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Bail 462-J PPC

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javed khan
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136 views4 pages

Bail 462-J PPC

Uploaded by

javed khan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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IN THE COURT OF ADDITIONAL SESSION JUDGE TOPI

1. Wakeel Khan S/O Abdul Ghafoor R/O Mainai Tehsil Topi


District Swabi.

---------Accused/Petitioner
VS

1. The State
2. SDO Maqbool Shah PESCO SUBDIVISION Topi
-------- (Respondents)

Case FIR NO. 325 Dated: 06-05-2024


Offence U/S : 462-I
Police station: Topi

APPLCIATION U/S 498 Cr.P.C FOR THE GRANT OF


PRE ARREST BAIL TO THE ABOVE NOTED
ACCUSED/PETITIONETR TILL FINAL DECISION OF
THE CASE.

Respectfully Sheweth:

1. That the Accused/ Petitioner have falsely been involved in


the above captioned case with malafide intentions for
ulterior motives and extraneous consideration just to
harass and humiliate him.
(Copy of the F.I.R is attached)

2. That the local police is after the arrest of the


accused/Petitioner for some ulterior motive.

3. That the Accused/Petitioner approach before this


Honourable court for his release on pre-Arrest bail on the
following grounds amongst the others:
GROUNDS:

A. That except the bare allegations in F.I.R there is no


cogent evidence available on record to connect the
accused/ petitioner with commission of alleged offence.

B. That prosecution case is false, exaggerated and based


on surmises and conjectures and furthermore there is
no private eyewitness of the alleged occurrence.

C. That the offense with which the accused/ Petitioner is

charged does not fall within the ambit of prohibitory

clause of Section 497 (2) Cr.P.C which entitle the

accused/ petitioner to the grant of bail.

D. That the story narrated by the complainant is not


Appealable and plausible to a prudent mind.

E. That prosecution case is motivated with malafide to


cause irreparable loss to the honour of the
accused/petitioners and further to blackmail and
pressurize the accused/Petitioners to complete
nefarious desires which are not permitted under the
law.

F. That Petitioner is neither a previous convict nor


hardened or desperate criminal.

G. That the accused/petitioner is belongs to a respectable


family and is ready to give sufficient bail bonds to the
satisfaction of this august Court.

H. That any other ground well be taken at the time of


Arguments with the kind permission of this Hon’ble
Court.
Prayer:
It is, therefore, most humbly prayed that on acceptance
of this pre-arrest bail application, the Accused/petitioner may
kindly be allowed pre-arrest bail till the final decision of the
instant case in the best interest of justice.

It is further prayed that ad-interim pre-arrest bail may


also be granted to the Accused/petitioners till the final
decision of the instant case.

Petitioner

Through
Dated: 11-05-2024 NAZIM KHAN
Advocate High Court

Certificate:
It is certified upon the information provided by the
Petitioner that it is the 1st bail petition filed before this
Hon’ble Court in the matter in hand…

Advocate…
AFFIDAVIT

I, Wakeel Khan S/O Abdul Ghafoor R/O Mainai Tehsil Topi


District Swabi, do hereby solemnly affirm and declare on oath
that the contents of the accompanying Pre Arrest Bail
Application are true and correct to the best of my knowledge
and belief and nothing has been concealed from this Hon'ble
Court.

DEPONENT

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