PRE ARREST BAIL (IN PAKISTAN)

IN THE COURT OF LEARNED SESSIONS JUDGE, KASUR

In the matter of:

Tahir Hussain son of Aftab Hussain, resident of House No. 222-A, Mohallah Khadim Hussain Road, Tariq Abad, Rawalpindi Cantt.
                                                                                                                                    …Petitioner

                                                            VERSUS

 The State

. …Respondent




PETITION FOR PRE ARREST BAIL U/S 498 Cr.P.C IN CASE FIR NO.374 DATED 06-05-09, U/S 489-F PPC, REGISTERED AT P.S CIVIL LINES, DISTRICT KASUR

Respectfully Sheweth:-

1. That the above mentioned case has been registered against the petitioner under the above mentioned offence by the local police however the petitioner has not committed any offence whatsoever. (Copy of FIR is attached herewith)
2. That now, the petitioner seeks his pre arrest bail inter-alia on the following:-
                                               

                                                GROUNDS:-

a. That the petitioner has falsely been implicated in the above-mentioned case and actually the petitioner did not commit any offence whatsoever.
b. That the above mentioned case has been registered against the petitioner with malafide intention and ulterior motives.
c. That a compromise has been effected and the complainant of the instant case has forgiven the petitioner and is ready to furnish an affidavit and also is ready to record his statement before the court.
d. That it is a case of further inquiry and probe and it is yet to be seen at the trial stage that which of the version is to be correct.
e. That the petitioner is a first offender in the alleged occurrence. He is not a previous convict and having no criminal record. In the said circumstances of the instant case, the petitioner is entitled for the concession of bail.
f. That the petitioner is a victim of malicious prosecution and he has no concern whatsoever with the alleged offence.
a. That the bail cannot be withheld as punishment to the petitioner.
b. That the offence mentioned in the FIR does not fall within the ambit of Prohibitory Clause of Section 497 Cr.P.C.
c. That the local police is now out to arrest the petitioner and if the petitioner is arrested, he would suffer an irreparable loss to his mind, body and reputation.
d. That the petitioner belongs to a respectable family, previously non-convict and ready to furnish the bail bonds to the satisfaction of this Honourable Court.

It is, therefore, respectfully prayed that the bail petition may kindly be accepted and petitioner may kindly be granted pre arrest bail till the final disposal of the case.
Ad-interim bail may also prayed for.
                                                                                                           

           

Petitioner                                                                                         

Through Counsel

Falak Sher Bhatti

Advocate High Court