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.