Asad Bail 9c

1
IN THE COURT OF ADDITIONAL SESSION JUDGE 1, QUETTA.
Bail Application No.___/2023
In the matter of:

Asadullah Son of Allah Nazar Caste Khilji, Resident of Arbab Town
Samangli Road Quetta, Presently confined at District Jail Quetta.
Applicant/Accused
Versus
The State
Respondent
OFFENCE UNDER SECTION 9(1) 3e, CNS ACT 1997 FIR NO,
21/2023 POLICE STATION PANJPAI, QUETTA.
APPLICATION UNDER SECTION 497 CR.P.C FOR GRANT OF

BAIL.
Respectfully sheweth:
1. That brief facts leading to file this instant Bail application are
that a case vides FIR No. 21/2023 was registered on 08-08-
2023 at P.S Panjpai, Quetta under above mentioned offences
on the complainant/Senior Inspector Saud ur Rehman lodged
an FIR, for Detail Perusal the copy of FIR is annexed herewith
as annexure “A”.
2. That it is pertinent to mention here prior to instant FIR the Wife

of accused/applicant filed an application under section 491
CRPC (Habeas corpus) with regard to illegal detention of her
husband by hands of law enforcing agencies before court of
law, wherein she contained that her husband was taken
into custody on 29-03-2023 at about 6 pm from Airport
Road Quetta, copy of application is marked as annexure B.
3. That after the filing petition before court of law in respect of

illegal detention of accused/applicant an FIR no. 21/2023 has
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been registered with police station Panjpai District Quetta,

offence under section 9 (1) 3(e) control of narcotics substance
act, 1997 against the accused/applicant by the officials of the
police station Panjpai with the allegation mentioned in said
FIR.
4. That the complainant in said matter very cunning, shrewd and

man of criminal mind and in order to drag the
applicant/accused into false, frivolous and fabricated case with
malafide intention and based on ulterior motive that the
applicant/accused law abiding citizen of Pakistan never ever
of involve in such kind of activities rendered by complainant
without any lawful justification and evidence.
5. That the complainant cooked up concocted story regarding

the commission of alleged incident which is based on
presumption assumption and same is amount of concealment
of ture fact or in order to safe their skin penal action, that as
stated above the applicant/accused was abducted the
hands of police official on dated 29-03-2023 at about 6
Pm, however registration of FIR after delay of 10 days
against the applicant/ accused with the allegation
mentioned in said FIR is based on ulterior motive.
6. That from the content of FIR shows police officials narrated

falsely and want to counter the version of Bibi Karima Wife of
the applicant/accused rendered before the court of law against
the police official and others, hence case of applicant/accused
covered further inquiry into matter.
7. That the application being innocent not committed any offence

with regard to transportation of narcotic whatsoever in nature,
as such malafide and ulterior motive on the part of the police
officials, complainant shown from the record hence preferring
the instant bail application on following amongst inter alia
other grounds.
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GROUNDS
A. That the accused/applicant was abducted by law enforcing

agencies on dated 29-03-2023 from airport road Quetta in
presence of his wife, due to which a petition was filed for
illegal detention of applicant/accused before court of law
against the authorities, but with ulterior motive and malafide
the police authorities has been implicated the
applicant/accused into false and fabricated case ,thus the
applicant/accused entitled to be released on bail.
B. That the police officials, complainant have violated the golden

principles of equity and the constitutional dictates, he also
illegally exercised his statutory obligation, neglected duties
invested in their office of virtue of their oath and constitution,
while lodging said FIR, hence the Accused is entitled for grant
of post arrest bail.
C. That the involvement of accused/applicant in the instant case

with malafide and ulterior motive on the part of police official,
complainant, while the accused/applicant as not committed
any offence whatsoever in nature and he falsely be involved in
the instant case and there is no prove or any evidence on the
face of record to corroborate the version of the complainant
however applicant/accused has no concerned or connection
with story of police official therefore, on this score too the
applicant is liable to be admitted to bail.
D. That it admittedly the instant case was registered against the

applicant/accused after the filling of (Habeas Corpus) petition
under section 491 Crpc, therefore police officials/complainant
wants to seeking nefarious design by the means of pretext
manner due to which false application of applicant/accused on
the face on record on this ground applicant/accused is
admitted to post arrest bail.
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E. That the there is no incriminating material to connect the

applicant/accused with the commission of alleged offence and
from the data available on the record there appears no
reasonable ground to believe that applicant/accused is
committed the offence as alleged rather there are sufficient
grounds warranting false implication of applicant/accused is
entitled to be admitted on post arrest bail.
F. That from data available on record and evidence collected no

prove with regard to criminal act has been brought on the file.
It is well settled law that no person can prosecuted by leveling
allegation of heinous, sensational or gruesome offence on the
part of police authorities, rather there should be some material
on record to connect the accused/applicant with the
commission of offence, hence therefore applicant is entitled to
be admitted on post arrest bail.
G. That there are various other irregularities and illegalities

committed by the police officials while lodging the said FIR,
hence the applicant deserves to be admitted to bail.
H. That the involvement of the accused/applicant is solely on the

basis of male fide intention, on for harassing, humiliating and
mentally torturing the accused/applicant, have no concern or
connection with the alleged offences therefore the
accused/applicant is entitled to be admitted on post arrest
bail.
I. That the applicant is ready to prepare and furnish solvent

surety to the entire satisfaction of this Hon’ble court if granted
bail.
J. That the counsel for applicant will add some more

grounds at the time of arguments of this bail application
with kind permission of this Hon’ble court.
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PRAYER
It is, therefore, respectfully prayed that the applicant/accused
may kindly be admitted to bail to such terms and conditions
which may deem fit and appropriate in the circumstances, in the
interest of justice, equity, and fair play.
DATED: -06-2023. Applicant/Accused

Through
Naveed Qambrani Advocate
Supreme Court.
CERTIFICATE.
It is certified that previously no bail application in the same FIR has

been filed before this Hon’ble Court.
Applicant/Accused
Through
Naveed Qambrani Advocate
Supreme Court.
 Relied upon all documents Annexure.

 Habeas Corpus petition under section 491 Crpc .
 Affidavit filed by wife of accused in respect of illegal dentition.
 Order passed by ASJ V Quetta on Habeas Corpus petition.
 Certified Copy of Order issued to wife of applicant on dated 08-4-2023.
 Copy of FIR no. 18/2023 Police station Panjpai Quetta.
 Copy of FIR no. 20/2023 Police station Panjpai Quetta.

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1

IN THE COURT OF ADDITIONAL SESSION JUDGE 1, QUETTA.

Bail Application No.___/2023

In the matter of:

APPLICATION UNDER SECTION 497 CR.P.C FOR GRANT OF

2. That it is pertinent to mention here prior to instant FIR the Wife

3. That after the filing petition before court of law in respect of

been registered with police station Panjpai District Quetta,

4. That the complainant in said matter very cunning, shrewd and

5. That the complainant cooked up concocted story regarding

6. That from the content of FIR shows police officials narrated

7. That the application being innocent not committed any offence

A. That the accused/applicant was abducted by law enforcing

B. That the police officials, complainant have violated the golden

C. That the involvement of accused/applicant in the instant case

D. That it admittedly the instant case was registered against the

E. That the there is no incriminating material to connect the

F. That from data available on record and evidence collected no

G. That there are various other irregularities and illegalities

H. That the involvement of the accused/applicant is solely on the

I. That the applicant is ready to prepare and furnish solvent

J. That the counsel for applicant will add some more

DATED: -06-2023. Applicant/Accused

It is certified that previously no bail application in the same FIR has

 Relied upon all documents Annexure.

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