Draft Specimen Template Protective Bail

byAdvocate Ikyan Shah •
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Draft Specimen Template Protective Bail

Draft Specimen Template Protective Bail

BEFORE THE HONORABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO: PL/LHC/XX-XX-2018/B/001


MR. AHMED ALI, SON OF MOHAMMAD ALI, CASTE KHAN, RESIDENT OF 567, DEFENCE COLONY, PAKPATAN SHARIF.
………PETITIONER
VERSUS
1. The State
2. MR. USMAN KHAN, SON OF ABDUL KHAN, CASTE KHAN, RESIDENT OF 789, GULBERG TOWN, PAKPATAN SHARIF.
………RESPONDENT


Case FIR No. 616/17
Dated: 13.08.2017
Offence U/S 324/353 186/224, 225/148 149 PPC1 3/20/65A.O.
Cross Version under section 302/395 PPC
P.S. Sadar Pakpatan
District Pakpatan Sharif


PETITION FOR PRE-ARREST/PROTECTIVE BAIL U/S 498 Cr. P. C.


Respectfully Sheweth:

1. That the petitioner seeks protective pre-arrest bail in the cross version of the Criminal Case registered vide FIR No. 616 of 2017 at Police Station Sadar Pakpatan, District Pakpatan. Copies of FIR and cross-version are Annex-A & B.

2. That the petitioner is absolutely innocent and has been involved with malafide intention just to blackmail, harass, and create inconvenience, and the petitioner seeks protective pre-arrest bail on the following amongst other grounds:

GROUNDS


  1. That the petitioner is absolutely innocent and he has been involved by the mother of the deceased in the cross version with malafide and ulterior motive otherwise the petitioner has no concern with the alleged offence.
  2. That the deceased were required by the police in a case of decoity and they were hardened and desperate criminals, when the police party readied to arrest them they made straight firing at the police party and the police acted in their self-defence. In this regard, FIR No. 616/2017 was lodged by Muhammad Atiq Butt, DSP Mian Chanoo.
  3. That the mother of the decoits who is being supported by the political figures of the area has lodged a cross-version against the petitioner and other police officials with malafide intention and ulterior motives with the object to blackmail and harass the petitioner.
  4. That no independent person from the locality has supported the false version alleged in the cross version and even otherwise the alleged cross version is absolutely false, fabricated, afterthought, and not plausible.
  5. That the allegation against the petitioner is absolutely false and fabricated and the same is without substance.
  6. That the petitioner is a respectable and law-abiding citizen and he has nothing to do with the alleged offence.
  7. That the petitioner is a government employee and is ready to furnish bail bonds to the satisfaction of this learned Court and assure to remain present on each and every date of hearing.
  8. That the police of District Pakpatan are bent upon arresting the petitioner and have surrounded the District Court of Pakpatan on the instruction of high officials as well as on political influence and pressure and the petitioner is unable to reach the Sessions Court to avail the remedy of pre-arrest bail hence the petitioner has preferred the instant petition to seek protective bail and to approach the learned Sessions Court Pakpatan Sharif for the appropriate relief.
  9. That the petitioner has apprehension of immediate arrest and if the petitioner is arrested by the police it will cause great humiliation to the petitioner.
  10. That there is no likelihood of absconding of the petitioner.
  11. That under the circumstances narrated above, the petitioner is entitled to the grant of protective bail.

PRAYER


Under the circumstances, it is respectfully prayed that this petition may kindly be accepted and the petitioner may kindly be allowed the protective bail so that he can file a petition for pre-arrest bail before the learned Sessions Court Pakpatan Sharif.

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


Certificate

Certified that as per instruction of the client, this is the 1st protective bail petition filed in the instant matter.

Advocate

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