BEFORE THE HON’BLE COURT OF CHIEF JUDICIAL MAGISTRATE AT

BUDGAM
In the case of:
Javid Ahmad Ganie
S/O Ab Aziz Ganie
R/O Choruth Qazigund
(Accused)
VERSUS
State through Incharge Officer P/S CIK Humhama

FIR No. 04 of 2011

Under section 2/3 ExIMCO

(Respondent)
In the matter of:
Application for grant of bail in favour of
accused above named.
May it please your honor:
That the application is submitted as under:
1. That the above named accused is the permanent
resident of State of Jammu & Kashmir, thus has
every right to invoke the jurisdiction of this
hon’ble court in order to seek redressal of his
legal rights.
2. That the above named accused has been arrested by
CIK Humhama on 11-10-2011 without any lawful
justification or reason.
3. That the police has arrested the accused on
unjustified reasons and has put him behind bars
which has infringed the most cherished right of
liberty of the accused.
4. That the continued detention and arrest of
accused is in gross violation of rights and
liberty as guaranteed under the constitution.
 5. That the accused has not committed any offence
and his detention in lockup has put his family
into a great trouble.
6. That the accused has not committed an offence
which is punishable with death or with regress
imprisonment, but is punishable with a simple
imprisonment, so in these circumstances the
accused seeks his release on bail.
7. That the investigation of the case is complete as
the accused has been lodged in Central jail and
there is no need to keep the accused in custody
as the accused has every right to prepare his
defense.
8. That the accused will not hamper with the
investigating agency nor will temper with the
prosecution witnesses if any, in case the accused
is released on bail.
9. That the accused shall fulfill all the conditions
whatsoever be imposed upon him by this honorable
court in the event of his release on bail.
10. That more grounds will be agitated at the time of
arguments.

In the premises, it is therefore prayed that

the application be allowed and accused be
enlarged on bail to secure the ends of
justice.

Date: 29-10-2011
Application
Through brother of accused

Namely Mohammad Ashraf Ganie

S/O Ab Aziz Ganie
R/O Peth Qazigund