Manoj.docx

In, The court of special excise court, Gaya

Excise case no. 595/18 U/s 30(a) of Bihar Excise Act

State Vs. 1. Manoj Paswan s/o Suresh Paswan 2. Pungi Yadav s/o Dev Narayan Yadav------------Accused

Humble bail petition on behalf of petitioner aforesaid namely Manoj Paswan and Pungi Yadav

Most Respectfully showeth:1) That the petitioner is innocent and he has been falsely made an accused. 2) That earlier no anticipatory or regular bail petition on behalf of the petitioner has been filed before this court or before any highercourt. 3) That the prosecution story in short is that the police inspector Dayanand Prasad Yadav with police of excise got information that some people from two motor cycle have bought liquor .At 03: 35 on the Biharipur Pokar two moter bike coming from Bilashpur and after police personal

help they try to stop them one of them run with motor cycle while one is arrested with liquor on their bike. On motor cycle no.CG10EL/ 6090, chesis no. MD2DHDKZZTCLO3843 &engine no. DKGBT.L11425 a jute bag under which 2 cartoon Royak Stage 750ml 12 bottel on which batch no.119A/24-8-2018 made in Haryana and Royal Stage 375 ml 24 bottel batch no.-112A/21-8-2018 is shown on the bottels. Total 36 bottel of liquor is seized by police. 4) That after arrested and investigation accused namely Upender Kumar s/o Ramprasad Mahto said that the other person run from bike is Manoj Paswan and Pungi yadav coming with liquor. 5) That it is further alleged that the petitioner was arrested on 11/03/2019 and in custody till now.

6) That the petitioner is languishing in jail for no fault of his own. 7) That the petitioner is innocent and has committed no offences.

8) That the petitioner is ready to furnish bail bond of any reasonable amount.

It is therefore prayed that your honour may be pleased toenlarge the petition on bail.

And for this petitioner shall ever pray.