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| Bail After Arrest format |
BEFORE
THE ILLAQA MAGISTRATE P.S GANJMANDI
Muhammad Zafran son of Muhammad Zaheer resident of Dhoke
Ratta,
Petitioner
Versus
The State
Respondent
PETITION
FOR BAIL AFTER ARREST U/S 497 CR.PC IN
CASE FIR NO. 420/21, DATED:
Respectfully Sheweth:
1.
That the allegations leveled against
the petitioner are false, frivolous, baseless, and concocted one.
2.
That the petitioner has been
falsely implicated in this case with malafides and ulterior motives.
3.
That nothing was recovered
from the possession of petitioner during the course of investigation.
4.
That there are glaring contradictions
between ocular and medical evidence.
5.
That the petitioner has been
sent to judicial lock up and no more required for further investigation.
6.
That there are grounds for
further inquiry into the guilt of petitioner which makes out the case to be one
of further inquiry under section 497 (2) Cr.PC.
7.
That the offences mentioned
in the FIR do not fall within the ambit of prohibitory clause of section 497
Cr.PC.
8.
That the Petitioner is
previously non-convict by any court of law.
9.
That
the petitioner is behind the bar since his arrest and the bail cannot be
withheld as punishment.
10.
That
further detention of petitioner would serve no judicious purpose rather it
would amount to punishment without trial.
11.
That the Petitioner is ready
to furnish sufficient surety for the satisfaction of this Honorable Court.
PRAYER:
Under the
above mentioned circumstances it is respectfully prayed that petitioner may
kindly be granted bail after bail till final disposal of the case.
Any other relief
which this Honourable court deems fit and proper may also be awarded.
Petitioner
Through
Mehmood
Sagheer
Advocate
High Court
CERTIFICATE
As per information received, it is
certified that this is the first petition for bail after arrest being
moved before this Honourable court on subject matter.
Counsel
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