BEFORE THE HON’BLE SPECIAL COURT OF ADDITIONAL

SESSIONS JUDGE TADA/NIA AT SRINAGAR

IN THE CASE OF: TAWHEED AHMAD BHAT

Through his brother
JAVEED AHMAD BHAT
Both Sons of : Late Abdul Khaliq Bhat
Both Residents of: Sozeith Goori Pora
Budgam

V/S

STATE THROUGH
S.H.O POLICE STATION RAJBAGH

IN THE MATTER OF: APPLICATION SEEKING BAIL OF THE ALLEGED-

ACCUSED.

May it please your honour;

The application seeking grant of bail to the alleged-accused
is submitted as under:

1. That the applicant has filed a bail application before

this Hon’ble court in case of F.I.R No. 73/2018 P/s
Rajbagh, Copy annexed as Annexure-“1”

2. That the above named alleged-accused is a domicile of

Union Territory of J&K and is a most law abiding and
peaceful citizen of India and the instant application
is filed by the Brother of the accused (namely Javeed
Ahmad Bhat S/o Abdul Khaliq Bhat R/o Sozeith Gori-pora
Budgam) who is interested in life and liberty of the
accused.

3. That the accused came to be arrested by the police

concerned on 09-03-2019 without any reasonable cause or
justification.
4. That the alleged-accused is purely an innocent person
who has not committed any kind of offence of whatsoever
nature nor even the alleged accused possess a shade of
criminal behavior on his past.

5. That the alleged-accused has been booked only in one

F.I.R bearing no.73/2018 of Police Station Rajbagh,
Copy annexed already as Annexure-“1” and PSA was
slapped on accused person by District Magistrate
Srinagar Under order No. DMS/PSA/48/2019 dated 08-08-
2019 on the basis of same F.I.R which is also evident
from the PSA dossier, the copy of the dossier is
annexed hereto as Annexure-“2”

6. That the Hon’ble High Court has been pleased to quash

the PSA slapped on the alleged-accused vide its order
dated 03-11-2020 in WP(Crl)403/2019. Copy of order
annexed hereto as Annexure-“3” for kind perusal of the
Hon’ble Court.

7. That the investigation of the case is complete and

charge sheet stands submitted by the Police concerned
in the said F.I.R and case titled state through P/s
Rajbagh V/s Showkat Ahmad Khan and others is pending
disposal before the Hon’ble Court and next date of
hearing is 07-11-2020.

8. That there is no apprehension or not even a remote

possibility for tempering with the prosecution evidence
as the final report stands already submitted.

9. That the alleged-accused has moved an application

through virtual/physical mode through the counsel on
09-06-2020 seeking permission to participate in last
rituals and funeral rites of his father who died on 09-
06-2020 which could not be processed on-time due to
Covid-19 restrictions as such a lenient view may be
taken against alleged accused and he may be released on
bail so as to allowing him to visit the grave of his
deceased father which is his right and duty of the son
 towards the father. Copy of the death certificate
attached hereto as Annexure-“4”.

10. That the liberty of the alleged accused has been

curtailed by the non-applicants without any rhyme or
reason.

11. That the alleged-accused undertakes to abide by all

terms and conditions attached to his bail and is ready
to furnish the bail bonds to the satisfaction of this
Hon’ble Court and also shall not leave the territorial
jurisdiction of this Hon’ble Court without prior
permission in case accused is released on bail.

Prayer:
IN THE PREMISES, it is therefore prayed that the
Hon’ble court may be pleased to allow the application
in hand and admit/enlarge alleged-accused on bail
keeping in view the above mentioned facts of the case
and the pandemic situation due to Covid-19 infection
outbreak Protocols to be followed and SOP’s issued by
the Government; same would be in consonance with law
and justice.

Applicant

Javeed Ahmad Bhat

S/o Late Abdul Khaliq Bhat
R/o Sozeith Gori-Pora Budgam
Through the Counsel:

Adil Rashid Bhat (Advocate)

Srinagar And Associates
05-11-2020 Cell/Whatsapp No. 7006601376
IN THE COURT OF SPECIAL COURT OF ADDITIONAL SESSIONS
JUDGE TADA/NIA AT SRINAGAR.

Suit/Appeal No……………………………………………………………….of 20…

In re: JAVEED AHMAD BHAT S/O LATE ABDUL KHALIQ BHAT R/O SOZEITH
GORI-PORA BUDGAM Plaintiff /Appellant /Petitioner/ Complainant
VERSUS
STATE THROUGH S.H.O POLICE STATION RAJBAGH Defendant/Respondent/
Accused
KNOW ALL to whom these present shall come that I/We. JAVEED AHMAD BHAT S/O
LATE ABDUL KHALIQ BHAT R/O SOZEITH GORI-PORA BUDGAM the above
named,do hereby appoint: ADIL RASHID BHAT, QAZI ATHAR AND WASEEM RAJA BHAT.
(herein after called the advocate/s) to be my/our Advocate in the above noted case authorize
him:-
1. To act, appear and plead in the above-noted case in this Court or in any other Court
in which the same may be tried or heard and also in the appellate Court including High
Court subject to payment of fees separately for each Court by me/us.
2. To sign, file, verify and present pleadings, appeals, cross-objections or petitions for
executions review revision, withdrawal, compromise or other petitions or affidavits or
other documents as may be deemed necessary or proper for the prosecution of the said
case in all its stages subject to payment of fees for each stage.
3. To file and take back documents, to admit and/or deny the documents of opposite
party.
4. To withdraw or compromise the said case or submit to arbitration any differences or
disputes that may arise touching or in any manner relating to the said case.
5. To take execution proceedings.
6. To deposit, draw and receive monthly cheques, cash and grant receipts thereof and to
do all other acts and things which may be necessary to be done for the progress and in
the course of the prosecution of the said case.
7. To appoint and instruct any other Legal Practitioner authorizing him to exercise the
power and authority hereby conferred upon the Advocate whenever he may think fit to
do so and to sign the power of attorney on our behalf.
8. And I/We the undersigned do hereby agree to rectify and confirm all acts done by the
Advocate or his substitute in the matter as my/our own acts, as if done by me/us to all
intents and proposes.
9. And I/We undertake that I/We or my/our duly authorised agent would appear in
Court on all hearings and will inform the Advocate for appearance when the case is
called.
10. And I/We the undersigned do hereby agree not to hold the advocate or his
substitute responsible for the result of the said case.
11. The adjournment costs whenever ordered by the Court shall be of the Advocate
which he shall receive and retain for himself.
12. And I/We the undersigned to hereby agree that in the event of the whole or part of
the fee agreed by me/us to be paid to the advocate remaining unpaid he shall be
entitled to withdraw from the prosecution of the said case until the same is paid up.
The fee settled is only for the above case and above Court. I//we hereby agree that once
fee is paid, I/We will not be entitled for the refund of the same in any case whatsoever
and if the case prolongs for more than 3 years the original fee shall be paid again by
me/us.

IN WITNESS WHEREOF I/We do hereunto set my/our hand to these presents the contents
of which have been understood by me/us on this 5TH day of November 2020

Accepted subject to the terms of the fees.

Advocate Client