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    Bail 9-C Faizan HC

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    Kashif Abbas
    1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

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    Bail 9-C Faizan HC

    Uploaded by

    Kashif Abbas
    690 views5 pages
    1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

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    Bail 9-C faizan HC

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    1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

    Copyright:

    © All Rights Reserved
    Download as RTF, PDF, TXT or read online from Scribd
    Download as rtf, pdf, or txt
    690 views5 pages

    Bail 9-C Faizan HC

    Uploaded by

    Kashif Abbas
    1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

    Copyright:

    © All Rights Reserved
    Download as RTF, PDF, TXT or read online from Scribd
    Download as rtf, pdf, or txt
    of 5

    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

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