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Bail Tenali 1

The document is a bail application filed by Dharavath Sathish Kumar Naik, who was arrested on 18-02-2025 under the NDPS Act for allegedly possessing methamphetamine. The petitioner claims innocence, argues that the case is fabricated, and requests bail on various grounds including lack of evidence and procedural violations. The application highlights that the petitioner has been in custody for over 50 days and has a fixed residence in Guntur.

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Suresh Kumar
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22 views7 pages

Bail Tenali 1

The document is a bail application filed by Dharavath Sathish Kumar Naik, who was arrested on 18-02-2025 under the NDPS Act for allegedly possessing methamphetamine. The petitioner claims innocence, argues that the case is fabricated, and requests bail on various grounds including lack of evidence and procedural violations. The application highlights that the petitioner has been in custody for over 50 days and has a fixed residence in Guntur.

Uploaded by

Suresh Kumar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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IN THE HON,BLE COURT OF THE SPECIAL JUDGE CONSTITUTED

UNDER NARCOTIC DRUGS AND PSYCHOTROPIC SUBSTANCES ACT-


CUM-IST ADDLTONAL SESSIONS JUDGE :: GUNTUR

CRL.M.P. NO. /2025


IN
CR.NO. 25/2025
(Of Prohibition & Excise Station, Guntur-Ii)
Betwwen:
DHARAVATH SATHISH KUMAR NAIK,
S/O. BALAJI NAIK
AGE. 28 YEARS,
DR-NO-20-20-11,
CHINNARAVURU, TENALI TOWN,
GUNTUR DISTRICT. ----PETITIONER/ACCUSED
AND
THE PROH.& EXCISE SHO
PROH & EXCISE STATION
GUNTUR-II ---RESPONDENT/COMPALINANT
PETITION FILED ON BEHALF OF PETITIONER/ACCUSED
U/S.437& 439 OF CR.P.C AND BNSS ACT

Date of offence : 18-02-2025


Date of arrest : 18-02-2025
Date of remand : 18-02-2025
Nature of offence : U/S 8 © R/W 21 © and 20 (b) (II) (A)
of NDPS ACT 1985
Territorial jurisdiction : learned Hon,ble special judicial
first Class magistrate for Proh &
excise :: Guntur.
It is humbly submitted that the respondent police arrested the
Petitioner/ accused on 18-02-2025 and produced them before
special judicial first Class magistrate for Proh & Excise : Guntur. On
the same day for the alleged offence punishable U/s U/S 8 R/W 21
© and 20 (b) (II) (A) of NDPS ACT 1985 of Proh & Excise station
Guntur-II. The learned magistrate sent them to judicial custody and
the petitioner/accused is languishing in district -jail, Guntur.

It is further submit that as per the version of the prosecution is


that on 18-02-2025 the respondent police secured reliable
information regarding to intoxicants are being sold and secured the
mediators and served notice U/S 103 BNSS act mediators and
secured the mediators them about the information of psychotropic
substances and need to conduct the search immediately I and my
staff along with vehicle no. AP 39 TA 9640 and reached met site
located at right side of venkatewara swami temple Brundavan
gardens Guntur town at about 12-30 pm Proh & Excise inspector
obrased that two male persons standing with two where and on
seeing us in uniform they tried to escape from the scene of offence
on suspicious I stopped them within active assistance my staff then
I ascertained the identity particular of them shown in above as A4
and A5 for searching of said two persons P&E issued notice U/s
50(1) NDPS act to second person by name Dharavath satish kumar
And searched him and found one plastic zip lock packets in his front
right side pant pocket containing white color powder. Then the P&E
asked the person about the powder which was in his possession, he
disclosed that the powder is “Meth (Methamphetamine) drug. The
P&E marked the packet as number (4) and weighing the packet and
noticed that the No.4 packet containing 1.26 Grams of (Meth)
“Methamphetamine” drug. All are false, fabricated and concocted
for the purpose of this case.

Hence this application is being is being filed for grant of bail to


the Petitioner/accused No-2 foe the following among other grounds
that may be urged at the time of hearing. And the ACCUSED NO-6
AND 9 ARE GRANT THE BAIL ON 27-03-2025, IN HON’BLE
HIGH COURT AMARAVATHI, GUNTUR.

GROUNDS
1. The petitioner/accused are innocents and they did not commit
any offence whatsoever.
2. The aforesaid F.I.R is entirely based on inadmissible confession
of the other petitioner/ accused and the case was fabricated
against the petitioner/accused for statistical purpose.
3. It is submitted that absolutely that the ingredients of N.D.P.S
Act not all made out in instant case.
4. It is further submitted that the case was registered against the
petitioner/accused fabricated the case and were taken into
custody by the ProH & Excise Guntur-II on 18-02-2025 and
the respondent police taken into police custody to the
accused on 25-03-2025 to 29-03-2025. the police
custody also complet.
5. The due procedure of search was not followed in this case and
the case is not at all maintainable against the
petitioner/accused.
6. The seizure was creating the respondent police for statistical
purpose nothing was seized from the possession of the
petitioners at any point of time.
7. It is submitted that the petitioner/accused are law abiding
citizens and the respondent police falsely implicated in this
case.
8. The petitioner/accused is a student and he is complete B. tech
recently and he was doing some private job in Guntur and
they are no way connected the alleged offence. The
Respondent police foisted the false case in a fraudulent
manaer.
9. The investigation in this is almost completed and material
witnesses are examined and formal charge sheet yet to be
filed.
10. There are no tempering of prosecution witnesses doesn,t
arise at any point of time.
11. The petitioner/accused are languishing in Dist–jail, Guntur
since 18-02-2025 for the past 50 days.
12. It is submitted that the petitioner is having fixed place at
Tenali, Guntur dist.
13. The petitioner/accused is having sufficient sureties for
their future appearance to the satisfaction of this Hon’ble
court.
Therefore it is humbly prayed that the Hon’ble court may be
pleased to enlarge the petitioner/accused on bail in the above
case pending disposal of the case and to pass such other
necessary orders in the interest of the justice.
Be pleased to consider
Place; Guntur
Date: 03-04-2025 Advocate for
petitioner/accused
N.B: it is humbly submitted that it is second bail
application except this, there is no similar petition filed or pending
before any court.

Advocate for
petitioner/accused

VERIFICATION
I, Dharavath Balaji, S/o Lakshmiram hindu aged about 54
years resident of Dr-no-20-20-11/1, near water tank, Chinaravuru,
VTC, Tenali, Guntur dist. No other than father of petitioner/accused
do hereby verify that I am duly authorized by the accused to
appoint Sri T. Prabhakararao, P.Naresh Kuamr, Advocates Guntur to
appear and argue on their behalf and that no other person has
been authorized to appoint any other advocate. No similar
application is filed and pending before any other court.

Signature of the interested person

Verified in my presence

Advocate
P.N.K
FOR ACCUSED

IN THE HON,BLE COURT OF


THE SPECIAL JUDGE CONSTITUTED
UNDER NARCOTIC DRUGS AND
PSYCHOTROPIC SUBSTANCES ACT-
CUM-
IST ADDLTONAL SESSIONS JUDGE ::
GUNTUR

CRL.M.P. NO. /2025


IN
CR.NO. 25/2025
(Of Prohibition & Excise
Station, Guntur-II)

PETITION FILED ON BEHALF OF


PETITIONER/ACCUSED U/S.437&
439 OF CR.P.C AND BNSS ACT
FILED BY:
T. PRABHAKARA RAO
P. NARESH KUMAR
ADVOACTES
GUNTUR
NO. 8639193288‘

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