Contention of learned counsel for the applicant is that the applicant is innocent and has falsely been implicated in the instant matter due to ulterior motive. He further submits that the contraband substance, which is said to be recovered, is named as 'M.D., though there is no such Narcotics Drugs & Substance, as is defined/enlisted in the Narcotic Drugs and Psychotropic Substances Act of 1985. He further submits that the recovery memo is also prepared in a very causal manner and it has been stated that the drug received is "Smak ka baap hai" , which clearly shows the recklessness on the part of the police authority and the police has ignored the stringent provision as is envisaged in the Act, 1985 read with Rule 2024. He further added that though the sample has been sent to the Forensic Science Laboratory but no report has been received as yet and he added that the applicant has three cases criminal history which has been explained and he is languishing in jail since 17.07.2024 and he undertakes that he will not misuse the liberty of bail, if granted and would cooperate in the trial proceedings. Thus, submission is that the applicant may be enlarged on bail.