BEFORE THE HON’BLE COURT OF CHIEF JUDICIAL MAGISTRATE AT

BUDGAM

In the case of:

Shabir Ahmad Wani (age 30 years)
S/O Ali Mohammad Wani
R/O Wanpora Chadoora
Tehsil Chadoora
District: Budgam.
(Accused)
VERSUS
State through S.H.O P/S Chadoora

(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 and is residing at village Wanpora
Tehsil Chadoora District Budgam thus has every right to
invoke the jurisdiction of this hon’ble court in order to seek
redressal of her legal rights.
2. That the accused named above stand arrested by S.H.O P/S
Chadoora on 21st day of May 2011 and have involved him in a
false criminal case.
3. That the police Chadoora for no reasons has been harassing
the accused for no justifiable reasons and a false case has
been registered against the accused implicating him in a
concocted case.
4. That the police for no justifiable reasons are causing undue
harassment to the accused and his family members.
5. That this application is moved by the applicant Shamim
Ahmad Wani on behalf of accused above named who stand
arrested by police Chadoora and is presently lodged in police
station Chadoora for no fault of him.
 6. That due to continued detention in police lockup the entire
family members are frustrated.
7. That the continued detention and arrest of accused is the
gross violation of right of liberty as guaranteed under the
constitution.
8. That the accused will not hamper with the investigating
agency nor will temper with the prosecution witnesses.
9. That the accused will fulfill all the conditions whatsoever be
imposed upon her by this honorable court.
10. That more grounds will be agitated at the time of arguments.
11. That the accused has not committed any offence and her
detention in police lockup has put her family into a great
trouble.

In the premises, it is therefore prayed that the

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

Date: 24-05-2011
Applicant

Shamim Ahmad Wani

S/O Ali Mohammad Wani
R/O wanpora Chadoora