I. The Government of India ('GoI') under the powers conferred on it under the Disaster Management Act of 2005 ('DM Act') issued Order on 24 March 2020 declaring a nationwide lockdown to contain the spread of a pandemic caused by COVID-19 (novel coronavirus) till 14 April 2020.1It was also announced that with effect from 25 March 2020, all modes of travel by air, train, bus and other means of public transportation stand suspended across all States in India; only persons involved in essential services were permitted to undertake necessary travel. Given the immediate suspension of all modes of transport millions of migrant workers and daily wagers were left stranded in the cities/towns across India with no means of daily subsistence, food or shelter to sustain them during the period of lockdown. In such a milieu, Prem Kumar, Dinesh Shankar, and Shashank Yadav all migrants working in a textile mill in Navi Mumbai decide to journey back to their hometown in Dharbhanga (Bihar) by walk after spending a week locked in a shelter home in Sion (Mumbai) without adequate food and water. On 28 March 2020, three of them begin their journey home which would take approximately 15-20 days after factoring all the halts they would have to take at villages/towns along the road. On 10 April 2020 when they halted in some fields along side a bypass road near Varanasi that would have taken them to their home State of Bihar, they were apprehended by a patrol party of Uttar Pradesh police. After a brief altercation with the police who thrashed them for loitering in the nearby fields which are private properties, all of them were committed to police custody for undertaking inter-State travel despite the announcement of lockdown, and for engaging in negligent act likely to spread infection. After obtaining permission from officer-in- charge of the local police station, a FIR was registered on 11 April 2020 under sections 188, 269, and 270 of IPC read with Section 3 of the Epidemic Diseases Act of 1897. A citizen journalist gets a whiff of this incident the next day and immediately reports it to a local NGO-Saathi.The NGO requests you to represent and seek bail for all three (3) migrant labourers. Draft a bail application for any one of the arrested migrants and file it before the concerned Court at the earliest.