Draft Specimen Template Post-Arrest Bail

byAdvocate Ikyan Shah •
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Draft Specimen Template Post-Arrest Bail

Draft Specimen Template Post-Arrest Bail

BEFORE THE HONORABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO: PL/LHC/XX-XX-2015/B/002


MR. HASSAN KHAN, SON OF FAISAL KHAN, CASTE KHAN, RESIDENT OF 789, GULBERG AVENUE, LAHORE.
Presently Confined at District Jail Lahore.
Petitioner
VERSUS
1. THE STATE
2. (COMPLAINANT) A.S.I. POLICE STATION CITY, (COMPLAINANT).
Respondents


F.I.R. No. : 387/2015
OFFENCE U/S : 9-C (CNSA)
DATED : 29.03.2015
POLICE STATION : City.
DISTRICT : LAHORE.

BAIL PETITION
UNDER SECTION 497 CR.P.C. FOR GRANT OF BAIL AFTER ARREST TO THE PETITIONER


Respectfully Sheweth:

1. Through the instant bail petition, the petitioner seeks bail after arrest in the case registered through F.I.R No 387/2015 dated 29.03.2015, under section 9-C CNSA at Police Station City, District Lahore.

2. That the FIR was registered on the application of the complainant/Respondent No.2/Ahmed Khan, wherein it has been alleged that upon raid charas weighing 1140 grams were recovered from the petitioner. A copy of F.I.R. along with a better copy is appended herewith for the kind perusal of this Honourable Court as Annex-A.

3. That the petitioner applied for Post Arrest Bail before Learned Sessions Judge, Ali Raza, however, the same was dismissed vide order dated 19.06.2015 passed by Learned Additional Sessions Judge, Fahad Ahmed. Copies of the Bail Petition & order of dismissal dated 19.06.2015 are Annex-B & C.

4. That the FIR is an outcome of a cock and bull story and the petitioner has nothing to do with the commission of the alleged offence.

5. That the petitioner has been involved falsely in the instant case, therefore, the petitioner humbly seeks the indulgence of this Honourable Court for the grant of post-arrest bail inter-alia on the following grounds:

GROUNDS

  1. That the instant F.I.R. is false and frivolous, having no truth therein.
  2. That the petitioner is totally innocent and has nothing to do with the commission of the alleged offence.
  3. That the case of the prosecution is based upon malafide.
  4. That as a matter of fact, nothing has been recovered from the petitioner; the alleged recovery is planted.
  5. That the instant case is a borderline case.
  6. That no private witnesses have been associated with the alleged recovery.
  7. That the petitioner has been behind bars for a considerable period i.e. about 3 months.
  8. That the petitioner is not required by the police for further investigation.
  9. That the petitioner has no criminal background.
  10. That if the petitioner is released on bail, there is no chance that the petitioner would tamper with prosecution witnesses.
  11. That there is no probability of absconding of the petitioner if he is released on bail.
  12. That in the aforementioned circumstances, the instant case appears to be one of further inquiry.
  13. That the petitioner is a law-abiding citizen of Pakistan and never thinks to take the law into his own hands.
  14. That there are reasonable grounds for believing that the petitioner has not committed any offence.
  15. That the petitioner is ready to provide a surety bond for the satisfaction of this learned court if the post-arrest bail is granted to the petitioner.
  16. That the petitioner humbly seeks to raise additional grounds at the time of the arguments.

PRAYER

In the aforementioned circumstances, it is humbly prayed that the petitioner may kindly be granted post-arrest bail.

PETITIONER
THROUGH
Ikyan Shah
Advocate High Court
Ikyan Law Associates
Green Acres Main Boulevard Lahore.


Certificate:

It is certified that upon instructions of the client, it is the 1st petition for bail after arrest filed before this Honourable Court in the matter in hand.

Advocate

Ikyan Shah (Advocate High Court)
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+92-302-6111222
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