the accused, the Petitioners and others were arrested. The Respondent Police have cooked up a story that the Driver of the Vehicle bearing Registration No.KA-41 AA-7253,