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I N T H E C OU RT O F S P E C I A L JU D G E , ( N . D . & P. S .

)
PAT I A L A

State of Punjab

Versus

Jodh Singh @ Kamal S/o Shamsher Singh r/o Near Satsang


Bhawan, Bhawanigarh Distt Sangrur

FIR NO. 41 dt. 25/2/2015


u/s 22/61/85 NDPS Act,
Police Station Kotwali, Patiala

Application for bail u/S. 167(2) Cr.P.C.

Sir,

It is respectfully submitted as under:

1. That the above noted case is pending in this Honble court


and same is fi xed up for awaiting challan.

2. That prima facie no case what so ever is made out against


the applicant/accused. And the applicants/accused has
been falsely involved in this case by the police of PS
Kotwali Patiala with ulterior motive.

3. That in the above noted case the accused applicant has


been arrested on 25/2/2015 and the prosecution has to
produce the challan within 180 days as per the provision
of 167(2) Cr.P.C. But the prosecution is failed to produce
the challan against the accused with in the prescribed
period of 180 days.

4. That the alleged separate recovery was of intoxitent


capsules & Tablets from the accused/applicant vide alleged
separate memo and it is further worthy to mention here
that it is also by prosecution that separate samples were
sent with chemical analysis from the present alleged
separate recovery.

5. That it is worthy to mention here that in the above noted


case prosecution failed to produce the challan against the
accused with in the prescribed period of 180 days as such
right of bail as per the provision of Cr.P.C. accrued to the
applicant/accused.

6. That the Challan in the aforesaid case yet to be presented


and it will also take long time for concluding of the trail of
the case as such the detention of the applicant for such a
long time is uncalled for.

7. That the applicant will not tamper with the prosecution


evidence.

8. That the applicant undertakes to appear on each and


every date of hearing and is ready to furnish surety/bail
bonds to the satisfaction of this Honble Court.

It is therefore prayed that the application may kindly


be accepted and the applicant may kindly ordered to be
released on bail till the fi nal decision of the case.

Submitted by:

Dated:

..Accused/Applicant
Through counsel:

Arun Bansal & Himanshu


Advocates, Distt Courts,Patiala
P/2178/09

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