"The applicant (Pacheco) is sick. He is tense and is unable to bear the tension that he is in police custody," the bail plea said.
The petition by the NCP MLA, who was arrested by Crime Branch in connection with death of his female friend Nadia Tarrado, on July 8 would be heard by the court on Monday.
His lawyer Surendra Desai said the medical reports maintained by Hospicio hospital at Margao and Goa Medical College And Hospital in Panaji establish that he is really unwell and any further police custody would be detrimental to his health.
The bail petition also claimed that Pacheco was in no way connected with the incident.
"There is no direct, indirect or circumstantial evidence against him except that he happened to be a close friend of the deceased and her family for many years," the petition read.
Nadia died allegedly after consuming poison on May 30. Crime Branch investigating the case had booked Pacheco and his close aide Lyndon Monteiro as accused in the case.
"The investigating agency is making mountain out of mole hill for oblique, ulterior and extraneous reasons and the investigation is politically influenced," the petition said.
Pacheco was accused of having a hand in her suicide even as he helped the family financially in paying hospital bills amounting to Rs 40 lakh, the lawyer said in the application.
Meanwhile, NCP has taken strong exception to the way Pacheco has been dragged into the controversy and said the state government should ensure that investigation in the case is conducted impartially.
"While making it clear that NCP welcomes a thorough investigation on the charges levelled by police on Pacheco, the party requests the government to see to it that investigations are carried out in an impartial manner," NCP's Goa unit president Joseph Philip D'Souza said.
"The party takes strong exception to the way its MLA Pacheco has been dragged into the controversy over the suicidal death of Nadia. Investigations should not be dragged on and the MLA should not be unnecessarily kept in the custody," D'Souza said.