IN THE COURT OF LAHORE HIGH COURT LAHORE.
Shahid Junaid son of Sufi Junaid Caste Kashmiri resident Street no 11 Galla ghulam Muhammad Thaikay Daar Wala Bakhtay Wala Gujranwala.
1. Atif Alias Atee
2. The State
Case no: 36 / 08 Dt: 31-01-10.
police station: Sabzi Mandi Gujranwala.
May it please your honour,
1. That abridgely the facts giving rise in the instant petition are that the petitioner is a law abiding citizen of Pakistan and has a very good antecedents in his credit.
2. That on 31-01-10 the above said F.I.R. was lodged against the culprits who forcibly entered in the abode of the petitioner and injured his real brother Muhammd Saleem F.I.R. and its better copy is annexed with this petition as ANNEX-A & A.1.
3. That due to the firing of the accused /Respondents the brother of the petitioner Namely Muhammad Saleem seriously injured and he sustained 10 firearms from the hands of the accused persons/respondents.
4. That the above said F.I.R was lodged against the respondents and the respondent No 1 was also arrested in the above titled case and his bail after after arrest was dismissed by the learned session judge, and the respondent No 1 after that filed a bail petition before the Honourable Lahore High Court Lahore , which was entrusted to the Honourable Mr. Justice Syed Mazahir Ali Akbar Naqvi judge Lahoare high court Lahore and the Honourable court pleased to announced the order for the grant of bail to the accused / Respondent No 1 on 01-07-10. order of the Honourable Judge is annexed as ANNEX-B.
5. That after the bail of the accused/ Respondent No 1 from the jail he again began to threat the petitioner and his other family members and the petitioner seeks his cancellation of bail on the following grounds,
· That the respondent No 1 is a desperate and hardened criminal and remained involved in many criminal activities like dacoity etc. copy of fresh F.I.R. is annexed with this application as ANNEX- C.
· That the above said F.I.R lodged after the releas of the accused /respondent No 1 from the jail , which shows his criminal mentality.
· That the accused / respondent No 1 is also threatening the petitioner and his family members for the withdrawl of the above said main case.
· That the accused / respondent is also threatening the witnesses of the case , while the witnesses are also very much afraid towards the act of the respondent No 1 .
· That the accused / respondent No 1 is also not appearing in the learned trial court on each and every date of hearing so the learned court is unable to proceed further in this case until or unless the accused / respondent No 1 would not be declared proclaimed offender.
Under these circumstances its most humbly and respectfully prayed that due to the conduct of the accused / respondent No1 , the bail already granted to the accused may kindly be recalled in the interested of justice and fair trial of this case.