IN THE COURT OF WORTHY SESSIONS JUDGE,

LAHORE.

B.A. No. ____________ / 2021

Ghaffar Masih son of Nawab Masih resident of Street # 1, Near

Nishter Colony Police Station , Lahore.(Presently Confined in
Camp/District Jail , Lahore.)
….Petitioner

VERSUS

The State
….Respondent

FIR No. : 819/2021 Dated 23.05.2021

Offence : U/s 9-C CNSA
Police Station : Ichhra, Lahore.

APPLICATION UNDER SECTION 497 Cr.P.C.

FOR THE GRANT OF POST-ARREST BAIL

Respectfully Sheweth:

1. That the above titled case was registered on the

instance of complainant against the petitioner at

police station Ichhra, Lahore. Copy of FIR is

attached as Annexure “A” .

2. That the petitioner is innocent and nothing to do

with the alleged off ence whatsoever.

3. That the petitioner seeks his post arrest bail on

the following amongst other:

GROUNDS

(a) That the petitioner is innocent and has been

falsely involved in this case.

(b) That the petitioner is no more required by

the police and there is no likelihood of the

petitioner to abscond or tamper with the

prosecution evidence.

(c) That the petitioner is previous non convict

never been involved in any anti social or

criminal activity.

(d) That there is no any independent witness of

the occurrence mentioned in the FIR.

(e) That nothing has been recovered from the

petitioner, the alleged recovery is planted

one.

(f) That the petitioner is ready to furnish surety

bond for the entire satisfaction of this

Honourable Court.
 (g) That further grounds will be argued at the

time of arguments.

PRAYER

It is, therefore, most respectfully prayed that

the petitioner may very kindly be released on bail till

the final decision of this case in the supreme interest

of justice.

Petitioner

Through

Aftab Ahmad Hanjra

Advocate High Court

7-A Takbeer Block, Model Town Courts, Lahore.

Dated: 25-08-2021.

CERTIFICATE
As per information provided by my client, this is
first bail petition on the subject before this
Honourable Court.

Advocate