Bail Petition
Bail Petition
Bail Petition
"FIR was registered against the petitioner that charas wheighing 1140 grams
recovered from him upon raid. Bail petition was dismissed by Sessions Court.
Bail was filed before Honourable High Court on the grounds that he was
innocent, case was borderline case and the petitioner had no criminal
background."
BEFORE HONOURABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO:____________________________
👉P___, SON OF ____, CASTE _____, RESIDENT OF ____.
Presently Confined at District Jail _____.
…..Petitioner......
VERSUS
👉1. THE STATE
👉2. (COMPLAINANT) A.S.I. POLICE STATION CITY, (COMPLAINANT).
…..Respondents
F.I.R. No. : ________
OFFENCE U/S : 9-C (CNSA)
DATED : __________
POLICE STATION : City.
DISTRICT : ______
🔸B A I L P E T I T I O N
UNDER SECTION 497 CR.P.C. FOR GRANT OF BAIL AFTER ARREST TO THE
PETITIONER.
Respectfully Sheweth:
✍️1. That through the instant bail petition, the petitioner seeks bail after arrest in
case registered through F.I.R No _________ dated _______, under section 9-C CNSA
at Police Station City, District ____.
✍️2. That the FIR was registered on the application of the
complainant/Respondent No.2/___, wherein it has been alleged that upon raid
charas weighing 1140 grams was recovered from the petitioner. Copy of F.I.R
along with better copy is appended herewith for kind perusal of this Honourable
Court as Annex-A.
✍️3. That the petitioner applied for Post Arrest Bail before Learned Sessions
Judge, ___, however, same was dismissed vide order dated _________ passed by
Learned Additional Sessions Judge, ___. Copies of Bail Petition & order of
dismissal dated _____ are Annex-B & C.
✍️4. That the FIR is an outcome of cock and bull story and the petitioner has
nothing to do with the commission of alleged offence.
✍️5. That the petitioner has been involved falsely in the instant case, therefore,
the petitioner humbly seeks indulgence of this Honourable Court for grant of pre-
arrest bail iner-alia on the following grounds:
🔸G R O U N D S
✍️a. That the instant F.I.R is false and frivolous having no truth therein.
✍️b. That the petitioner is totally innocent and he has nothing to do with the
commission of alleged offence.
✍️c. That the case of the prosecution is based upon malafide.
✍️d. That as a matter of fact nothing has been recovered fro the petitioner, the
alleged recovery is planted one.
✍️e. That the instant case is borderline case.
✍️f. That no private witnesses have been associated with the alleged recovery.
✍️g. That the petitioner is behind the bar for a considerable period of time i.e.
about 3 months.
✍️h. That the petitioner is not required by the police for further investigation.
✍️i. That the petitioner has no criminal background.
✍️j. That if the petitioner is released on bail, there is no chance that the
petitioner would tamper with prosecution witness.
✍️k. That there is no probability of absconsion of the petitioner if he is released
on bail.
✍️l. That in aforementioned circumstances, the instant case appears to be one of
further inquiry.
✍️m. That the petitioner is law-abiding citizen of Pakistan and never thinks to
take law in his hand.
✍️n. That there are reasonable grounds for believing that the petitioner has not
committed any offence.
✍️o. That the petitioner is ready to provide surety bond for the satisfaction of this
learned court if the post-arrest bail is granted to the petitioner.
✍️p. That the petitioner humbly seeks to raise additional grounds at the time of
the arguments.
🔸P R A Y E R
In the aforementioned circumstances, it is humbly prayed that the petitioner may
kindly be granted post arrest bail.
PETITIONER
THROUGH
A.B.C
Advocate High Court
🔸Certificate:
It is certified that upon instructions of the client it is the 1st petition for bail
after arrest filed before this Honourable Court in the matter in hand.
Advocate
A.B.C.