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BEFORE THE HON’BLE COURT OF CHIEF JUDICIAL MAGISTRATE AT

BUDGAM

In the case of:


Gulshan Sonotra (age 40 years)
S/O Gh. Mohidin.
R/O Peer Wari Baramulla
(Applicant)
VERSUS
State through S.H.O P/S Khanshaib

(Non-applicant)
In the matter of:
Application for grant of bail in favour of applicant
above named.
May it please your honour:
That the applicant most humbly submits as under:
1. That the above named applicant is the permanent resident of
State of Jammu & Kashmir and as such has every right to
invoke the jurisdiction of this hon’ble court in order to seek
redressal of his legal rights.
2. That the applicant named above stands arrested by S.H.O
police station Khanshaib on 18 th of April 2010 and involved him
in a false and frivolous criminal case and is in their custody.
3. That it is apt to mention here that the police personals of
police station Khanshaib without any justified cause or
reason has implicated the applicant in a false, frivolous
and fictitious allegation and the concerned police station
in this behalf had booked the applicant in a false case.
4. That due to continued detention in police lockup the
entire family members are frustrated because the
applicant is the sole bread earner of his family.
5. That the coordinal principal of criminal jurisprudence is
that every accused should be treated as an innocent till
the guilt is proved against beyond any shadow of doubt
and if the application at hand will not be considered,
same will result the pre-trail punishment of applicant.
6. That in the event of applicant’s detention it implicates the
gross violation of right of liberty as guaranteed under the
constitution of the country therefore this application of
mind merits to be accepted.
7. That the investigation of the case is complete in all
respects and the applicant do undertake that in the event
of grant of bail, he will not hamper with the investigating
agency nor will temper with the prosecution witnesses.
8. That the applicant will fulfill all the conditions
whatsoever be imposed upon him by this honorable
court.
9. That more grounds will be agitated at the time of
arguments.

In the premises, it is therefore prayed that the


application at hand be allowed and applicant be
enlarged on bail to secure the ends of justice.

Date: 27-04-2010
Applicant
Through counsel
Z.A Bhat & Associates

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