JOINT AFFIDAVIT ON BEHALF OF ACCUSED NOS. 2, 3 AND 4 IN SUPPORT OF THEIR WRITTEN OBJECTION TO THE STATE’S APPLICATION FOR CANCELLATION OF AD-INTERIM BAIL

 

DISTRICT: NORTH 24-PARGANAS

IN THE COURT OF THE LEARNED ADDITIONAL CHIEF JUDICIAL MAGISTRATE

AT BIDHANNAGAR

NORTH 24 PARGANAS

 

G.R. No. 230 of 2025

Arising out of Bidhannagar Women Police Station Case No. 06 of 2025

dated 01.03.2025

Under Sections 385/506/509/120B of the Indian Penal Code, 1860

(with subsequently added Sections 419/420/465/467/468/471/109/118/120 IPC)

 

State of West Bengal   

               ...Prosecution

Versus

Ms. Rina Paladhi & Others    

               ...Accused Persons

 

 

JOINT AFFIDAVIT ON BEHALF OF ACCUSED NOS. 2, 3 AND 4

IN SUPPORT OF THEIR WRITTEN OBJECTION TO THE STATE’S APPLICATION

FOR CANCELLATION OF AD-INTERIM BAIL

 

We, the following deponents;

1. Debojita Chatterjee Chakraborty, wife of Arnab Chakraborty, aged about 32 years, by faith Hindu, by occupation Service, residing at Chhota Jagulia, North 24-Parganas, Pin - 743294, being Accused No. 2 / Deponent No. 1;

2. Gopa Paul, daughter of Gobinda Paul, aged about 32 years, by faith Hindu, by occupation Service, residing at Panihati (M), Sodepur, North 24-Parganas, Pin - 700110, being Accused No. 3 / Deponent No. 2;

3. Piyali Roy, wife of Kalyan Roy, aged about 39 years, by faith Hindu, by occupation Service, residing at Baybreeze Apartment, Flat No. 2, 937 Nayanad, Mukundapur, Sonarpur, South 24-Parganas, Kolkata - 700099, being Accused No. 4 / Deponent No. 3;

do hereby jointly and severally solemnly affirm and state as follows;

1.  That we are accused nos. 2, 3 and 4 respectively in the above-mentioned proceeding. We are fully acquainted with the facts and circumstances of the case, competent to affirm this affidavit, and duly authorised to affirm the same jointly in support of our written objection to the State’s application under Section 480(5) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

2.  That on 13.03.2025 we voluntarily surrendered before this Learned Court and prayed for bail. Upon hearing the parties and perusing the formal FIR, written complaint and the materials then produced, this Learned Court was pleased to record that our custodial detention was not necessary and granted us ad-interim bail of Rs.1,000/- each with one registered surety of the like amount.

4.  That we duly furnished the bail bonds and have remained subject to the jurisdiction of this Learned Court. We have regularly made ourselves available to the judicial process and have neither evaded nor attempted to evade the due course of justice.

5.  That after being released on bail, none of us has violated any condition of bail, absconded, failed to cooperate with the investigation, approached or intimidated any witness, interfered with the administration of justice, tampered with any document or evidence, or committed any further offence. The State’s application does not specify any such post-bail misconduct.

6.  That the State seeks cancellation principally on the ground that graver provisions of the IPC were subsequently added. We state that the subsequent addition or alteration of penal provisions does not amount to any act or omission on our part and cannot, by itself, constitute abuse of the liberty granted to us.

7.  That by order dated 30.04.2026 this Learned Court disposed of the de facto complainant’s application dated 13.06.2025 pursuant to the direction of the Hon’ble High Court at Calcutta dated 17.04.2026. The said order allowed monitoring/further investigation on the aspect of the appropriate penal provisions and directed the Investigating Officer to proceed with the investigation “as per law”.

8.  That the order dated 30.04.2026 did not cancel, suspend or modify our ad-interim bail dated 13.03.2025; did not direct our arrest or surrender; did not record our guilt or any prima facie finding that we committed the subsequently added offences; and did not record any violation of bail or obstruction of investigation on our part. The matter was fixed on 30.06.2026 for our appearance and for hearing the applications filed by the accused persons other than accused no. 1.

9.  That the observation in the order dated 30.04.2026 that an aspect concerning the provisions of law had not been properly investigated is a direction governing the scope of investigation. It is not a finding as to the result of such investigation and cannot be treated as proof of any allegation against us.

10.  That the documents referred to by the State, including the Indian Nursing Council letter dated 22.07.2022, emails of May 2024 and documents relied upon in connection with CRR No. 1793 of 2025, relate to a period preceding the grant of bail. Investigation into such pre-existing materials does not amount to any supervening conduct by us.

11.  That the accusations are substantially documentary and institutional in nature. The relevant letters, emails and institutional records have either been obtained or are capable of being obtained from independent bodies. We have not destroyed, altered, concealed or withheld any record from the Investigating Officer.

12.  That we deny the allegations of forgery, cheating, personation, conspiracy, abetment, concealment, extortion and criminal intimidation made against us. The mere addition of penal provisions is not proof of the essential ingredients of any alleged offence, and all our rights and contentions on facts and law are expressly reserved.

13.  That cancellation of bail already granted stands on a footing distinct from rejection of bail at the initial stage. In the absence of any misuse of liberty, supervening circumstance or legally sustainable challenge to the order granting bail, our continued detention is neither necessary nor justified.

14.  That we undertake to continue to cooperate with the investigation, to appear before this Learned Court and the Investigating Officer as and when lawfully directed, not to influence any witness or tamper with evidence, and to comply with every reasonable condition that this Learned Court may impose.

15.  That, without prejudice to our prayer for rejection of the State’s cancellation application and confirmation of our bail, we are ready to furnish fresh or additional bail bonds and comply with any further reasonable condition concerning the subsequently added provisions, instead of being directed into custody.

16.  That the statements made in the accompanying written objection may be treated as part of this affidavit. The submissions of law contained therein are based on advice received from our learned Advocate, which advice we believe to be true and correct.

 

 

 

 

We, Debojita Chatterjee Chakraborty, Gopa Paul and Piyali Roy, the three deponents above named, do hereby jointly verify that the statements made in paragraphs 1 to 16 are true to our respective knowledge and belief, derived from the case records and legal advice received; that the submissions of law are based on advice which we believe to be true; and that no material fact has been concealed therefrom.

Verified at Bidhannagar, North 24-Parganas, on this ____ day of August, 2026.

 

_______________________________

Debojita Chatterjee Chakraborty
Accused No. 2 / Deponent No. 1

 

_______________________________

Gopa Paul
Accused No. 3 / Deponent No. 2

 

_______________________________

Piyali Roy
Accused No. 4 / Deponent No. 3

Identified by me:

Advocate

Notary