IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No._____________/B/2002

Bilal Ahmad S/o Muhammad Iqbal, caste Khokhar, R/o Kachi Sarai,
outside Daulat Gate, Multan.
……….Petitioner
VERSUS
The State. ……..Respondent

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

Case: -
F.I.R. No. 315/2001 Dated 13.10.2001
U/s: 392 P.P.C. converted into 395/412 P.P.C.
P.S. Qutab Pur, Multan.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That the instant F.I.R. was registered on the statement of one

Muhammad Sadiq, stating thereby that he is working as
Accountant with Akbar Brothers, B.C.G. Chowk, Multan. On the
night of occurrence, at 11:00 P.M., he, with his real brother,
Muhammad Javaid, while riding a Motorcycle No. 7949/MNW,
CD-70, model 1998, red in colour, going to their home. At 11:15
P.M., when they reached near the Farooq Pura Graveyard 4
unknown persons (complexion detailed) armed with “Khanjars”
intercepted them. The accused persons snatched motorcycle,
Registration Book and Rs. 1500/- from them and fled away.
 Accused persons can be identified by the complainant and his
brother. Copy of F.I.R. is annexed as Annex “A” and better copy
is Annex “A/1”.

3. That the petitioner applied for post arrest bail in the court of first
instance, but the same was refused vide order dated 2.1.2002. The
petition for the same relief was also turned down by the court of
learned A.S.J, Multan, vide order dated 14.2.2002. Copies of
orders are Annexes “B & C”.

4. That the petitioner is entitled for the concession of post arrest bail
inter alia on the following: -

GROUNDS

i) That the petitioner is not nominated in the F.I.R. and arrest

of petitioner is a case of high-handedness committed by the
police.

ii) That the petitioner was arrested on the statement of co-

accused while the co-accused were arrested on the
pointation of “Mukhbar”.

iii) That no identification parade was held for the

identification of petitioner.

iv) That the petitioner was arrested on 25.9.2001 and

remained on physical remand, but nothing was
recovered from the possession of petitioner.

v) That petitioner is innocent in this case and roped up

falsely in this.

vi) That the petitioner agitated the plea of muocence, which

was not properly investigated.

vii) That in these circumstances, no reasonable grounds

exist to connect the petitioner with the crime.
 viii) That it is a case of further inquiry in the present
situation, when there is no evidence against the
petitioner.

ix) That the investigation in the case is almost complete

and petitioner is no more required by the police.

x) That the petitioner is behind the bars since his arrest

and no useful purpose can be served with further
detention of petitioner.

xi) That the petitioner is neither previous convict and nor

having any record.

Keeping in view of the above-mentioned

submissions, it is respectfully prayed that the
petition in hand may kindly be accepted and post
arrest bail may please be allowed to the
petitioner.

Any other relief, order or direction which

this Hon’ble Court deems fit may please be
extended in favour of petitioner to meet the ends
of justice.

Humble Petitioner,
Dated: ___________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the clients,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble court.
Advocate
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. _____________/2002

In
Crl. Misc. No._____________/B/2002

Bilal Ahmad Vs The State

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth: -
That certified copies of Annexures “A, A/1 & C” are
not available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of the original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of the documents.
APPLICANT,

Dated: __________
(BILAL AHMAD)
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

Crl. Misc. No._____________/B/2002

Bilal Ahmad Vs The State

INDEX

S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Bail Petition.
3 Copy of F.I.R. & better copy. A & A/1
4 Copies of orders. B&C
5 Dispensation Application.
6 Vakalatnama

PETITIONER
Dated: ____________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176