I N T H E C O U R O F I L L A Q A J U D IC I A L M A G I S T R A T E

P O L I C E S T A T I O N C H A K R AL A , M I AN W AL I
CRL. MISC.NO. ___________ /2023.

 A B D U L
MAJEED S/O MANZOOR ELAHI R/O DHOKE
FAQEERA, TEHSIL & DISTRICT TALAGANG.

.......Petitioner
VERSUS
    The State
……. Respondent

CASE FIR NO: 5/23,  DATED:  08/01/2023

OFFENCE U/SS: 489-F PPC
POLICE STATION: CHAKRALA
DISTRICT MIANWALI

Petition U/S 497 Cr.P.C for the grant of post arrest bail. 

Respectfully sheweth:-

                     That above mentioned FIR was got registered against the

present petitioner at the instance of complainant with
malafide intention, ulterior motives, false and fabricated
allegation leveled by the complainant against the petitioner,
in which petitioner was arrested and after formal
 investigation sent to judicial look-up. For further detail
copy of FIR is attached herewith.
                     That the petitioner now seeks kind indulgence of this
Honorable Court for the grant of post arrest bail inter-alia
on the following amongst other grounds:

G R O U N D S 

1. That the petitioner is quite innocent in this case and

has nothing to do with the commission of alleged
offence as mentioned in the FIR.
2. The Petitioner is behind bars since his arrest and no
more required by the Prosecution as investigation has
been completed and that the Petitioner is previously
non-convict who is ready to furnish sufficient surety
to the satisfaction of this Court.
3. That the prosecution story as narrated in the FIR is
false, frivolous, baseless and concocted one just to
harass, blackmail and pressurize the present
petitioner.
4. That the offences mentioned in the FIR does not fall
within the ambit o prohibitory clause.
5. That there is no apprehension of Petitioner’s
absconding away or tampering with the prosecution
evidence particularly when the Petitioner is ready to
furnish surety bond according to the entire
satisfaction of this Honourable Court.
6. That further submissions and arguments shall be
advanced at the time of hearing of titled case.
 7. That all the facts and circumstances of the case make
case of the petitioner one of further inquiry.

PRAYER:

In view of the above submission, it is,

humbly prayed that the post-arrest bail
may kindly be granted to the petitioner till
the final decision of this case in the
interest of law and justice. 

PEITITONER. 

THROUGH COUNSEL

MALIK ATIF IQBAL AWAN ADV

LLM (NEW DELHI), INDIA.

VERIFICATOIN: -

Verified upon oath at Mianwali at this day of _________2023 that

contents of the bail petition are true and correct and nothing has
been concealed therefrom.
 
DEPONENT.
  
  
 I N T H E C O U R O F I L L A Q A J U D IC I A L M A G I S T R A T E
P O L I C E S T A T I O N C H A K R AL A , M I AN W AL I

  
Crl.Misc.No.__________________-/2023

ABDUL MAJEED    VERSUS        The State

 

I N D E X.
Sr. No. Description of Documents Annex. Dated Page
   
01 Grounds of bail Petition Affidavit.      

02 Copy of FIR. “A”    

03 Power of Attorney.      

PEITITONER.
 
THROUGH COUNSEL
 

MALIK ATIF IQBAL AWAN ADV

LLM (NEW DELHI), INDIA.