Scribd
Upload
19 views3 pages

337-A bail Dadullah

bail application of Dadullah seeking justice filed of the same before the competent court which was allowed

Uploaded by

najeeb
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
19 views3 pages

337-A bail Dadullah

bail application of Dadullah seeking justice filed of the same before the competent court which was allowed

Uploaded by

najeeb
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 3

IN THE COURT OF JUDICIAL MAGISTRATE MFC

CHAMAN

1. Dadullah
2. Qudratullah
Both sons of Haji Dost Muhammad
By caste Achakzai / Salehzai
R/o Toor Pul Chaman
Presently confined in Sub-Jail Chaman
(Accused/Applicants)

VERSUS

The State
Respondent…

OFFENCE UNDER SECTION 337-A Q&D, 504, 506(ii), 34 PPC

APPLICATION UNDER SECTION 497 Cr.P.C FOR GRANT


OF BAIL

Respectfully submits as under:-

1. Brief facts leading to file of instant application are that an FIR

No.80/2024 has been lodged by one complainant against the accused

applicants with Police Station City Chaman under the above-mentioned

allegations. For perusal of facts copy of FIR is annexed as annexure-“A”.

Being highly aggrieved from registration of instant case/FIR, the

applicants/accused being behind the bar prefers to file instant application

on the following amongst other grounds:-

G R O U N D S:-

A) That the accused/applicants are innocent persons and they

did not commit any offence whatsoever alleged in the instant

FIR, the complainant party for harassment and blackmailing

registered the instant FIR against the present


applicants/accused, therefore, they are entitled to be released

on bail.

B) That no independent direct or indirect eye witness available

on record of prosecution to connect the accused/applicants

with the commission of certain allegations, it is just self-

concocted frivolous story having mala-fide intention and

false implication on part of complainant party, therefore, the

accused/applicants are entitled to be released on bail.

C) That the alleged section 337-A Q&D, is either bailable in

nature triable by this hon’ble court and same do not fall

within the ambit of prohibitory clause under section 497 (1)

Cr.P.C. On this score too they are entitled to be released on

bail.

D) That actually the brother of applicants/accused namely

Shamsullah has been beaten by the complainant party,

injured Shamsullah MLC is also annexed here for ready

reference and applicants/accused were deserved to lodge

FIR against the complainant party but here the complainant

who is accused lodged the false FIR against the

applicants/accused, on the sole ground, they are entitled to

be released on bail.

E) That the applicants/accused have been shifted to judicial

lockup and are no more require to I.O Police for further

probe, on this sole ground alone, they are entitled to be

released on bail.

F) That accused/applicants are permanent residents of Chaman

and they are ready to furnish solvent surety bonds to the


entire satisfaction of this Hon’able court if they are released

on bail.

G) That the counsel for accused/applicants reserves right of oral

arguments on each and every point of law at the time of

hearing the instant application available to him.

It is therefore, accordingly respectfully prayed that keeping in view of

the above mentioned submissions, the accused/applicants may kindly be

released on bail in the interest of justice and equity.

Dated: 26-10-2024
Accused/Applicants
Through Counsel

CERTIFICATE:

Certified that prior to filing the instant application, no other

application of the same matter has ever been moved/filed on behalf of

accused before this or Apex court of law, except the present one.

Date: 26-10-2024
Accused/Applicants
Through Counsel

You might also like