PRE-ARREST BAIL:
Pre-Arrest bail was filed before High Court after Learned
Additional Sessions Judge dismissed bail before arrest of the petitioner.
BEFORE HONOURABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO:____________________________/B/2015
____, SON OF ____, CASTE ____, RESIDENT OF ____, DISTRICT____.
…..Petitioner
V E R S U S
1. THE STATE
2. ______, SON OF _____, CASTE ___, RESIENT OF ____,
DISTRICT____.
…..Respondents
F.I.R. No. : ___/2014
OFFENCE U/S : 406
P.P.C.
DATED : ____
POLICE STATION :
_____
DISTRICT : _____
B A I L P E T I T I
O N
UNDER SECTION 498 CR.P.C. FOR GRANT OF BAIL BEFORE ARREST TO
THE PETITIONER.
Respectfully Sheweth:
1. That through the instant bail petition, the petitioner
seeks bail before arrest in case registered through F.I.R No ___/2014 dated
_____, under section 406 Pakistan Penal Code at Police Station ____, District
___.
2. That succinctly stated facts giving rise to the filing of
bail petition in hand are that aforementioned FIR was registered on the
application of the complainant/Respondent No.2/____(name), wherein it has been
alleged that the petitioner was entrusted with some amount of the complainant
and he misappropriated the same; hence, the FIR was registered against the
petitioner. Copy of F.I.R No. ___/2014 dated ___ u/s 406 PPC is appended
herewith for kind perusal of this Honourable Court as Annex-A.
3. That the petitioner applied for Bail Before Arrest before
Learned Sessions Judge, __, however, same was dismissed vide order dated ___
passed by Learned Additional Sessions Judge, ____. Copies of Bail Petition
& order of dismissal dated _____ are Annex-B & C.
4. That the FIR is an outcome of cock and bull story and
local police is after the petitioner to arrest him, whereas, the petitioner has
nothing to do with the commission of alleged offence.
5. That the petitioner has been involved falsely in the
instant case, therefore, the petitioner humbly seeks indulgence of this Honourable
Court for grant of pre-arrest bail iner-alia on the following grounds:
G R O U N D S
a. That the instant F.I.R is false and frivolous having no
truth therein.
b. That the petitioner is totally innocent and he has
nothing to do with the commission of alleged offence.
c. That the case of the prosecution is based upon malafide.
d. That the real culprit is _____ with whom the complainant
has affected compromise and the petitioner is not responsible for any
misappropriation as no money was entrusted to him. (this ground depends upon
the circumstances of the case).
e. That there is an unexplained delay between registration
of FIR and commission of alleged offence.
f. That if the petitioner is released on bail, there is no
chance that the petitioner would tamper with prosecution witness.
g. That there is no probability of absconsion of the
petitioner if he is released on bail.
h. That in aforementioned circumstances, the instant case
appears to be one of further inquiry.
i. That the petitioner is law-abiding citizen of Pakistan
and never thinks to take law in his hand.
j. That there are reasonable grounds for believing that the
petitioner has not committed any offence.
k. That the petitioner is ready to provide surety bond for
the satisfaction of this learned court if the pre-arrest bail is granted to the
petitioner.
l. That the petitioner humbly seeks to raise additional
grounds at the time of the arguments.
P R A Y E R
In the aforementioned
circumstances, it is humbly prayed that the petitioner may kindly be granted
bail before arrest.
It is also humbly prayed that till disposal of titled bail
petition, interim bail may be granted to the petitioner.
PETITIONER
THROUGH
____________________
Advocate High Court
C.C. NO:P-LH____
#Basic_Pakistani_Laws_in_Urdu
66/3, HAJVERY COMPLEX, 2-MOZANG ROAD, LAHORE.
Certificate:
It is certified that
upon instructions of the client it is the 1st petition for bail before arrest
filed before this Honourable Court in the matter in hand.
Advocate
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