Bail Application before Judicial Magistrate

IN THE COURT OF SH. PANKAJ SHARMA, J.M.    PATIALA HOUSE COURTS, NEW DELHI

            Bail Application No._______of 2024

STATE              VERSUS               SALMAN

                                                   FIR NO. 60/24

U/S. 9/13 Delhi Agricultural Cattle Preservation Act, 1994

PS.   Vasant Kunj South

APPLICATION UNDER SECTION 480, BNSS, 1973 FOR BAIL ON BEHALF OF ACCUSED SALMAN S/o.YUSUF

The Accused above- named most respectfully showeth :-

1. That the accused/applicant was arrested by the police on 08.02.2024 and was produced before the Hon’ble Court on 08.02.2024 and was remanded to police custody for two days. Thereafter the accused/ applicant was sent to judicial custody on 11.02.2024 and is in jail since then.
2. That an FIR No. 60/24 dated 08-02-2024 was registered at the Police Station Vasant Kunj South , New Delhi under Sections 9 & 13 of Delhi Agricultural Cattle Preservation Act, 1994 against the applicant/ accused.  As per said FIR , HC Ravinder Singh was requested on behalf of Eagle One that one truck bearing no. HR 69-0370 loaded with cow meat had entered into Delhi which should be cheked.  That HC along with other staffs started checking  at Rajokari Flyover and at about 2.05 A.M. the truck no. HR 69-0370 was coming from side of Gurgaon which was got stopped from which smell of meat was coming. On checking it was found that the truck was loaded with fresh red meat of any animal. It is further stated that on interrogations accused could not satisfactorily answer about the meat.
3. That the Applicant / Accused is an innocent driver at his young age of 25 years and has been falsely implicated in the instant case as he has nothing to do with the alleged offence.
4. That the Applicant / Accused is a married person of 25 years of age and earns his livelihood  by doing the work of a driver for last 2-3 years. He has responsibility of his parents and other family members besides his wife. That the Accused belongs to a poor but respectable family and has never indulged in any illegal activities or case.
5. That there is no chance of the accused tampering with the prosecution evidence in the event of the release on bail as the recovery of alleged meat has been affected and investigation by police is complete.
6. That the accused is a permanent resident of  Distt. Baghpat, UP., and there is no chance of his absconding in case  he is released on bail.
7. That the Accused is prepared to join the investigation as and when he is directed to do so.
8. That the Applicant / accused is ready to furnish the sound surety to the satisfaction of this Hon’ble Court.
9. That the Applicant / accused  is ready to abide all the terms and conditions if any imposed upon him while admitting him to bail.
10. That the Accused has clean antecedent and has never been involved earlier in any crime of any nature.
11. That the Accused from all account is an innocent person.

PRAYER

It is, therefore, most respectfully prayed that the Accused may kindly be released on bail during the pendency of this case in the interest of justice.

                                                   Accused

                     Through

                                                ( Avinash Nandan Sharma)

                                                                 Advocate

                               Ch.No.671, Patiala House Court

                                                 New Delhi, Mob: XX

New Delhi

Date: