Department of Law

Bahria University Islamabad

ASSIGNMENT ON

“POST ARREST AND PRE ARREST BAIL

PETITION”
 Submitted By

Muhammad Ibrahim

Registration No: 01-177162-021

Submitted To

Sir Haroon Sami

Case 1

FACTS
FIR was registered against the petitioner that unlicensed arm has been recovered from him upon raid.
Bail petition was dismissed by Sessions Court. Bail was filed before Honourable High Court on the
grounds that he was innocent, case was borderline case and the petitioner had no criminal background.

BEFORE HONOURABLE ISLAMABAD HIGH COURT,ISLAMABAD

CRIMINAL MISC. NO:176/B/2019
AHMED SON OF ZAFAR CASTE XYZ RESIDENT OF ISLAMABAD
Presently Confined at District Jail Islamabad
…..Petitioner
VERSUS
1. THE STATE
2. A.S.I. POLICE STATION CITY
…..Respondents
F.I.R. No. : 176/2019
OFFENCE U/S : 13,19 & 24 ARMS ACT,1878
DATED : 24.09.2019
POLICE STATION : F-8 ISLAMABAD
DISTRICT :ISLAMABAD

Bail Petition

UNDER SECTION 497 CR.P.C. FOR GRANT OF BAIL AFTER ARREST TO THE PETITIONER.

Respectfully Sheweth :

1. That the petitioner seeks bail after arrest in case registered through FIR under section 13,
Section 19(e) and Section 24 of The Arms Act, 1878.
2. That the petitioner applied for Post Arrest Bail before Learned Sessions Judge however, same
was dismissed vide order dated 15.09.2019 passed by Learned Additional Sessions Judge, Copies
of Bail Petition & order of dismissal dated 15.09.2019 are Annexed.
3. That the FIR was registered on the application of complainant where it has been alleged that
upon raid un-licensed arm was recovered from the petitioner.
4. That the FIR was an outcome of cock and bull story and the petitioner has nothing to do with the
commission of alleged offence.
5. The petitioner has been falsely involved in this case therefore the petitioner humbly seeks
indulgence of this Honourable Court for grant of post arrest bail iner-alia .
6. That the FIR is false and fabricated one having no truth there in.
7. That as a matter of fact no recovery has been made and the alleged recovery is planted one .
8. That no private witness has been associated with the alleged recovery.
9. That petitioner is Honourable student of Government High School XYZ and he cannot go to his
academia as he is behind the bars.
10. That there is no probability of abscondence of petitioner if he is released on bail.
 11. That in aforementioned circumstances the instant case requires further inquiry.
12. That the petitioner humbly seeks to raise additional grounds at the time of the arguments.
13. That the petitioner is ready to provide surety bonds for the satisfaction of the court if the bail is
granted to him.

PRAYER

In the aforementioned circumstances it is humbly prayed that the petitioner may kindly granted post
arrest bail.

Certificate:
It is certified that upon instructions of the client it is the 1st petition for bail after arrest filed before this
Honourable Court in the matter in hand.

PETIONER THROUGH

Raja Amir

Advocate High Court

Case 2

FACTS

Team Bahria University had a cricket match with team Air University during which there was exchange
of harsh words and fight broke out the petitioner being captain of team Bahria University tried to stop
the fight but two players got involved in scuffle and stab each other one player got injured and in FIR the
name of captain of team Bahria University was also mentioned the petitioner claims innocence and
went to Additional Sessions court Islamabad for pre arrest bail.
BEFORE HONOURABLE ISLAMABAD HIGH COURT,ISLAMABAD
CRIMINAL MISC. NO:176/B/2019
TAIMOOR SON OF SULEMAN CASTE XYZ RESIDENT OF ISLAMABAD
Presently Confined at District Jail Islamabad
…..Petitioner
VERSUS
1. THE STATE
…..Respondents
F.I.R. No. : 177/2019
OFFENCE U/S :337-F P.P.C
DATED : 24.09.2019
POLICE STATION : F-8 ISLAMABAD
DISTRICT :ISLAMABAD

Bail Petition

UNDER SECTION 498 CR.P.C. FOR GRANT OF BAIL AFTER ARREST TO THE PETITIONER.

Respectfully Sheweth :

1. That the petitioner seeks bail after arrest in case registered through FIR under section 337-F(iv)
2. That the FIR was registered on the application of complainant where it has been alleged that the
petitioner along with other persons mentioned in FIR threatened the complainant and caused
hurt by cutting and incising the flesh , exposing the bone.
3. That the FIR was an outcome misconception and misunderstanding, and the petitioner has
nothing to do with the commission of alleged offence.
4. The petitioner has been falsely involved in this case therefore the petitioner humbly seeks
indulgence of this Honourable Court for grant of pre arrest bail iner-alia.
5. That his name was falsely mentioned in FIR on misunderstanding or under misconceptions.
6. That the petitioner and the complainant has no past grievance and did not even know each
other in the first place.
7. That there is no sufficient evidence to prove his involvement.
8. That if he is ought to be arrested then it will have adverse affect on his studies and future.
9. That in aforementioned circumstances the instant case requires further inquiry.
10. That the petitioner humbly seeks to raise additional grounds at the time of the arguments.
 11. That the petitioner is ready to provide surety bonds for the satisfaction of the court if the bail is
granted to him.

PRAYER

In the aforementioned circumstances it is humbly prayed that the petitioner may kindly granted post
arrest bail.

PETIONER THROUGH

Raja Amir

Advocate High Court