is PEPORE THR EO Le COUNT OF PY LOO Toman Corte 2 PEMNOE Powe At strana te te ee + we mis (= T ? Prew be fame 4 Lule orsaens ome ae Cadre fp bremar cer CUS (NDEX a me Index Leaves Page Bo. eo Application © 06 leaves o2 Annexure leaves 03 Power of attorney Ol leave Applicant through counsel Shahnawaz Adi Shah Advocate Cell No 700695447 3BEFORE THE HON'BLE COURT OF 3°” hy the case of In the matter of:- Application seeking b: ADDITIONAL DISTRICT & BESBIONS JUDGE AT SRINAGAR Ue fof damm And Kashiner Applicant vs Sandeep Kumar and other Non-applicant ail of the accused No.2 Hardeep singh S/O Pakhar Singh R/O Megowal Doaba Hosiarpura Punjab after admitting fresh bail bonds. May it please your Honour, The applicant humbly submits as under: 1. ‘That the above named accused has been arrested by the police under FIR No.57/2021 under section 8/51 NDPS and the challan/charge sheet has been presented before this Hon’ble Court on the completion of the investigation. ‘That the accused No.2 is an uneducated illiterate person who was not aware that he has to appear on each and every hearing of the case. Furthermore he thought that that the challan filed against him has been disposed off when he was enlarged at bail. Aptly the next date of hearing of the case is on 14/12/2023. ‘That the accusedNo.2 is a labourer who often uses to go to different regions in search of menial work and thus there was communication gap between his counsel andined Nod which renutted in the abarner the in herrings of the recuned Neon the pre Hertinently the necused Ne 2 in the only member int family who is earning hand and he is the only one whe caters the day today requirements of his farni suffering, particularly the bed ridden parents who from several chronic ailments. That the accused No.2 did not cause his appearance on last several hearings and thus the hon’ble court b forfeited his bail bonds and has sent him to judicial custody on 28/11/2023. That the accused No. 2 is willing to furnish the fresh bail bonds to secure his bail and assure the hon’ble court that he will remain present on each and every hearing of the case and will stand the trial, That the applicant is a labourer by profession who is the only person in his family to shoulder the responsibilities of the whole family and this is the only applicant who by doing menial works cater the day to day requirements of his family members including the old aged bedridden chronic patient parents. That the accused / applicant is innocent and has not committed any offences whatsoever and the applicant has no desire to evade the due Process of law and shall face the trial to vindicate his innocence. That there is no likelihood of applicant of tampering with the prosecuting evidences. That there is no useful purpose would be served if the applicant is denied bail,that may be anpuard hy the tor nvanting Naud Hr Thar the appheant doen net have any pant criminal 12 That the detention of the appheant in under the » of circumstances illegal and contrary to the prov the law under Art, 21 and 22 of the constitution 13, That this Hon'ble Court has discretion to grant Bail on furnishings the fresh by the accused. ‘The granting, of bail is Rule and its rejection is exception, moreover every accused is presumed to be innocent until the final decision of the court if he is not released on bail. 14. That the charge sheet is pending before the Hon’ble Court and it will not serve any purpose if the accused be continued to remain in the judicial custody. The accused if enlarged at bail will be able to pursue his case more effectively. In the premises it is therefore prayed that this Hon’ble Court may enlarge the accused / applicant on bail on of justice. Place: Srinagar Date: 29/11/2023