APPLICATION PRAYING FOR EXEMPTION FROM SURRENDERING

IN THE SUPREME COURT OF INDIA

(CRIMINAL APPELLATE JURISDICTION)

CRL. M. P. NO. _______ OF 2022

IN

SPECIAL LEAVE PETITION (CRL) NO. ____________ OF 2022

IN THE MATTER OF:

 

ABC                                          ….……………….PETITIONER

VERSUS

STATE OF UTTAR PRADESH &ORS.……….………….………………….RESPONDENTS

 

APPLICATION PRAYING FOR EXEMPTION FROM SURRENDERING

To

The Hon’ble Chief Justice of India and His companion Justices of the Hon’ble Supreme Court of India

The application of the petitioner

MOST RESPECTFULLY SHEWETH:

  1. The petitioner is approaching this Hon’ble Court under Article 136 of the Constitution of India intending to challenge the impugned Final judgement and Order dated 18.04.22 passed by the Hon'ble High Court of Allahabad in Criminal Revision No. 27 of 2018 whereby the Appeal of the Petitioner has been dismissed and judgement passed by the Learned Sessions Court upheld.

 

  1. The necessary facts have been fully set out in the accompanying Special Leave Petition and the same are not being reproduced for the sake of brevity. The Petitioner craves leave of this Hon’ble Court to rely upon the same at the time of hearing of this application.

 

  1. That the Petitioner has a family and old aged parents to look after and has none to take care of them also being the sole bread earner it would be harsh upon the petitioner and his family.He has to take his parents for health check ups frequently the same may not be available if he is taken into custody. 

 

  1. That this application is bonafide and for ends of justice. 

PRAYER

In the circumstances herein above, it is therefore, most respectfully prayed that this Hon’ble Court may graciously be pleased to:

  1. Exempt the petitioner from surrendering; and
  2. pass any other further order/orders as may be fit and proper.

 

AND FOR THIS ACT OF KINDNESS YOUR PETITIONER SHALL EVER PRAY. 

 

 

FILED BY

__.08.2022

NEW DELHI

 

 (ADVOCATE FOR THE PETITIONER)

 

 

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