IN THE COURT OF ISLAMABAD HIGH

COURT, ISLAMABAD.

Bail petition No. ______2021

Usman Javed S/o Muhammad Javed Presently confined in Adyala Jail

Rawalpindi.

Petitioner……….

Vs.
1. The State

Respondents…….

IN CASE FIR NO.506/23, DATED 4.5.2023 UNDER

SECTION 9(1)6-C OF CNSA, P.S. KARACHI COMPANY,
ISLAMABAD.

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

Respectfully Sheweth;

The petitioner humbly submits as under:-

FACTS

1. That the petitioner is respectable citizen of Pakistan who has been

attributed a role of carrier of narcotic substance weighting 1500 grams.
2. That the said narcotic substance has been alleged to be recovered from
the petitioner/accused by the police.

3. That the petitioner/accused has no concern whatsoever with the

commission of any sort of offence as mentioned in the above
mentioned FIR but due to ulterior motives on the part of the police, the
local police has booked the petitioner/accused without any reason or
cause.
4. That the petitioner is entitled for concession of post-arrest bail inter-
alia on the following

Grounds
i. That the petitioner is innocent in the above mentioned case and have
falsely been implicated by the local police with malafide intensions
without any justification or involvement of the petitioner.

ii. The story alleged by the prosecution is a cock-tale story and no such
occurrence ever took place.

iii. That the alleged offence never took place and the local police has
lodged the instant FIR just to blackmail, humiliate and disrepute the
family of the petitioner.

iv. That there is neither previous criminal record of the petitioner nor he
has ever been convicted.

v. That the petitioner hails from a reputed family and used to work hard
for their necessity hoods and having unblemished past record. He
can’t even dream to be part of such a heinous activity.

vi. That the case is one of further inquiry and the petitioner cannot be
kept behind the bar for an indefinite period.
 vii. That the alleged quantity recovered from the accused is 1120 grams
which lies in border line, hence the petitioner could be granted
concession of bail.

viii. That the petitioner is behind the bar since his arrest and he is no
more required for investigation purposes hence, he is entitled to the
concession of bail.

ix. That there is no possibility of tempering with the prosecution record

as it is in the custody of the local police and there is no possibility of
the abscondence of the petitioner/accused as he is a poor employee
hence he is entitled to the concession of bail.

5. That the petitioner/accused is ready to furnish solvent surety bonds to the

satisfaction of this honourable court and is ready to appear as and when directed
by this Honorable court.

PREYER:
Under the aforementioned facts and circumstances, it is therefore respectfully
prayed that the present petitioner may kindly be granted bail till the final
decision of the case. Ad interim bail may graciously be granted till the final
decision of the case.

Through Counsel…………..

Mufeed Khan Yousafzai

Advocate High Court

CERTIFICATE:
Certified as per instruction received and subject to confirmation
from record that this is the first petition moved by the petitioner in
the instant case before this Honorable Court. Previously no bail
petition has been filed by the petitioner before this Honorable Court.

Counsels
 IN THE COURT OF ISLAMABAD HIGH
COURT, ISLAMABAD.

Bail petition No. ______2021

CM No. _________2021
Usman Javed S/o Muhammad Javed Presently confined in Adyala Jail
Rawalpindi.

Petitioner……….

Vs.
1. The State

Respondents…….

(IN CASE FIR NO.506/23, DATED 4.5.2023 UNDER

SECTION 9(1)6-C OF CNSA, P.S. KARACHI COMPANY,
ISLAMABAD.

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

APPLICATION FOR EXEMPTION FROM PRODUCING CERTIFIED
COPIES.
Respectfully Sheweth;

1. That the applicant moved a bail petition accompanying here with which
may kindly be read as integral part of this application.

2. That the applicant has filed certain documents along with main bail
petition, certified copies of which are not available to the applicant.
 3. That the applicant entitles for exemption from producing certified
copies and if exemption sought is not allowed, the applicant shall suffer
an irreparable loss.

4. That the certified copied will be produced in the Court as and when
available.

PRAYER:
It is therefore, respectfully prayed that this Hon’ble Court may very graciously
be pleased to accept the application and exempt the applicant from producing
certified copies.

Applicant
Through Counsel…………..

MUFEED KHAN YOUSAFZAI

ADVOCATE HIGH COURT

 IN THE COURT OF ISLAMABAD HIGH COURT,
ISLAMABAD.

Bail petition No. ______2021

USMAN JAVED
Vs.
The State etc

IN CASE FIR NO.506/23, DATED 4.5.2023 UNDER SECTION

9(1)6-C OF CNSA, P.S. KARACHI COMPANY, ISLAMABAD.

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

INDEX

Sr. Page Annexur

Description of documents Dated
No. No. e

1 Bail petition 1-4

2 Copy of FIR 5 A
6 Attested Copies of order 6-7 B
Application of exemption of
7 8-9
documents
8 Wakalatnama. 10

…………….Petitioner

…..Through Counsel,

MUFEED KHAN YOUSAFZAI

ADVOCATE HIGH COUT