Pre Arrest Bail Petition

IN THE COURT OF SESSIONS JUDGE, LAHORE.

 

 

 

 

B.A. No.___________/2024

 

ABC S/O XYZ R/O  Lahore.

…Petitioner

VERSUS

         The State.

…Respondent

 

Case FIR No.    000/2024                   Dated: 16.01.2024

Offence U/S:    462-I PPC

Police Station: ZZZ.

District:            Lahore.

 

PETITION UNDER SECTION 498 Cr.P.C. FOR THE GRANT OF PRE-ARREST BAIL TO THE PETITIONER.

Respectfully Sheweth:-

  1. That the above said false, frivolous, baseless and concocted case FIR was got registered by the complainant against the petitioner with malafide intention and ulterior motives. For detail prosecution story, copy of FIR is attached herewith as Annexure-A.
  2. That the petitioner seeks his pre-arrest bail from this Hon'ble Court inter alia on the following amongst other:-

 

GROUNDS

    1. That the petitioner are quite innocent and the above titled case has been registered by the complainant with malafide intention and just to achieve ulterior motives with the active connivance of local police.
    2. That the alleged offence do not fall within ambit of prohibitory clause of section 497 Cr.P.C and in such like cases “grant of bail is a rule and refusal is an exception”.
    3. That the local police is bent upon to arrest the petitioner and there is every apprehension of his arrest and if the petitioner is arrested in this case, he will be humiliated in the eyes of society as well as family.
    4. That the petitioner has no nexus with the alleged crime and even he cannot think to commit such like offence.
    5. That from whatsoever angle it can be seen and adjudged that the case of the petitioners is one of further inquiry into his guilt and he is liable to be admitted to pre-arrest bail till final conclusion of the trial.
    6. That the petitioner are previously non-convicted and non-record holder and he is ready to join the investigation.
    7. That there is no apprehension of petitioner’s absconding or tampering with the prosecution evidence.
    8. That the petitioner is ready to furnish reasonable surety bond to the entire satisfaction of this Hon’ble Court.

 

PRAYER:-

       In view of the above submissions, it is, therefore, most respectfully prayed that the instant bail petition may kindly be accepted and the petitioner may very kindly be allowed pre-arrest bail till the final decision of the above said case and thereafter the same may kindly be confirmed.

        It is further prayed that ad-interim pre-arrest bail may also be granted to the petitioner.

Petitioner

Through

CH. MUHAMMAD SAEED ZAFAR

Advocate High Court

 

RANA AYYUB KHAWER

Advocate High Court

 

MUHAMMAD AHMED RAZA

Advocate High Court

Dated: 20.01.2024

CERTIFICATE:-

As per instructions of my clients this is 1st Pre-Arrest Bail Petition on the subject matter before this Hon'ble Court.

ADVOCATE

IN THE COURT OF SESSIONS JUDGE, LAHORE.

 

 

 

 

 

 

B.A. No.___________/2024

ABC

Versus

The State

(PETITION UNDER SECTION 498 Cr.P.C. FOR THE GRANT OF PRE-ARREST BAIL TO THE PETITIONER)

 

AFFIDAVIT OF:   ABC S/O XYZ R/O Mohallah Gohawa Bedian Road, Lahore Cantt, District Lahore.

                               

I, the above named deponent do hereby solemnly affirm and declare as under: -

That the contents of accompanying petition are true and correct to the best of my knowledge and belief and nothing has been concealed therein.

 

DEPONENT

VERIFICATION:-

Verified on Oath at Lahore on 20.01.2024 that the contents of above said affidavit are true and correct to the best of knowledge and nothing has been concealed therein.

 

DEPONENT

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