Bilal Ahmad

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

Crl. Misc. No._____________/B/2002 Bilal Ahmad S/o Muhammad Iqbal, caste Khokhar, R/o Kachi Sarai, outside Daulat Gate, Multan. ……….Petitioner VERSUS The State.

……..Respondent

PETITION FOR POST-ARREST BAIL U/S 497 CR.P.C. Case: F.I.R. No. U/s: P.S.

315/2001 Dated 13.10.2001 392 P.P.C. converted into 395/412 P.P.C. Qutab Pur, Multan.

Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the instant F.I.R. was registered on the statement of one Muhammad Sadiq, stating thereby that he is working as Accountant with Akbar Brothers, B.C.G. Chowk, Multan. On the night of occurrence, at 11:00 P.M., he, with his real brother, Muhammad Javaid, while riding a Motorcycle No. 7949/MNW, CD-70, model 1998, red in colour, going to their home. At 11:15 P.M., when they reached near the Farooq Pura Graveyard 4 unknown persons (complexion detailed) armed with “Khanjars” intercepted them. The accused persons snatched motorcycle, Registration Book and Rs. 1500/- from them and fled away.

Accused persons can be identified by the complainant and his brother. Copy of F.I.R. is annexed as Annex “A” and better copy is Annex “A/1”. 3. That the petitioner applied for post arrest bail in the court of first instance, but the same was refused vide order dated 2.1.2002. The petition for the same relief was also turned down by the court of learned A.S.J, Multan, vide order dated 14.2.2002. Copies of orders are Annexes “B & C”. 4. That the petitioner is entitled for the concession of post arrest bail inter alia on the following: GROUNDS i) That the petitioner is not nominated in the F.I.R. and arrest of petitioner is a case of high-handedness committed by the police. ii)

That the petitioner was arrested on the statement of coaccused while the co-accused were arrested on the pointation of “Mukhbar”.

iii)

That no identification parade was held for the identification of petitioner.

iv)

That the petitioner was arrested on 25.9.2001 and remained on physical remand, but nothing was recovered from the possession of petitioner.

v)

That petitioner is innocent in this case and roped up falsely in this.

vi)

That the petitioner agitated the plea of muocence, which was not properly investigated.

vii)

That in these circumstances, no reasonable grounds exist to connect the petitioner with the crime.

viii) That it is a case of further inquiry in the present situation, when there is no evidence against the petitioner. ix)

That the investigation in the case is almost complete and petitioner is no more required by the police.

x)

That the petitioner is behind the bars since his arrest and no useful purpose can be served with further detention of petitioner.

xi)

That the petitioner is neither previous convict and nor having any record. Keeping in view of the above-mentioned submissions, it is respectfully prayed that the petition in hand may kindly be accepted and post arrest bail may please be allowed to the petitioner. Any other relief, order or direction which this Hon’ble Court deems fit may please be extended in favour of petitioner to meet the ends of justice. Humble Petitioner,

Dated: ___________ Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959

Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176

CERTIFICATE: Certified as per instructions of the clients, that this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble court. Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

In re: C.M. No. _____________/2002 In Crl. Misc. No._____________/B/2002 Bilal Ahmad

Vs

The State

APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPIES OF ANNEXURES. =========================================

Respectfully Sheweth: That certified copies of Annexures “A, A/1 & C” are not available. However, uncertified/photo state copies of the same have been annexed with the petition, which are true copies of the original documents. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copies of the documents. APPLICANT, Dated: __________ (BILAL AHMAD) Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959

Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

Crl. Misc. No._____________/B/2002 Bilal Ahmad

Vs

The State

INDEX S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES 1

Urgent Form

2 3

Bail Petition. Copy of F.I.R. & better copy.

4

Copies of orders.

5

Dispensation Application.

6

Vakalatnama

A & A/1 B&C

PETITIONER Dated: ____________

Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959

Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176