"It will be heard tomorrow," said his lawyer Kushal Mor.
The application contends that CBI has found no evidence to justify his arrest, though it had his custody for 11 days and even subjected him psycho-analysis and polygraph tests.
CBI itself later applied for his transfer to judicial custody (where he is now), which shows that it completed the investigation and would not require further custody, it says.
Prior to the arrest, Mr Mukerjea had attended the office of investigation officers duly on various occasions and his statement too had been recorded, says the application. The grounds for arrest given by CBI are inconsistent and ambivalent and the entire approach of CBI appears "confused", it says and alleges that the central agency was trying to concoct a motive for Peter so as to implicate him for conspiracy.
Mr Mukerjea's wife Indrani, her former husband Sanjeev Khanna and her former driver Shyam Rai are accused of murdering Indrani's daughter from another marriage Sheena Bora in April 2012. Peter was arrested for being a party to the conspiracy.
The application further says that CBI adopted Mumbai police's earlier investigation but didn't negate the latter's "clean chit" to Mr Mukerjea. Police had said that Peter had no role in the crime and Indrani had kept him in the dark.
"CBI adopting the investigation of Mumbai police in toto and then arraigning Peter as an accused clearly amounts to contradiction of its own stand," it says.
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