Anticipatory Bail Application
BEFORE THE HON'BLE COURT OF DISTRICT AND SESSION JUDGE (Central Distt. ) TIS
HAZARI COURTS, DELHI
IN THE MATTER OF:
STATE V/s A
S/O Sh. B
(HUSBAND OF COMPLAINANT)
R/O H. No. 1, K road, Ward- , Sonipat -
NAME OF THE COMPLAINANT
C W/o Sh. A and D/o Sh.D resident of H. No. 6, ___________________, New Delhi- 110005.
I st
APPLICATION FOR ANTICIPATORY BAIL U/S 438 Cr.P.C. ON BEHALF OF ABOVE NAMED
APPLICANT.
MOST RESPECTFULLY SHOWETH:-
1. That the applicant is a peace loving and law abiding citizen of India and residing at the
aforesaid address, and earning for his livelihood.
2. That on dated ____________ the marriage between the applicant and the complainant was
solemnized according to Sikh rites and ceremonies at Delhi which was duly consummated,
However, no issue was born out of said wedlock.
3. That the conduct/behavior of the complainant remained all right, hardly for few days after
marriage, towards applicant and his family. After that her conduct was changed and she started
misbehaving with the applicant and his family members and started torturing the applicant mentally
by pressurizing the applicant to live separately from his family members. All the misbehavior was
done on the instigation of her parents, who always instigate the complainant not to stay in the
matrimonial house like a dutiful wife. Complainant never discharged the duties of dutiful wife with
applicant and also as dutiful daughter- in- law towards applicant’s family. Further complainant
prevented applicant from freely talking with his family members and restrained him from having any
attachments with his family members, as complainant never liked them. This action of complainant
has caused mental agony and harassment to applicant as well as to his family. Moreover,
complainant is extremely fashionable and extra modern type of woman and highly extravagant. She
demands money from applicant without any need for unnecessary issues. She used to pressurize
