Draft of Application for Bail

IN THE COURT OF DISTRICT & SESSION JUDGE, DELHI

 

A S/o…Sh……R/o…Delhi                                   .....Petitioner/Accused

Versus

State                                                                        ...… Respondent

 

                                          FIR No.: 71/91

                                                                    U/s:………………N.D.P.S. Act

                                                                     Police Station: Connaught Place

 

Application under Section 437, Criminal Procedure Code 1973 for Bail

The Accused above-named most respectfully SHOWETH:-

1.     That the Accused was arrested by the police on 1^st January 1991 and is in judicial custody since then. It is alleged that on 1^st January 1991, the Accused was suspiciously moving on Baba Kharakh Singh Marg, New Delhi when the police apprehended him, conducted the search and recovered 3 gms of smack from his pocket.

2.     That the Accused has been falsely implicated in the instant case and he has nothing to do with the alleged offence.

3.     That nothing was recovered from the possession of the Accused or at his instance the so-called case property had been planted upon the accused.

4.  That the Accused is a law-abiding citizen and belongs to a very respectable family and has never indulged in any illegal activities and commands respect and admiration in his locality.

5. That in November, 1990, the Accused found some persons selling smack near Hanuman Mandir, Connaught Place, New Delhi. The Accused immediately reported it to police, as a result of which police also arrested some of the persons. Since then those persons, who were arrested at the instance of the Accused, were threatening accused to falsely implicate him in a criminal case in collusion with police. The Accused made a complaint in this regard to the Dy. Commissioner of Police, true copy of which is annexed hereto as Annexure ‘A’.

6.  That after the said complaint, the Accused was called by Vigilance Department Police who enquired into his complaint. True copy of the said notice issued by the Vigilance Cell is enclosed herein as Annexure ‘B’.

7.     That it is unimaginable that the Accused who made a complaint against the selling of smack, would himself indulge in such activities.

8. That the Accused is a permanent resident of Delhi and there is no chance of absconding in case if he is released on bail.

9.   That there is no chance of the Accused tampering with the prosecution evidence in the event of release on bail.

10.  That the Accused is prepared to join the investigation as and when directed to do so.

11.    That the Accused is not a previous convict and has not been involved in any crime of this nature except the present case.

12.    That the present case is a result of clear manipulation by the police.

13.    That the Accused from all account is an innocent person.

 

Prayer

It is therefore respectfully prayed that the Accused may kindly be released on bail during the pendency of this case.

Accused

Through

Sd/- (Advocate)

Place:

Date: