BEFORE THE COURT OF HON’BLE 1st ADDITIONAL

SESSIONS JUDGE AT JAMMU

Sanjay Kumar Jangade & ors.

..Applicants

UT of J&K

Through Incharge, Police Station Satwari

Jammu,JK (UT)

..Non-Applicants

IN THE MATTER OF :- Application for grant of bail under NDPS

Act.

MAY IT PLEASE YOUR HONOUR,

The applicant most respectfully submits as under:-

1. That the above mentioned challan is pending for disposal before

the Hon’ble Court and fixed for hearing on 04/08/2022.

2. That the applicants are residents of Chhattisgarh and work as daily

wage workers in Jammu.

3. That the bail application had already been presented before

the Hon’ble Court of 2nd Additional Sessions Judge, which has

been dismissed in default for non-prosecution and hence are

filing a fresh application.

4. That the applicants have no connection with the offence in which

they have been implicated. The incarceration of the applicants is

having detrimental effect on the family members. The applicants

are only earning members in their respective families.

5. That the applicants have been in judicial custody since 28-04-

2022.It is further submitted that the challan is pending before the

Hon’ble court and investigation is already completed and there is

 no genuine reason to continue the judicial custody of the accused

persons and the accused are behind the bars for past 4 months.

6. That the applicants have been falsely implicated in a case whereas

they have not played any part in the alleged occurrence.

7. That even though bail is a matter of discretion in the case of non

bailable offences but, in case of the applicants the charges leveled

against the applicants are totally false, manipulated and are vague

hence, in such circumstances applicants deserve bail.

8. That applicants have deep roots in the society and are permanent

residents of the above-mentioned state in such eventuality there

is no possibility of jumping over the bail in case bail is granted to

them.

9. That the applicants are ready to co-operate the IO and are ready

to put the presence whenever and wherever the court deems fit

and proper.
 10. That the applicants are ready to furnish bail bonds or any

other requisite condition put forth for the purpose of bail by this

Hon’ble court of Law.

IN THE PREMISES:-

It is therefore, respectfully prayed that keeping in view the

above-mentioned facts it is most humbly submitted that application for

grant of bail may kindly be entertained by calling the report and

thereafter , bail may kindly be granted in the interest of justice.

Dated: 03rd of August 2022. APPLICANTS

THROUGH COUNSEL