Furnishing the list of politicians who visited Lalu in his special ward of the Ranchi hospital, the agency told the Supreme Court that Lalu's conduct does not warrant him any relief.
It maintained that Lalu has also attempted to give a false impression that he has been sentenced to just 3.5 years in jail for the fodder scam cases whereas the truth is that his jail term is for 27.5 years when all his sentences are cumulatively counted.
In one of the cases of convictions where Lalu has been convicted for 7+7 years, CBI said, he has not served jail sentence even for a single day and has remained in hospital ever since his conviction and sentence was pronounced.
"During the period in which the petitioner remained in hospital, he is not only granted a special paying ward with all facilities but he is virtually conducting his political activities from there which would be clear from the visitors' register," said the affidavit by the CBI.
It added: "The petitioner who claimed to be so unwell that he cannot even remain in jail but has to remain hospitalised suddenly claimed to be fully fit physically and sought bail, inter alia, on the ground which is recorded and rejected by the Hon'ble High Court".
Questioning Lalu's motive, CBI said that the person, who wanted to get bail to lead his party in the upcoming Lok Sabha election, has now come before the highest court of the country to get the reprieve by citing medical conditions.
"Simultaneous raising of pleas for bail on medical grounds and bail to guide the party and to carry out all essential responsibilities as a party president in ensuing Lok Sabha election are mutually contradictory and manifests that in the garb of bail on medical ground, the Petitioner in essence want to pursue his political activities which is impermissible in law. Thus on this ground only the present petition is liable to be dismissed," said the affidavit.
It pointed out that the court must not lose sight of the fact that Lalu has been convicted for illegal acts when he was the chief minister of Bihar and any relief to him would set a bad precedent when he has served just 20 months of his 27.5 years' jail term.
"Considering the serious nature of the offence and the gravity of accusation alone no indulgence by this Hon'ble court in granting grant bail to the Petitioner is warranted," emphasised the agency.
The Supreme Court is set to hear the bail plea on Wednesday. Senior advocate Kapil Sibal appears for Lalu in the top court.