BEFORE THE LAHORE HIGH COURT, RAWALPINDI BENCH

RAWALPINDI

Cr.Misc No._____________‘2014

Faizan S/o Muhammad Afzaal, caste Awan, resident of Mohra

Shah Wali Shah Tehsil Taxila, District Rawalpindi.
(Presently confined in District Jail Adiala Rawalpindi).

………….Petitioner
Versus
The State
………Respondent

CASE FIR NO.455 DATED 27.06.2014,

OFFENCE U/S 9-C CNSA, P.S. TAXILA.

PETITION FOR POST-ARREST BAIL U/S 497

CR.P.C.

Respectfully submitted:-

1- That petitioner has been falsely implicated in the

above-mentioned case and presently confined into District

Jail Adiala Rawalpindi.

2- That it has been alleged in the FIR that petitioner,

being suspicious, was searched and during this course,

contraband material i.e. Charas weighing 1165 grams was

allegedly recovered from his possession.

3- That the allegations leveled in the FIR against

petitioner are absolutely false, baseless, concocted and ill

founded and petitioner is quite innocent. The local police

fabricated the instant case against the petitioner with

malafide intention and ulterior motives.

4- That in fact, police raided upon residential house of

petitioner at late night on 27.06.2014 and outraged

modesty of females. The police also snatched the purse of

lying-in female containing a gold Kanta and cash amount

worth Rs.25,000/- and later on entangled petitioner in the

instant case. Malice of police is very much evident from

the fact that police showed arrest petitioner from Mohallah

whereas petitioner was apprehended from his residential

house. Even otherwise, police registered separate cases

against other family members of petitioner on the same

day by setting wider-net including petitioner’s aged father,

uncle and brothers.

5- That the petitioner is victim of malicious prosecution

having no concern whatsoever with the alleged offence.

Nothing was recovered from petitioner and alleged

recovery is planted one.

6- That alleged recovery is 1165 grams which is on the

border line of section 9-B/9-C of CNSA and apparently,

the case falls under the ambit of section 9-B/CNSA which

does not fall under the prohibitory clause of Cr.P.C.

7- That in circumstances, case against petitioner falls

under the ambit of further enquiry. That investigation into

the case is complete in all respects and person of

petitioner is no longer required for the purposes of further

investigation.

8- That petitioner belongs to respectable family, has the

blotless career and is also a previous non-convict.

Moreover, he is a minor and student as well having no

concern whatsoever with such like acts. Even otherwise,

petitioner falls under the ambit of Section 497 (I) Cr.P.C.

for the purpose of bail.

 9- That petitioner preferred his bail petition before the

Learned ASJ Taxila who dismissed the same without any

cogent and lawful reason.

10- That petitioner is ready to furnish adequate sureties

to the entire satisfaction of this Honourable Court.

It is therefore, respectfully prayed that

petitioner may kindly be admitted to post-

arrest bail till the final disposal of the case.

Petitioner

Through

SH. MUHAMMAD YAQUB

Advocate
Supreme Court of Pakistan
CC No.16462

CERTIFICATE:

This is the first bail petition on behalf of the

petitioner, before this Honourable Court.

Counsel
BEFORE THE LAHORE HIGH COURT, RAWALPINDI BENCH
RAWALPINDI

Cr.Misc No._____________‘2014

Faizan Versus The State

PETITION FOR POST-ARREST BAIL U/S 497 Cr.P.C.

I N D E X

Sr.No. Description of documents Page No. Annexure

1. Bail petition 1-4
2. Copy of FIR a/w better
copy.
3. Impugned order of ASJ
Taxila dismissing bail
petition
4. Copy of bail petition

5. Copy of birth certificate

6. Application for
dispensation

7. Vakalat Nama

…Petitioner
Through:-

SH. MUHAMMAD YAQUB

Advocate
Supreme Court of Pakistan
CC No.16462