BAIL APPLICATION UNDER SECTION 439 OF THE CODE OF CRIMINAL

PROCEDURE,1973.
In the High Court of _____________ at ____________
Criminal misc. __________ (M) _____________No.____ of 20___
In the matter of:
Petitioner/Accused______________
(Presently lodged in Central jail , Tihar.)
Vs.
Collector of Customs_______________
[Application u/s 439 (praying for releasing
Of the petitioner/accused on bail)]
To
The Honble Chief Justice and his companion justices of the said high
court____________.
The humble petition of the petitioner above named:
MOST RESPECTFULLY SHEWETH:
1) That the petitioner/ accused was apprehended by the customs officers of
____________ on ______ in connection with an alleged offence punishable u/s
135 of the customs Act, 1962 in connection with recovery of 20 gold biscuits
weighing _________ gms valued at Rs_______ and currency worth Rs_____ from
the luggage which doed not belong to the petitioner.
2) BRIEF FACTS OF THE CASE
3) That the petitioner/accused informed the officers he had no connection with
the seized goods, the petitioner was forced, induced and threatened to make
involuntary statement by the customs officers u/s 108 of the customs act,
1962.
4) That the petitioner/ accused is innocent and has not committed any offence
whatsoever.
5) That the petitioner/accused was produced in the court of learned session
judge on________ and bail application moved by him was rejected on ________
6) That the petitioner /accused is a respectable man of the society and he has
never come to the adverse notice of any law enforcing authority.
7) That the petitioner/accused is not a previous convict.
8) That the petitioner/accused is a permanent resident of _____________ living
with the family members and there is no chance of his absconding from trial.

9) That the investigation of the case qua the petitioner/accused is over and no
useful purpose would be served if the accused/petitioner is denied bail.
10)
That the bail application moved before the sessions court was
dismissed on _______
11)
That the petitioner/accused is ready to abide by any condition imposed
by this Honble court.
12)
That no similar bail application has been filed on behalf of the
petitioner/accused in this Honble Court or in any other High Court.
PRAYER
In view of the forgoing it is most respectfully prayed that:
A) The petitioner/accused may kindly be admitted to bail on such terms and
conditions as this honble court may deem fit and proper in the interest of
justice and/or;
B) Pass any further order or orders as this Honble court may deem fit and
proper in the interest of justice.
Prayed accordingly.
PETITIONER/ACCUSED
DATED:

through
COUNSEL
____________