IN THE COURT OF HON’BLE JUDGE SPECIAL COURT

BATHINDA.

State versus 1. Shankar Singh Tamber age

about______years son of
Gopal Singh resident of
Dhungar Kheri, Shamgarh,
Mandsaur, Madhya Pradesh.

2. Radhe Sham age about

____years son of Prabhu
Lal resident of Lasudia,
Bhawani Mandi, Jhalawar,
Rajasthan now Confined in
Central Jail, Bathinda.

Accused/Applicants

Case FIR No.106 Dated 22.06.2021.

Under Section 18(b)/61/85 Narcotic

Drugs & Psychotropic Substances Act.

Police Station Sangat, Bathinda.

First Bail Application Under Section 439 Cr.P.C

Sir ,

It is respectfully submitted as under:

1. That this is first bail application on

behalf of accused/applicants and there is
no such bail application is pending,
decided or declined by any other court
including Hon’ble Punjab and Haryana
High Court Chandigarh as disclosed by
accused/applicants. An affidavit is
attached herewith.
2. That the alleged recovery of 700 Gram
opium has been foisted on the accused/
applicants otherwise nothing incriminating
was recovered from his possession.
3. That the accused/applicants has been
falsely implicated in the above noted
case. That the entire prosecution story
is preplanned.
4. That the accused/applicants are in custody
since 22.06.2021 and his person is not
required by the police.
5. That the alleged recovery does not falls
within the ambit of provisions of section
37 of Narcotic Drugs & Psychotropic
Substances Act and the alleged recovery is
a non-commercial quantity.
6. That the mandatory provisions of Narcotic
Drugs & Psychotropic Substances Act have
not been complied with by the police.
7. That the accused/applicants has not
committed the alleged offence nor will
commit such offence if released on bail.
8. That no Gazetted officer was joined
by the police at the time of alleged
recovery which shows the story of
police doubtful.
9. That the allegations leveled against the
accused/applicants are specifically denied
and it will long time for presentation
of challan.
10. That the prosecution witnesses are
interested and official witnesses and
there is no apprehension of their being
won over by the accused/applicants.
11. Nothing is to be recovered from him as the
alleged recovery has been since affected.
12. That trial of the case is likely to take
sufficient long time and no useful
purpose will be served to keep the
accused/applicants in further custody.
13. That the accused/applicants undertake to
appear before the court on each and every
date of hearing without fail.
14. That the accused/applicants is ready to
furnish bail bonds to the entire
satisfaction of this Honl’ble Court.
15. The details of cases pending/decided
against the accused are as under: -
1. Whether the accused/applicants were/are
in any other cases registered against
him anywhere in India ? In case, it
is up to date status of the proceedings
in those case .
Ans: No
2. If the accused/applicants are on bail any
cases pending against him or sentence
awarded to him in any others cases has
suspended, specific mention is required to
be made .
Ans: No
3. Number title of any other pending cases
against the accused/applicants in the
court where such a petition is moved.
Ans: No
4. Whether he/they/has/have even been
declared proclaimed offender in any case
or not.

Ans: No
 It is therefore prayed that
the court may direct the release the
accused/applicants on bail in the interest
of justice.

Any other order which the court may deem fit

and proper in the facts and circumstances of
the case may be also passed in favor of the
accused/applicants.

Dated Submitted By:

1. Shankar Singh Tamber son

of Gopal Singh resident
of Dhungar Kheri,
Shamgarh, Mandsaur,
Madhya Pradesh.

2. Radhe Sham son of Prabhu

Lal resident of Lasudia,
Bhawani Mandi, Jhalawar,
Rajasthan now Confined in
Central Jail, Bathinda.

Accused/Applicants

Through Counsel
IN THE COURT OF HON’BLE JUDGE SPECIAL COURT
BATHINDA.

State versus Shankar Singh and others

Case FIR No.106 Dated 22.06.2021.

Under Section 18(b)/61/85 Narcotic

Drugs & Psychotropic Substances Act.

Police Station Sangat, Bathinda.

First Bail Application Under Section 439 Cr.P.C

AFFIDAVIT

I_______________________________________
______________________District______________do
hereby solemnly declared and affirm as under:-

1. That accused/applicants are _________________

of deponent and as such deponent is well
conversant the facts and circumstances of case.
2. That the first bail application on behalf of
accused/applicants and there is no such bail
application is pending, decided or declined
by any other court including Hon’ble Punjab and
Haryana High Court Chandigarh as disclosed by
accused/applicants.
Deponent

Verification
Verified that the contents of
my affidavit are true and correct to the
best of my knowledge and belief and that
nothing has been concealed therein.
Dated Deponent