Bail Application

BEFORE THE COURT OF SESSION JUDGE, QUETTA.

IN THE MATTER OF:
Mr. Hidayatullah Khilji S/o Saifullah Khilji , Residing at Jinah Town,
Quetta..............................................................................................APPLICANT
Versus
State of Pakistan.........................................................................RESPONDENT
FIR No.: 152/2020
Offences U/s: 344 PPC, 496/A Women Protection Act
APPLICATION UNDER SECTION 497 OF THE CODE OF CRIMINAL
PROCEDURE 1898 FOR GRANT OF BAIL
The applicant/ accused respectfully submits as under:
1. That the present application under section 497 of the Code of Criminal
Procedure 1898 is being filed for seeking grant of bail in FIR No. 152/2020
registered at Police Station of Saryab,Quetta. The present application is being
moved as the accused has been arrested on 17-11-2020 in connection with the
said FIR. The applicant is now in judicial/police custody. The copy of FIR is
annexed hereby and marked as annexure A.
2. That the instant F.I.R is false and frivolous having no truth therein and the
case of the prosecution is based upon malafide intentions.
3. That the Applicant is a law abiding citizen of Pakistan and a responsible
person and is living at the above mentioned address.
4. That there is no probability of absconsion of the applicant if he is released
on bail.
5. That the offence alleged against Accused is a bailable offence as provided
in schedule-2 of CrPC. So, the grant of bail gets as matter of right of the
accused.
6. That the FIR is lodged with delay and consultation and deliberations of
complainant party.
7. That there are reasonable grounds for believing that the Applicant has not
committed any offence and he is innocent and no useful purpose would be
served by keeping him under custody and this is a fit case for grant of bail.
8. That the applicant undertakes to abide by the conditions that this Honorable
Court may impose at the time of granting bail to the accused and further
undertakes to attend the trial on every date of hearing.
9. That the Applicant is ready to provide surety bond for the satisfaction of
this court if the post-arrest bail is granted to the applicant.
10. That the applicant humbly seeks to raise additional grounds at the time of
the arguments.

PRAYER:
In view of the above stated facts and circumstances it is most respectfully
prayed that this Honorable Court may be pleased to Grant bail to the Petitioner
in connection with FIR No. 152/2020 registered and pass any other such order
as this Honorable Court may deem fit and proper in the interest of justice.
Mr. Hidayatullah Khilji S/o Saifullah Khilji , ...............................APPLICANT
Through
MS. Zahra Batool..................................................................................Counsel
Place: Quetta
Dated: July 6th,2021