Bail Application in NDPS Case of Narcotics Control Branch (NCB)



                     PATIALA HOUSE COURT, NEW DELHI


                    Bail Application No._________of  2024


          IN RE :



S/o. Sh.  Lal

R/o. House No. 00,

Keha Ram Street,

Mukatsar, Punjab.                                                   …. Petitioner





State  (NCB)                                                            …. Respondent


                                                                       Case Crime No. VIII/13/DZU/2024

                                                       U/S  21, 25A & 29 of  NDPS Act

                                                                         Narcotics Control Branch, New Delhi

                                                                    Date of Arrest: 24.01.2024





The applicant respectfully submits as under:


  1. That the applicant along with two other accused persons was arrested in the above mentioned case on 24.01.2024 by the NCB team at Delhi.
  2. That according to the case of the prosecution made on the basis of complaint, on 24.01.2024 at about 7.15 IO had received a secret information regarding the drug deals near pillar No.709 at Uttam Nagar West Metro Station, New Deilhi between a Nigerian person namely Ifeanyi Okafor , Rimpu and Banwinder Singh, both are resident of Mukatsar Punjab. And then a raiding team of NCB was constituted for the spot and the said three persons/ suspects were intercepted by the NCB team.  It is alleged that in this raid 25 grams heroin, Rs. 25000 in cash and five mobile phones have been recovered. It is further alleged that 25 grams heroin was given by accused No. 1 to the accused No. 2 and 3 who gave Rs. 25000 to the accused No. 1 as sell proceed of the recovered heroine.
  3. That no narcotics drugs and psychotropic substances have been recovered from the Accused 3.  which fact has been specifically stated in para 9 of the complaint- “that during personal search of accused Balwinder Singh drug was not recovered except one mobile phone.”  The alleged recovery shown from the applicant in his personal search is planted one.
  4. That the applicant first time came in Delhi along with his friend Balwinder Singh, the co-accused in the present case and was moving at the Uttam Nagar Metro Railway Station while he was arrested by the NCB Team. The applicant / accused was wrongly implicated in the above case.
  5. That applicant/accused is victim of narcotic drugs and occasionally uses it when offered by his friend circle and knows nothings about the network of supply of these drugs. He is an innocent addict of drugs which is spoiling his life and family.
  1. The applicant and co-accused Balwinder Singh are friends residing in the same locality at Mukatsar, Punjab and are known to each other for last 8 to 10 years.
  2. That officials of Narcotics Departments also went to search out the residence of the applicant at Mukatsar, but did not find/ recover any kind of narcotic drugs there.
  3. That the applicant is a man of 35 years of age engaged in mobile repair work. He is an uneducated married person having the responsibility of a son aged about 5 years and a widow mother. His father expired 10 years ago. He has to look after all the members of his family.
  4. That the applicant undertakes to join the investigation as and when directed to do so. He is permanent resident of House No. 00 , Kheta Ram Street, Mukatsar, Punjab.
  5. That the charge sheet has been filed  in the instant case before this Hon’ble Court   and hence the  investigation of the case  is complete.
  6. That the applicant undertakes to abide by any of the conditions imposed by this Hon’ble court for admitting the applicant to bail.
  7. That the applicant is ready to furnish the sound surety to the satisfaction of the Hon’ble Court.
  8. That no useful purpose will be served by keeping the accused / applicant in jail with hard core criminals.


           It is, therefore, most respectfully prayed that  this Hon’ble Court may kindly be pleased to grant  bail to the accused / applicant above named till the final disposal of the case  , in the interest of justice.

           Any other relief (s)  which this Hon’ble Court may deem fit and proper on the facts and circumstances of this case, may also be passed.





                                               (Avinash Nandan Sharma)

               Delhi                                                                     Advocate

               Date 09.03.2024                    Ch.No.671, Patiala House Court

                                                               New Delhi, Mob: 7292020323

Print Friendly and PDF