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Bail Before Arrest U S 489

1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

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Yasir Khan
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482 views3 pages

Bail Before Arrest U S 489

1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

Uploaded by

Yasir Khan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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[1]

IN THE COURT OF SESSIONS JUDGE,


ISLAMABAD

Ajaz Hussain S/o Ghulam Hussain R/o house no.10,block no. 90-
B,Sec G-9/2, Tehsil & District Islamabad
… Petitioner
Vs.
The State
… Respondent

FIR NO. 209 DATED 01.07.2013


U/S 489-F P.P.C.
P.S. AAbpara, ISLAMABAD.

PETITION UNDER SECTION 498 Cr. P.C. FOR BAIL


BEFORE ARREST

Respectfully Sheweth:

1. That the petitioner has been falsely implicated in the case,


particulars of which have been given above in detail.

2. That very registration of instant FIR is based on malafide on


part of the complainant as well as police.

3. That there is inordinate delay in lodging FIR for which no


justification, whatsoever, has been given in the FIR. Delay is
fatal to case of prosecution if not explained, as in this case, and
sufficient to prove malafide on part of the complainant.

4. That the Cheque in question has been rendered without


consideration and the main ingredients which must exist to
constitute offence under section 489-F ppc i.e., consideration,
dishonest issuance of cheque, are missing in the instant case.

5. That it is the civil court which has to determine the rights of the
parties. The complainant has tried to convert a civil dispute into
a criminal one.
[2]

6. That the police is behind the petitioner for his arrest due to
ulterior motives and if petitioner arrested in hands of police it
will result into humiliation and unjustified harassment to him.

7. That the petitioner is previous non-convict and has unblemished


past to his credit. The offences leveled in the FIR do not fall
within the prohibitory clause of Section 497 Cr. P.C. and in
such like cases bail is ruled and no exceptional circumstance
exist in this case.

8. That case of the petitioner is one of further inquiry; hence


petitioner is entitled for bail as of right.

It is, therefore, respectfully prayed that this Honourable Court


may very graciously be pleased to admit the petitioner to bail before
arrest till final decision of the instant case.

Further prayed that ad-interim pre arrest bail may also be


granted till final disposal instant petition.

Petitioner

Through

Ch. Abdul Rehman Bajwa


Advocate High Court
Islamabad
Certificate:

Certified that this is the first petition for


bail before arrest being filed in this
Honourable Court. No other bail petition
of the petitioner is pending at any other
forum as per information furnished by
the petitioner.

Counsel
[3]

IN THE COURT OF SESSIONS JUDGE,


ISLAMABAD

Ajaz Hussain Vs. The State

FIR NO. 209 DATED 01.07.2013


U/S 489-F P.P.C.
P.S. AAbpara, ISLAMABAD.

PETITION UNDER SECTION 498 Cr. P.C. FOR BAIL


BEFORE ARREST

AFFIDAVIT

I, Ajaz Hussain S/o Ghulam Hussain R/o house no.10,block no.


90-B,Sec G-9/2, Tehsil & District Islamabad do hereby solemnly
affirm and declare on Oath that contents of accompanying bail
petition are true and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.

DEPONENT
VERIFICATION:

Verified on Oath that contents of my above affidavit are true


and correct to the best of my knowledge and belief and nothing has
been concealed therefrom.

DEPONENT

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