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Bail 9-C Faizan HC

1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

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Kashif Abbas
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2K views5 pages

Bail 9-C Faizan HC

1) Faizan has been arrested and charged with possession of 1165 grams of charas under section 9-C of the CNSA. He claims the police fabricated the case against him with malice and that nothing was actually recovered from his possession. 2) He further alleges that on the night he was arrested, the police raided his home, outraged the modesty of females, and stole a gold ornament and cash from his family. 3) Faizan is asking the court to grant him post-arrest bail and for the case to be further investigated, as he claims to be innocent and a victim of malicious prosecution.

Uploaded by

Kashif Abbas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as RTF, PDF, TXT or read online on Scribd
  • Case Introduction: Introduces the court case of Faizan versus The State, detailing the initial case description and the FIR's number involved.
  • Case Allegations and Rebuttals: Documents allegations made against the petitioner and the rebuttals highlighting that the petitioner was wrongly implicated.
  • Legal Considerations and Defense: Discusses legal arguments stating the petitioner's credibility and the reasons why the allegations are baseless and insufficient for further investigation.
  • Bail Petition Request: The official bail request petition outlined by the petitioner's lawyer with a closing certificate validating the honorable court interaction.
  • Document Index: Lists related documents for the bail petition in a structured format for reference within the court proceedings.

BEFORE THE LAHORE HIGH COURT, RAWALPINDI BENCH

RAWALPINDI

[Link] No._____________‘2014

Faizan S/o Muhammad Afzaal, caste Awan, resident of Mohra


Shah Wali Shah Tehsil Taxila, District Rawalpindi.
(Presently confined in District Jail Adiala Rawalpindi).

………….Petitioner
Versus
The State
………Respondent

CASE FIR NO.455 DATED 27.06.2014,


OFFENCE U/S 9-C CNSA, P.S. TAXILA.

PETITION FOR POST-ARREST BAIL U/S 497


CR.P.C.

Respectfully submitted:-

1- That petitioner has been falsely implicated in the

above-mentioned case and presently confined into District

Jail Adiala Rawalpindi.

2- That it has been alleged in the FIR that petitioner,

being suspicious, was searched and during this course,


contraband material i.e. Charas weighing 1165 grams was

allegedly recovered from his possession.

3- That the allegations leveled in the FIR against

petitioner are absolutely false, baseless, concocted and ill

founded and petitioner is quite innocent. The local police

fabricated the instant case against the petitioner with

malafide intention and ulterior motives.

4- That in fact, police raided upon residential house of

petitioner at late night on 27.06.2014 and outraged

modesty of females. The police also snatched the purse of

lying-in female containing a gold Kanta and cash amount

worth Rs.25,000/- and later on entangled petitioner in the

instant case. Malice of police is very much evident from

the fact that police showed arrest petitioner from Mohallah

whereas petitioner was apprehended from his residential

house. Even otherwise, police registered separate cases

against other family members of petitioner on the same

day by setting wider-net including petitioner’s aged father,

uncle and brothers.


5- That the petitioner is victim of malicious prosecution

having no concern whatsoever with the alleged offence.

Nothing was recovered from petitioner and alleged

recovery is planted one.

6- That alleged recovery is 1165 grams which is on the

border line of section 9-B/9-C of CNSA and apparently,

the case falls under the ambit of section 9-B/CNSA which

does not fall under the prohibitory clause of Cr.P.C.

7- That in circumstances, case against petitioner falls

under the ambit of further enquiry. That investigation into

the case is complete in all respects and person of

petitioner is no longer required for the purposes of further

investigation.

8- That petitioner belongs to respectable family, has the

blotless career and is also a previous non-convict.

Moreover, he is a minor and student as well having no

concern whatsoever with such like acts. Even otherwise,

petitioner falls under the ambit of Section 497 (I) Cr.P.C.

for the purpose of bail.


9- That petitioner preferred his bail petition before the

Learned ASJ Taxila who dismissed the same without any

cogent and lawful reason.

10- That petitioner is ready to furnish adequate sureties

to the entire satisfaction of this Honourable Court.

It is therefore, respectfully prayed that

petitioner may kindly be admitted to post-

arrest bail till the final disposal of the case.

Petitioner

Through

SH. MUHAMMAD YAQUB


Advocate
Supreme Court of Pakistan
CC No.16462

CERTIFICATE:

This is the first bail petition on behalf of the


petitioner, before this Honourable Court.

Counsel
BEFORE THE LAHORE HIGH COURT, RAWALPINDI BENCH
RAWALPINDI

[Link] No._____________‘2014

Faizan Versus The State

PETITION FOR POST-ARREST BAIL U/S 497 Cr.P.C.


I N D E X

[Link]. Description of documents Page No. Annexure


1. Bail petition 1-4
2. Copy of FIR a/w better
copy.
3. Impugned order of ASJ
Taxila dismissing bail
petition
4. Copy of bail petition

5. Copy of birth certificate


6. Application for
dispensation

7. Vakalat Nama

…Petitioner
Through:-

SH. MUHAMMAD YAQUB


Advocate
Supreme Court of Pakistan
CC No.16462

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