IN THE LAHORE HIGH COURT LAHORE.
1. Mohammad Rasheed son of
Mohammad Ramzan Caste Arain
Resident of Fatah Wala Post Office Khuddian Khas tehsil
and district Qasoor.
2. Ijaz Hussain Abdul Rehman Reident of Abubakar Town Post Office Khuddian
Khas tehsil and district Qasoor.
(petitioners)
Vresus
The
………………………………….….………..State.
(Respondent)
FiR
No P.S
Offence
502
/09 Khuddian 324/148/149 P.P.C
BAIL
APPLICATION U / S 498
CR.P.C FOR THE GRANT OF
PRE ARREST BAIL.
MAY
IT PLEASE YOUR HONOUR:-
1.
That the accused
petitioners were involved in the above mention case due to the malafide
intention of the complainant as well as local police, otherwise the accused /
petitioner is quite innocent.
2.
That the above
mentioned case has been got Register against the
petitioner is false frivolous baseless and concocted, with malafide intentions
and ulterior motives of the complainant and police.
3.
That the
allegations leveled against the petitioner are totally false and petitioner has
no concern with the commission of the alleged offence.
4.
That the
complainant under ulterior motive and with malafide intention to harass and
black mail the petitioner, has got registered the above noted false case, no
such incident as alleged in the F I R (copy of F.I.R Annex as A & better
copy annex as A1 )had ever took place. Moreover, pre arrest bail of the
petitioners were dismissed by learned Additional Session Jude vide order
27-08-09.(copy of order dt 27-08-09Annex as B)
5.
That nothing
incrimination and substantial material available on record, connecting the
petitioners with the commission of the alleged offence in this way way the complainant of the case did high handedness and
tried to involve the petitioners in this false and frivolous case.
6.
That the
petitioners are respected law abiding citizen. The local police is bent upon to arrest the petitioners and they will suffer
irreparable loss to his respect and family honour.
7.
That there is no
apprehension of abscondance of the petitioners or to temper with the
prosecution evidence.
8.
That the petitioners are ready to submit bail
bonds to the entire satisfaction of this honourable court.
Prayer
It is therefore respectfully prayed that the
petitioners may very kindly be granted ad – interim pre arrest bail, till the
final disposal of this petition and oblige.
Petitioners
Through : -
Muhammad Jawad
Ahmad
Advocate High Court,
P.L.H 1511
IN THE LAHORE HIGH COURT LAHORE.
1. Mohammad Rasheed son of
Mohammad Ramzan Caste Arain
Resident of Fatah Wala Post Office Khuddian Khas tehsil
and district Qasoor.
2. Ijaz Hussain Abdul Rehman Reident of Abubakar Town Post Office Khuddian
Khas tehsil and district Qasoor.
(petitioners)
Vresus
The
…………………………………………….….………..State.
(Respondant)
FiR
No P.S
Offence
502
/09 Khuddian 324/148/149 P.P.C
BAIL
APPLICATION U / S 498 CR.P.C FOR THE GRANT OF PRE ARREST BAIL.
MAY
IT PLEASE YOUR HONOUR:-
Affidavite of Mohammad Rasheed son of Mohammad Ramzan
Caste Arain Resident of Fatah Wala
Post Office Khuddian Khas tehsil and district Qasoor,do
hereby solemnly declare and affirm as under:-
1
That the accused petitioners were involved
in the above mention case due to the malafide intention of the complainant as
well as local police, otherwise the accused / petitioner is quite innocent.
2
That the above mentioned case has been got
Registered against the petitioners is false frivolous baseless and concocted,
with malafide intentions and ulterior motives of the complainant and
police.
3
That the allegations leveled against the
petitioners
are totally false and petitioner has no concern with
the commission of
the alleged offence .
4
That the complainant under ulterior motive
and with
Malafide
intention to harass and black mail the
Petitioners, has got registered the above noted false
case, no such incident as alleged in the F I R had ever
took place.
5
That nothing incrimination and substantial
material
Available
on record, connecting the petitioner with
the commission of the alleged offence .
6
That the petitioner is respected law abiding
citizen.
The local police is bent upon to arrest the
petitioners
and they will suffer irreparable loss to his respect
and
family honour.
7
That there is no apprehension of
abscondance of the
petitioners or to temper with the prosecution
evidence
8
That the petitioners are ready to submit
bail bonds
to the entire satisfaction of this honourable court.
Deponent
Vereification : -
Verified on oath at Lahore On 09-10-09 that the contents of the said petition are correct to the best of my
knowledge and belief .
Deponent