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Petition Under Section 497 CR.P.C. For Grant of Bail - 420 - 468 - 471

This document is a bail application filed in an anti-corruption court in Lahore, Pakistan. The petitioner is seeking pre-arrest bail and claims to only be a marginal witness in a case related to the revocation of a power of attorney. The petitioner argues the delay in filing the FIR and denies any wrongdoing or profit from the matter.

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Umair Zia
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177 views7 pages

Petition Under Section 497 CR.P.C. For Grant of Bail - 420 - 468 - 471

This document is a bail application filed in an anti-corruption court in Lahore, Pakistan. The petitioner is seeking pre-arrest bail and claims to only be a marginal witness in a case related to the revocation of a power of attorney. The petitioner argues the delay in filing the FIR and denies any wrongdoing or profit from the matter.

Uploaded by

Umair Zia
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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IN THE COURT OF SPECIAL JUDGE ANTI CORRUPTION

COURT, LAHORE.

B.A. No. ____________ / 20

Name , S/o, D/o Father Name , resident of


_____________________.
….Petitioner

VERSUS

The State
….Respondent

FIR No. : 1145/07 dated 22.09.07


Offence : U/s 420/468/471 PPC
Police Station : North Cantt, Lahore.

APPLICATION UNDER SECTION 498 Cr.P.C.


FOR THE GRANT OF PRE-ARREST BAIL.

Respectfully Sheweth:

1. That the above titled case was registered on the

statement of Raja Muhammad Hayat at the above said

police station and petitioner was granted ad-interim

pre-arrest relief by Mr. Ch. Badar-ud-Din, learned

Additional Sessions Judge, Lahore, and during the


2

course of arguments it was pointed out that

revocation deed was registered in the office of Sub

Registrar through local commission i.e. Mr. Noor

Muhammad, Advocate, and it was observed by the

learned Additional Sessions Judge, that as the local

commission has performed his duty by endorsing his

report on the revocation of power of attorney, thus

he has performed his duty as public servant and

accordingly the ordinary court had no jurisdiction to

decide the matter and it relates to the present court

and petitioner has withdraw the petition from the

above said court today, hence instant petition this

Honourable Court. Co-accused Tariq Hussain etc. have

already been admitted to ad-interim pre-arrest bail

by this Honourable Court till 17.01.2008.

2. That the alleged occurrence took place on 21.04.2007

whereas the FIR was lodged on 22.09.2007 just after

the delay of five months and no reasonable and

plausible explanation whatsoever about the said

delay has given in the FIR and the said delay is

sufficient to concoct the story and to involve the

innocent persons in the false case.


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3. That petitioner is only the marginal witness of the

revocation deed and has not derived any financial

profit and even otherwise has not cause any loss

either to the complainant or some body else. It is

admitted fact that the revocation deed was signed

and thumb marked by Ch. Barkat Ali and petitioner is

the witness to this extent and it is pertinent to

mention here that at the time of execution of

revocation deed Ch. Barkat Ali was fully conscious

and the story narrated by the complainant about his

unconsciousness is false, frivolous and concocted

one.

4. That the complainant has involved the petitioner in

the instant case with malafide intention and ulterior

motives with the connivance of the local police just

to compel the petitioner to support their version

otherwise petitioner has no connection whatsoever

about the commission of said offence.

5. That section 420 and 471 are quite bailable, whereas

section 468 does not attract in the instant case and

also does not fall under the prohibitory clause of

section 497(1) rather it falls, keeping in view the

above said submissions and other grounds available,


4

case of the petitioner fall under section 497(2) Cr.P.C.

needs further inquiry into the guilt of the petitioner

and as such petitioner are entitled to be released on

pre-arrest bail.

6. That there is no apprehension of his abscondance or

tampering with the prosecution witnesses, petitioner

has already join the investigation and or yet to join

the investigation as and when required by the

investigating officer and also undertake to appear

before this Honourable Court on each and every date

of hearing.

7. That the petitioner is ready to furnish the surety

bond for the entire satisfaction of this Honourable

Court, if he is admitted to bail.

Under the above circumstances, it is

humbly prayed that the above named petitioner

may kindly be granted pre-arrest bail till the

decision of the trial.

Ad-interim pre-arrest bail may also be

prayed for.
5

Petitioner

Through

Dated:

Advocate

CERTIFICATE

As per information by the petitioners this is


the first bail petition on the subject in this
court.

Advocate
6

IN THE COURT OF SPECIAL JUDGE ANTI CORRUPTION


COURT, LAHORE.

B.A. No. ____________ / 20

In re:
VS The State

FIR No. : 1145/07 dated 22.09.07


Offence : U/s 420/468/471 PPC
Police Station : North Cantt, Lahore.

APPLICATION UNDER SECTION 498 Cr.P.C.


FOR THE GRANT OF PRE-ARREST BAIL.

AFFIDAVIT OF

I the above named deponent do hereby solemnly affirm and declare


as under:
That the contents of accompanying bail application are true and
correct to the best of my knowledge and belief and nothing has
been concealed therein.

Deponent
VERIFICATION

Verified on oath at Lahore this 9 th day of January 20 , that


the contents of the above affidavit are true and correct to
the best of my knowledge and belief and nothing has been
concealed therein.

Deponent
7

IN THE COURT OF SPECIAL JUDGE ANTI CORRUPTION


COURT, LAHORE.

B.A. No. ____________ / 20

In re:
VS The State

INDEX

Sr. No. Description of Documents Date Page

1. Bail Petition 09.01.08 1-5

2. Affidavit 09.01.08 6

3. Copy of F.I.R. 22.09.07 7

4. Power of Attorney

Petitioner

Through

Dated:

Advocate

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