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IN THE COURT OF SPECIAL JUDGE(Banking Crime) PUNJAB, LAHORE.

BA . No. ______________________________________ 2011

Shaikh Muhammad Tahir s/o Shaikh Muhammad Gulzar R/o `House No


265/aMohala Iqbal Avenue Near Shoukat Khanam Hospital, Lahore .

Petitioner

Vs
The State Respondent Case FIR No. Dated:17-06-2011 PS FIA/CCC/ Lahore . C- 49/2011

Offence Under Section 201/409/419/420/468/471/109- PPC section 5(2) Prevention of corruption Act of 1947 District: Lahore

_________________________________ Petition Under Section 498 CR PC for the Grant of Interim Bail
Respectfully Sheweth:
1. That the present petitioner has got apprehension for arrest in the above

titles case has been register at the instance of Muhammad Rafique

Operation Manager National Bank Wahdat Road Branch Lahore the complainant at the police station FIA/CBC/LHR. 2. That the according to the contents of the FIR, the petitioner was the custodian of the cheque books and security documents in the National Bank Wahdat Road Branch Lahore from where two cheque books were stolen and Used by some one else to withdrawn an amount of Rs 4.5milion from Ac No13-6492-7. 3. That the petitioner is quite innocent. The allegation is absolutely false baseless, concocted and based upon malafied intention of the complainant, and the FIR was lodged with malafied intension with convenience of FIA the petitioner has nothing to do with alleged occurrence. 4. That the petitioner seeks pre-arrest bail inter alia on the following:

GROUNDS

a. That the petitioner has been involved in this case with malafide intention and ulterior motives just to humiliate harass and black-mail him. b. That the petitioner was just a custodian and when those cheque books were stolen had properly informed to the complainant because he too have the keys , whereas the petitioner has no concerned with the issuance, and all other matters of Banking Process. c. That the petitioner had already being punished by the bank so no one can be punished twice of the same offence, while the petitioner dont1` have any knowledge about the concerned offences. d. That the offence mentioned in the FIR does not fall under the prohibitory clause of Section 497 Cr. P.C. e. That the petitioner is previously non-convicted and belong to respectable families of the locality, if the petitioner is arrested, he will be humiliated. f. That this is a case of further enquiry. g. That the petitioner is ready to join the investigation as and when required by the police. h. That there is no apprehension of the petitioner abscondence of tampering with the prosecution evidence in case, if the petitioner is admitted to bail. i. That the petitioner has no concern in any manner whatsoever with the concerned allegation just to harass the petitioner whereas they have no concern with aligated offence levied on

the petitioner and the petitioner is ready to furnish the surety bound for the satisfaction of this honorable court.

Prayer
It is therefore, respectfully prayed that this petition may kindly be accepted and petitioners may kindly be admitted to pre-arrest bail till the final decision of this case. It is further prayed that ad-interim bail may also be granted till the final decision of this petition.

Petitioner

Through

Muhammad Kamran siddiqui Advocate High Court Siddiqui Law Chambers


48 Lewer Mall View Garden Society Lahore

IN THE COURT OF SPECIAL JUDGE(Banking Crime) PUNJAB, LAHORE.

BA . No. ______________________________________ 2011

Shaikh Muhammad Tahir

Vs
The State
1

Petition Under Section 498 CR PC for the Grant of Interim Bail

AFFIDAVIT OF Shaikh Muhammad Tahir s/o Shaikh Muhammad Gulzar R/o `House No 265/aMohala
Iqbal Avenue Near Shoukat Khanam Hospital, Lahore.

1.
I, the above named deponent solemnly affirm and declare as under;
That the Contents of the accompanying petition are correct and true to the best of dependants knowledge and belief and nothing has been concealed there from. Moreover, the deponent has not filed any other petition except the instant petition in any other Court.

DEPONENT

Verified on oath at Lahore on this 10 day of August2011 that all the contents of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

IN THE COURT OF SPECIAL JUDGE(Banking Crime) PUNJAB, LAHORE.


BA . No. ______________________________________ 2011

Shaikh Muhammad Tahir

Vs
The State
2

Petition Under Section 498 CR PC for the Grant of Interim Bail

Petition Under Section 498 CR PC for the Grant of Interim Bail

INDEX
Sr.No. 1. 2. 3. 4. Description of documents Bail Application Affidavit Copy of FIR Power of Attorney Annexure Pages 1 to 3 4 5 to7 8

Petitioner
Through

Muhammad Kamran siddiqui Advocate High Court Siddiqui Law Chambers


48 Lewer Mall View Garden Society Lahore