IN THE COURT OF MSXXXXXXXXX, LD. M.M.

SOUTH-EAST DIST., SAKET COURT, NEW DELHI.

IN THE MATTER OF :-

xx                       VS.                       xx

                                                                   Cr.Case NoXXXXX/XXX

     FIR NO.XXX20XX

                                                                   U/S. 337 of IPC,   

     P.SXXXXX

                                                                   D.O.H.: xxx

APPLICATION ON BEHALF OF APPLICANT / ACCUSED NAMELY XXXXX FOR CANCELLATION OF NON BAILABLE WARRANT.

MOST RESPECTFULLY SHOWETH :-

1.       That the captioned FIR case proceeding is pending before this Hon’ble Court and same is fixed for xxx

2.       That the applicant / accused is filing the present application seeking cancellation of Non Bailable Warrant in the said FIR case proceeding, which have been issued by this Hon’ble Court against the applicant / accused on xxx

3.       That applicant / accused submits that applicant / accused always appeared through his counsel before this Hon’ble Court from the first date of hearing when summons was issued to the accused/applicant.

4.       That it is submitted the previous counsel of the Applicant / accused was not informed about the date of hearings of the present case, even applicant unable to communicate with his previous counsel about the status of the present case. In the second week of September, 20XX previous counsel of the Applicant informed that he is not interested to pursue or appear in his case, due to which Applicant engaged the new counsel for the present case, who inspected the order-sheets and found that on 06.06.20XX none has appeared on behalf of applicant / accused before this Hon’ble Court, resulting which this Hon’ble Court was pleased to issued Non-Bailable Warrants against the applicant / accused for his non-appearance / absence.

5.       That it is respectfully submitted that the absence of the applicant / accused was not intentional, deliberate but due to the reason as submitted above and applicant / accused never wanted to abscond or to avoid participating in the captioned proceeding as it is apparent from the record, except for previously applicant / accused was regularly participating in the proceeding.

6.       That it is further submitted that accused is law abiding citizen and do have faith in the administration of justice and has nor intention to hamper or cause any kind of hindrance to the proceedings of the captioned case.

7.       That applicant / accused undertakes to appear regularly before this Hon’ble Court in the captioned matter and will be more vigilant in participating the proceeding of the present case and will abide by the conditions as directed by this Hon’ble Court.

8.       That the applicant seeks the permission of this Hon’ble Court to urge any additional ground which would be made available to him at the time of hearing of the present application also.

P R A Y E R

          In view of above, it is therefore most respectfully prayed that this Hon’ble Court may be pleased to cancel the Non Bailable Warrants issued against the applicant / accused, in the interest of justice.

Pass such further order or orders as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case be also passed in favour of the applicant.

          It is prayed accordingly,

DELHI                                                       APPLICANT / ACCUSED

THROUGH

DATED

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COUNSELS FOR THE ACCUSED

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