For concept of anticipatory bail. Read here

Sample draft of Anticipatory Bail

IN THE HIGH COURT OF ______________ AT _______

(CRIMINAL MISCELLANEOUS JURISDICTION)

A.B.A. No. __________ / 2026

IN THE MATTER OF:

An application under Sections 482 and 484 of B.N.S.S., 2023;

A N D

IN THE MATTER OF:

XYZ, aged about ______, Son of ____________, Resident of ___________________, P.O. _______, P.S. _________, District______________, State ______, Pincode ______             

                           ....…PETITIONER

VERSUS

  The State of ___________               

…….OPPOSITE PARTY

To,

The Hon’ble Chief Justice of the Hon’ble High Court of _____________ at ______________ and His Other Companion Judges of said Hon’ble Court.

The humble petition on behalf of the petitioner above named.

MOST RESPECTFULLY SHEWETH: –

1. That this is an application on behalf of the petitioner, who prays for grant of anticipatory bail by this Hon’ble Court as he has got reasonable apprehension of being arrested in connection with ________________________, which is now pending in the Court of the ___________________________________________.
2. That the petitioner has not moved earlier before this Hon’ble Court at any time earlier in A.B.A / B.A / Cr. M.P. / Cr. Writ / Cr. Revision or any other matter in connection this case as prayed for in this application.
3. That the cause of action arose within the territorial jurisdiction of this Hon’ble High Court of ____________________ at __________________.
4. That the prosecution story, in brief, ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Certified copy of the F.I.R. in connection with _________________ is being annexed herewith and marked as ANNEXURE–1 to this application.

• That it is stated and submitted that the petitioner is innocent and has been falsely implicated in this case on the basis of false and frivolous allegations.
• That it is stated that {add additional facts showing innocence}. Next paragraphs should also provide grounds for which you are seeking anticipatory bail

Photocopy of the facts _______ is being annexed herewith and marked as ANNEXURE-2 to this anticipatory bail application.

• That …………….
• That …………….
• That ………………
• That the petitioner is a respectable person having deep roots in the society and there is no likelihood of his absconding or tampering with the prosecution witnesses.
• That this application is being made bonafide and in the interest of justice.
• That the petitioner is ready and willing to abide by any condition as may be imposed by this Hon’ble Court under Section 482(2) of the BNSS, including co-operating with the investigation.

It is, therefore, prayed that Your Lordships may graciously be pleased to enlarge the petitioner on anticipatory bail in the event of his arrest or surrender in connection with ___________________, for the offences registered under Sections ___________________ of the B.N.S., which is now pending in the Court of ______________________.

AND/OR

Pass such other order or orders as Your Lordships may deem fit and proper in the facts and circumstances of this case for doing conscionable justice to the petitioner.

AND for this the petitioner shall ever pray.

Affidavit

A F F I D A V I T

{ADD PARVIKAR NAME}

I, ___________________, aged about _______________, Son of _________________, Resident of ________________________________, do hereby solemnly affirm and state as follows: –

1.      That I am Friend and Pairvikar of the petitioner in this case and am well acquainted with the facts and circumstances of this case.

2.      That the contents of this petition and affidavit have been read over and explained to me in Hindi which I have fully understood the same.

3.      That the statements made in paragraphs ____________________________________ are true to my knowledge and those made in paragraphs ____________________________________ are true to my information and derived from relevant records of this case and the statement made in rest of the paragraphs are my humble submissions before this Hon’ble Court.

4.      That the annexure is the true /typed/ photocopy of its original.

Verified, signed and sworn this affidavit at the premises of Hon’ble High Court of _____________ on this the …… day of Month ____ year______.

Index

IN THE HIGH COURT OF __________________ AT _________________

(CRIMINAL MISCELLANEOUS JURISDICTION)

A.B.A No. __________ / 2026

XYZ                                                         ……PETITIONER

     VERSUS

The State of __________________                    …..OPPOSITE PARTY

Sub: Anticipatory Bail Matter

I N D E X

Sl. No.	Annexures		Particulars	Pages
1.			Anticipatory Bail Application with its affidavit and Adhar Card of Pairvikar.
2.	ANNEXURE–1		Certified copy of the F.I.R. in connection ________
3.	ANNEXURE–2		Photocopy of the _________
4.			Impugned Order (add rejection order of Session Court
5.		VAKALATNAMA

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This draft is prepared by Jeet Sinha

Advocate at Jharkhand High Court