IN THE
Muhammad Bilal son
of Muhammad Bashir, Caste Dindar,
R/o Qabrastan Road, Mohala Mirza Colony, Shaheen Abad, Gujaranwala.
Petitioner
1.
The State
2.
Milak Zulfiqar Ali son of Muhammad Nazir,
Caste Malik, R/o Mohala Mujahid
Pura, 91/C Block , Shaheen Abad, Gujaranwala.
Respondents
* * *
Case FIR No. : 777/11
Dated :
Offence U/S : 406 PPC
Police Station : Dhullay, Gujaranwala.
PETITION UNDER SECTION 498 CR.P.C. FOR THE GRANT OF PRE-ARREST BAIL.
Respectfully Sheweth:-
1.
That an FIR No. 777/11
was lodged at Police Station, Dhullay, Gujranawala against
the petitioner. Facts briefly mentioned in the FIR are that Malik
Nadeem complainant lodged an FIR alleging that
accused Naveed had obtained his vehicle on rent and
agreed to pay rent installment but he violated the terms of the agreement and
misappropriated his amount. A case u/s 406 PPC was registered against the
accused / petitioner. Copy of the FIR is annexed herewith as Annexure A.
2.
That previously pre-arrest bail of the petitioner
has been rejected dated
3.
That the whole story narrated in FIR is false and
fabricated, therefore, the petitioner is
seeking pre-arrest bail on the
following amongst other;
a)
That the present petitioner is
innocent and law-abiding citizen and whole story narrated in FIR is false and
fabricated which is made out only to blackmail and pressurize the petitioner.
b)
That there is a vast and unexplained,
inordinate delay of lodging the FIR which shows the malafide of the
complainant.
c)
That the petitioner is totally innocent
having no nexus with the alleged story. The prosecution story is after thought,
concocted one, self made with consultation to implicate the petitioner in this
false case, even otherwise no occurrence as alleged in the FIR is ever taken
place.
d)
That the local police under the influence of the
complainant lodged the FIR with malafide intention and with ulterior motives.
e)
That no prima-facie case is made out against the
petitioner.
f)
That petitioner is
previously non-convicted and all offence mentioned in FIR is not attracted.
g)
That the alleged offence against the petitioner does
not fall under the prohibitory clauses of section 497.Cr.P.C.
h)
That the petitioner being law-abiding citizen cannot
think to involve himself in such like offence.
i)
That present petitioner is
ready to join the investigation as and when required.
j)
That the present petitioner is
ready to furnish surety to the entire satisfaction of this Honourable Court.
k)
That there is imminent danger of the arrest of the
present petitioner only to humiliate them in society.
l)
That there is no chance of tempering with the
prosecution witnesses or abscondance of the petitioner.
m)
That petitioner craves to urge any other additional
ground at the relevant time.
It is therefore, most respectfully prayed that under
the facts and circumstances mentioned above that the petitioner may very kindly
be granted to bail till the final decision of this case.
It is further prayed that the petitioner may also be
admitted to ad-interim pre-arrest bail during the pendency of the instant
petition.
Petitioner
Through:-
Muhammad Nisar Malik
Advocate High Court
Session
Courts
C.C
No.
PLH-00000
Dated:
CERTIFICATE:
As per instructions, that this is first Bail Petition on the subject titled before this
Hon’ble court.
Counsel
IN
THE
Crl.
Petition
No. _________/2012
Muhammad Bilal Vs. The State etc.
(Pre-Arrest
Bail Application)
of Muhammad Bilal son of Muhammad Bashir,
Caste Dindar, R/o Qabrastan
Road, Mohala Mirza Colony, Shaheen Abad, Gujaranwala.
I, the above named deponent do hereby
solemnly affirm and declare as under: -
That
contents of the accompanying Bail Application
are true to the best of my knowledge and belief and be read as integral part of
this affidavit.
Verified on Oath at
Deponent
IN THE
Muhammad Bilal Vs. The State etc.
(Pre-Arrest Bail Application)
APPLICATION U/S 561-A Cr.PC FOR DISPENSATION OF UNCERTIFIED DOCUMENTS.
That the petition has filed the
accompanying bail petition without the
certified copies of certain annexure and undertakes to furnish the same as and
when made available.
It is therefore, respectfully prayed that
the production of certified copies of certain annexure may kindly be dispensed
with for the time being.
Through:-
Counsel
Dated:
IN THE
Muhammad Bilal Vs. The State etc.
(Pre-Arrest Bail Application)
APPLICATION
UNDER SECTIO 561-A Cr.P.C FOR GRANT OF INTERIM RELIEF
of Muhammad Bilal
son of Muhammad Bashir, Caste Dindar,
R/o Qabrastan Road, Mohala Mirza Colony, Shaheen Abad, Gujaranwala.
I, the above named deponent do hereby solemnly affirm and
declare as under:-
That contents of the accompanying Application
are true to the best of my knowledge and belief and be read as integral part of
this affidavit.
Deponent
VERIFICATION
Verified
on Oath at
Deponent
IN THE
Cr. Misc No.___________/B/2012
Muhammad Bilal Vs.
The State etc.
(PRE-ARREST BAIL.)
I
N D E X
|
Sr.# |
Description |
Annex |
Date |
Page # |
|
1.
|
Petition
and Affidavit |
|
|
01-05 |
|
2.
|
Copy
of FIR |
A |
|
06 |
|
3.
|
Copy
of Bail Petition before ASJ |
|
|
07-08 |
|
4.
|
Copy
ASJ Order |
B |
|
09-10 |
|
5.
|
Dispense
Application & Affidavit |
|
|
11-12 |
|
6.
|
Power
of Attorney |
|
|
|
PETITIONER
Through:-
Muhammad Nisar Malik
Advocate High Court
Session
Courts
C.C
No.
PLH-00000
Dated: