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| Bail Before Arrest application |
In the name of ALLAH, the most beneficent, the most
merciful
IN THE COURT OF SESSIONS JUDGE
RAWALPINDI
Zafran Khan son
of Muhammad Zaman resident of House No. 1, Street No. 5, Mohallah Shah Chan
Chiragh, Rawalpindi
Petitioner
Versus
The State
Respondent
PRE ARREST BAIL PETITION U/S 498
CR.PC, IN CASE FIR NO 577 DATED
Respectfully
Sheweth:
1.
That
the storey narrated in the FIR is false, frivolous, baseless and concocted.
2.
That
the petitioner is innocent and has not committed the offence mentioned in the
FIR.
3.
That
the petitioner has been involved in the instant FIR with malafide intentions
and ulterior motives.
4.
That
the offences mentioned in the FIR do not fall within the ambit of prohibitory
clause of section 497 Cr.PC.
5.
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.
6.
That
there is no apprehension of abscondance of the petitioner or to temper with the
prosecution evidence.
7.
That
the Petitioner is previously non-convict by any court of law.
8.
That
the petitioner would suffer an irreparable loss, if arrested by the police.
9.
That
the petitioner is ready to join the police investigation when and where
required by the police.
PRAYER
Under the circumstances, stated above, it is therefore humbly
prayed that the instant petition may kindly be accepted and the petitioner may
kindly be granted bail before arrest.
Ad interim bail is also prayed for.
Petitioner
Through
Mehmood Alam
Advocate High
Court
CERTIFICATE
As
per instructions received, it is certified that this is the first petition
for bail before arrest being moved before this Honourable Court.
Counsel
