1. In the instant appeal, the appellant has assailed the judgment/order dated 27.12.2013, passed by court below, whereby the appellant has been convicted under Section 8/20 NDPS, Act and has been sentenced to undergo rigorous imprisonment for a period of 10 years and fine of Rs. 1.00 lac, in default of payment of fine, shall further undergo rigorous imprisonment for a period of one year.

2. The appellant through the medium of this Memo of appeal seeks indulgence of this Court for setting aside the impugned judgment of conviction and order of sentence inter alia on the following grounds:—

(1) That the very basis of the prosecution case i.e., the alleged information received by the Intelligence Officer, namely, Suresh Sharma and reduced into writing does not disclose the commission of any offence under law, which itself shows that the entire prosecution story against the appellant, is false.

(2) That none of the members of the alleged team constituted for the purpose of raid have been arrayed as witness nor the statement of any of such member has been recorded, which clearly amounts to the suppression of material facts and thereby reflects without any doubt that no such team was ever constituted nor any such raid was conducted and the appellant has been falsely implicated.

(3) That the none of the persons from whom the intelligence officer Suresh Kumar alleged to have been taken the seal (NCB seal) have ever been examined as witness, which could prove that said seal was kept in safe custody.

(4) That the prosecution even failed to prove the existence of the place of occurrence and no site plan or any other document of any kind whatsoever have been annexed along with the complaint which could even prove the existence of the alleged place of occurrence, even the intelligence officer in his statement has said that he did not know in jurisdiction of which police station the alleged occurrence has occurred, which clearly shows that the entire story of place of occurrence and recovery there from is false.

(5) That all the three witnesses, namely, Vipan Kumar, Naresh Kumar and Sanjay Kumar gave entirely different version of the place of occurrence and in the absence of proof of the alleged place of occurrence as narrated in the preceding para the conviction of the appellant is not warranted under law.

(6) That the complaint has been filled by the Intelligence Officer (I.O), NCB but in the complaint or even during the trial the complainant fails to prove his rank i.e., whether he hold the rank of Inspector or above and thereby whether he is an authorized officer to file such complaint.

(7) That no FSL form was prepared on spot, which is mandatory under law, which clearly shows that no recovery of contraband has been affected from the appellant. Non preparation of the FSL form on the spot cause serious prejudice to the appellant but said omission on the part of the prosecution has been undermined by the trial court.

(8) That fact of conducting a false investigation against the appellant and preparing false documents against him can be well evidenced from the fact that I.O in his examination in-chief states that the alleged inventory of the seized articles have been prepared by him and same is in his handwriting but when has been cross examined in respect of the same, he himself states that this not the original inventory prepared by him as the original was misplaced and he did not even remember that where the original inventory has been kept.

(9) That no contraband was ever recovered from the appellant and the alleged document of recovery-cum-seizure memo prepared against the appellant is a false document as the same is reflected from the fact that the said recovery-cum-seizure memo prepared against the appellant is a false document as the same is reflected from the fact that the said recovery-cum-seizure memo is alleged to be prepared on spot prior to the registration of the case no. i.e. NCB/J2U/Cr. No. 1/2012 but the said docu