Hi
You have to move the court under section 437 of Criminal Procedure Court and you can seek bail on the following grounds:
1. That the present FIR has been registered on false and bogus facts. The facts stated in the FIR are fabricated, concocted and without any basis.
2. That the police has falsely implicated the applicant and arrested him in the present case, the applicant is a respectable citizen of the society and is not involved any criminal case.
3. That the facts stated in the complainant was also saddened and grieved by the shocking murder and was participating in the funeral/ condolence meeting and had no role whatsoever to be arrayed in the case
4. That the applicant is not required in any kind of investigation nor any kind of custodial interrogation is required, nor any recovery is to be made at the instance of the applicant.
5. That the applicant is having very good antecedents, he belongs to good family and there is no criminal case pending against them.
6. That the applicant is a permanent resident and there are no chances of his absconding from the course of justice.
7. That the applicant undertakes to present himself before the police/court as and when directed.
8. That the applicant has high diabetic and high blood pressure, the applicant is in constant need of nursing support and medication.
Hope this information is useful