1

IN THE ISLAMABAD HIGH COURT, ISLAMABAD.

Crl. Misc. Application No._____________________/2023

In
Crl. Appeal No. 121/2018
Titled as:-
MIAN MUHAMMAD NAWAZ SHARIF
Versus
The State etc

APPLICATION UNDER SECTION 561-A ALONG WITH OTHER

ENABLING PROVISIONS OF CODE OF CRIMINAL PROCEDURE 1898.

It is respectfully submitted as under:-

1. That the petitioner filed Crl. Appeal No. 121/2018 (Mian Muhammad
Nawaz Sharif Vs. State), whereas Co-Convicts filed Crl. Appeals Nos.
122/2018 (Maryam Nawaz (Maryam Safdar) Vs. State) and Crl.
Appeal No. 123/2018 against judgment dated 06-07-2018 in ACR No.
20/2017 passed by Hon,ble Judge Accountability Court No.I,
Islamabad, whereby they all were convicted and sentenced to
various terms of imprisonment along with fine.

2. That it is relevant to mention here that at the time of

pronouncement of above said judgment of conviction, petitioner and
his daughter were in London in view of his wife’s critical condition in
London, where she was persistently dependent on a ventilator for
life support, and, as such, on 06-07-2018 had applied for the
postponement of the announcement of the judgment in the case for
one week to enable him to be personally present in the learned Trial
Court to hear the judgment, but the Learned Judge, Accountability
Court did not accede to this request and announced the judgment on
06-07-2018 in absentia.

3. That the petitioner and his daughter returned back to Pakistan

voluntarily on 13-07-2018 and surrendered to custody to order of
imprisonment. They both were confined at Adyala Jail Rawalpindi
wherefrom the above noted Crl. Appeals were filed on their behalf.
4. That the above said Crl. Appeals were admitted for hearing vide
order dated 21-01-2019. It is relevant to mention here that the
petitioner, his daughter and his Son-in-Law were allowed bail upon
suspension of sentence by this Hon,ble Court vide order dated
19.09.2018 (PLD 2019 Islamabad 38).

5. That the bureau challenged the above said order dated 19-09-2018
before the Hon,ble Supreme Court of Pakistan which was dismissed
vide order dated 14-01-2019. (PLD 2019 SC 445).

6. That when the above noted appeals were fixed for hearing, the
petitioner could not enter appearance due to which his Crl. Appeal
No. 121/2018 was dismissed vide order dated 23-06-2021 with an
observation “Appellant may file an application before this Court, as
and when he surrenders or is captured by the authorities, for decision
of the appeal on merits -------------”.

7. That it is significant to mention here that the Crl. Appeals Nos.

122/2018 and 123/2018 by co-convicts were heard and decided on
merit vide judgment dated 29-09-2022 whereby both the Co-
Convicts were acquitted.

8. That the petitioner was also convicted and sentenced to 7 Years

Rigorous Imprisonment with fine and forfeiture of receivable
property vide judgment dated 24.12.2018 in another ACR No.
19/2017 by Hon,ble Judge Accountability Court No.II, Islamabad.

9. That the petitioner surrendered to custody in pursuance of the

above said judgment and filed an application seeking his shifting to
any Jail in Lahore instead of Adyala Jail Rawalpindi which was
allowed and the authorities were directed to shift him to Kot Lakhpat
Jail Lahore with an observation that the said order shall hold the
field till it is withdrawn, modified or recalled by the same court or
set at naught by any Superior Court.

10. That the petitioner was shifted to Kot Lakhpat Jail Lahore. He filed
the Crl. Appeal No. 01/2019 against the judgment dated
24.12.2018 while he was under incarceration in pursuance of the
order of imprisonment vide above said judgment.
 11. That the above noted appeal was admitted for hearing vide order
dated 21-01-2019, it would suffice to submit here that the above
noted appeal was ultimately dismissed for default in appearance
vide order dated 23-06-2021 with an observation “Appellant may
file an application before this Court, as and when he surrenders or is
captured by the authorities, for decision of the appeal on merits -------
------”.

12. That during the pendency of the above noted appeal, petitioner filed
Writ Petition No. 32/2019 seeking suspension of sentence on merit
which was withdrawn whereas the writ petition No, 352/2019
seeking suspension of sentence on Medical Ground was dismissed
vide order dated 20.02.2019. (PLD 2019 Islamabad 343). This
order was assailed before the Hon,ble Supreme Court of Pakistan
through C.P No. 639/2019 which was decided vide judgment 26-03-
2019 (2019 SCMR 734) whereby petitioner was granted time
specific bail on Medical Grounds.

13. That upon expiry of the stipulated time in the above bail granting
order, the petitioner again surrendered before Jail Authorities at Kot
Lakhpat Jail Lahore on 07.05.2019 and then filed writ petition No.
1986 of 2019 seeking suspension of sentence but same was declined
vide order dated 20.06.2019.

14. That petitioner was undergoing sentence of imprisonment at Kot

Lakhpat Jail, Lahore pursuant to his conviction and sentence vide
Judgment dated 24.12.2018 when he was arrested by NAB in
another case pertaining to Chaudhary Sugar Mills (CSML) on
21.10.2019, he was being held in NAB custody at the NAB Office at
Lahore when he had to be shifted to Services Hospital in critical
condition as his blood platelets during NAB custody fell to 16000 per
microliter.

15. That on account of the precarious and critical condition of the

petitioner, a Special Medical Board was constituted by the
Government of Punjab to ensure proper treatment, however, the
Health condition of the petitioner could not improve despite all
 possible efforts and the situation became both alarming and life
threatening.

16. That it was in the above context that the petitioner filed writ petition
No. 63511/2019 seeking bail after arrest upon Medical Ground in
CSML Case which was allowed vide order dated 25.10.2019 by
Hon,ble Division Bench of Lahore High Court Lahore. Copy of the
order dated 25-10-2019 is attached herewith ANNEXURE-A.

17. That, simultaneously, the petitioner also approached this Hon,ble

Court through writ petition No, 3716 of 2019 to seek bail upon
suspension of sentence in the aforesaid Al-Azizia Reference which
was allowed vide order dated 29-10-2019, operative part whereof is
as under:-

In our short order of the even date we granted eight (8)

weeks bail to petitioner No.2 by suspending the sentence handed
down by the learned Judge Accountability Court-II, Islamabad vide
judgment dated 24-12-2018 in NAB Reference No. 19 of 2017. In
case, the health of petitioner No.2 does not improve and he needs
further medical attention, the Government of Punjab may, on its
own, decide the issue regarding suspension of sentence. Even
otherwise, petitioner No.2 may approach the Government of
Punjab under Section 401(2) Cr.P.C. The apprehension expressed
by the learned counsel for petitioner No. 2 can be alleviated as in
case of non-exercise of duty by the Government of Punjab or
misuse of the discretion or exercise of duty by the Government of
Punjab or misuse of the discretion or exercise of the same in an
arbitrary and whimsical manner, the matter can be agitated
before the Court of law for appropriate remedy. Order dated
29.10.2019 reported as (2020 PCRLJ 213).

18. That the health condition of the petitioner did not improve and thus
on 07-11-2019, Medical Board after review of the Clinical Care and
old Medical Reports gave a consensus opinion which is reproduced
as under:-

1. Despite two weeks of work up no cause for severe

thrombocytopenia has been identified, which remains
 unresponsive to provisional treatment aimed at ITP. The
Local (Nationally available) resources have been
exhausted. Further delay in clarifying the diagnoses exposes
him to profound undue risks, which is likely to lead to
adverse health and life consequences.

2. We would strongly recommend the patient to be shifted to

an advanced Medical Care Facility abroad where
appropriate diagnostic and interventional facilities are
available.

Copy of the report is attached herewith as Annexure-B.

19. That on account of the consensus view of the Board, the shifting of
the petitioner to an Advanced Medical Care Facility abroad became
imperative, however, he was unable to go abroad as his name was in
the Exit Control List (ECL) on the basis of Memorandum dated 20-
08-2018.

20. That confronted with the situation above, an application was moved
to Secretary interior for removal of his name from ECL in order to
enable him to avail specialized treatment at the earliest whereupon a
report was sought from the Government of Punjab, Specialized
Health Care and Medical Education Department, the report sought
which was filed by the Board same day on account of urgency. Copy
of the report dated 11.11.2019 is attached herewith as Annexure-C.
For facility of reference, the relevant portion of the report is
reproduced here under:-

The patient needs treatment in a centre of excellence which

can deal with his blood disorder as well as any underlying
malignancy which may be causing his thrombocytopenia, while also
offering advanced coronary artery intervention, hemodialysis and
carotid/Neuro intervention. The contradictory nature of the
treatment were explained to the patient when he was at
Services Hospital Lahore. No public sector Hospitals in Pakistan
has the required facilities nor the expertise to deal with this
complicated case. Bleeding and thrombosis can be fatal in this
case. Any coronary carotid, renal or infectious can prove fatal at
any time.

21. That it is pertinent to mention here that in the above said report by
the Medical Board constituted by the Government of Punjab various
tests were advised, facilities for which were not available in Pakistan.
22. That the matter was taken up by the Sub-Committee of Cabinet
which summoned all the concerned including the Convener of the
Medical Board and Secretary Health Government of Punjab,
although, no reservation as to the Health Condition and shifting of
the petitioner could be expressed by whosoever yet, one time
permission was granted for a period of 4 weeks subject to furnishing
an indemnity bond worth approximately Rs. 7 Billion.

23. That the petitioner’s brother Mian Muhammad Shahbaz Sharif

assailed the above said order through writ petition No. 68815/2019
before Hon,ble Lahore High Court Lahore, which was taken up by an
Hon,ble Division Bench who issued a direction to the Head of the
Medical Board to submit a report as to health condition of the
petitioner as also to enter personal appearance to explain the matter.

24. That suffice it to submit here that after submission of Medical Report
and its explanation by the Head of the Medical Board in person, the
operation of the above said memorandum / order to the extent of
condition was suspended vide order dated 16.11.2019, operative
part whereof is reproduced hereunder for ready reference:-

“3. We may mention that after hearing the leaned counsel of the
parties, it was resolved that if it is undertaken by the petitioner as
well as Mian Muhammad Nawaz Sharif for one time travel and
timely return then his request to travel abroad can provisionally be
looked into. Learned Counsel for the parties, under instructions,
submitted their respective proposed drafts of undertakings
submitted their respective proposed drafts of undertakings but no
consensus could be developed despite the hectic serious efforts put
in by them throughout the day. However, the petitioner and Mian
Muhammad Nawaz Sharif, filed their following undertakings, which
read as under:-

UNDERTAKING (Mark-A)

“I Mian Muhammad Shahbaz Sharif son of Late

Mian Muhammad Sharif having CNIC No. 35200-
 3085629-3 do hereby undertake to ensure
return of my brother Mian Muhammad Nawaz
Sharif, within four (4) weeks or as and when
certified by doctors that he has regained his
health and is fit to return back to Pakistan.

I further undertake to provide / send the

periodic medical report of the doctor duly
notarized by the Embassy or High Commission of
Pakistan to the Registrar of this Court.

I also undertake that if at any stage, the Federal

Government has credible information that Mian
Muhammad Nawaz Sharif is living abroad
despite his fitness to travel, a representative
from Pakistan’s High Commission or Embassy
would have a right to meet with his physician(s)
to verify or confirm about his health.”

UNDERTAKING (Mark-B)

“I Mian Mohammad Nawaz Sharif son of Late

Mian Muhammad Sharif having CNIC No. 35201-
5369836-7 do hereby undertake to return to
Pakistan as per my past record to face the
process of law and justice within four (4) weeks
or as soon as I am declared healthy and fit to
travel back to Pakistan by my doctors.
I also do hereby bind myself to the undertaking
given by my brother Mian Muhammad Shahbaz
Sharif.”

4. Admittedly, Mian Muhammad Nawaz Sharif, has been granted

one time permission to travel abroad in view of his critical health but
subject to the conditions mentioned in para 1 of submitting an
indemnity bond of 08 Million UK Pounds or equivalent Rupees, 25
Million US Dollars or equivalent Rupees Rs.1.5 Billion Rupees, are
under judicial scrutiny and also in view of the undertaking of M/s
Mian Muhammad Nawaz Sharif and Mian Muhammad Shahbaz
Sharif, operation of the impugned memorandum is suspended to the
extent of the said conditions and Mian Muhammad Nawaz Sharif is
granted one time permission to travel abroad as interim
arrangement for four (4) Weeks and will return when certified by
doctors that he has regained his health and is fit to return back to
Pakistan.”
Copy of order dated 16.11.2019 is attached herewith as
ANNEXURE-D.

25. That it is significant to mention here that in compliance of the above

said order dated 16-11-2019, Periodic Medical Reports have been
 submitted with the Registrar of Hon,ble Lahore High Court Lahore
from time to time.

26. That on 19-11-2019, the petitioner proceeded abroad for his

treatment, Periodic Medical Report dated 13-12-2019 was filed
before the Hon,ble Lahore High Court Lahore, since, the Government
of Punjab did not proceed to decide the issue of suspension of
sentence on its own as per order dated 29-10-2019 by this Hon,ble
Court in writ petition No, 3716/2019, a formal application dated
23.12.2019, under section 401(2) Cr.P.C was filed before the
Government of Punjab. Copy of the application is attached herewith
as ANNEXURE-E.

27. That it is pertinent to mention here that through the above said
application, it was brought to the notice of the Government of the
Punjab that the petitioner was permitted to go abroad by Hon,ble
Lahore High Court Lahore vide above said order dated 16.11.2019 in
writ petition No, 68815/2019. Thus, Government of the Punjab was
requested to suspend the sentence handed down vide judgment
dated 24-12-2018 in ACR No, 19/2017 in terms of the above said
order.

28. That on 26-12-2019, Section Officer (MP) Home Department

Government of Punjab intimated that above said application was
being examined and decision would be informed accordingly.

29. That on 06-01-2020, Section Officer (MP) Home Department

Government of Punjab asked for submission of latest clinical
examination and recent laboratory and imaging reports. Whereupon
Petitioner’s Counsel intimated the Government of Punjab to directly
contact the petitioner or his physician; thereafter, Medical and
Labortary Reports were submitted to Chief Secretary vide letter
dated 14-01-2020, whereas, a comprehensive summary by the
petitioner’s physician Doctor Adnan was submitted on 30-01-2020.
It is pertinent to mention here that in the meanwhile, periodic
Medical Report dated 15.01.2020 was submitted in Lahore High
Court Lahore; Government of Punjab issued letter dated 19-02-2020
requiring the petitioner or his representative to appear in person on
 20.02.2020 which was responded by Mr. Attaullah Tarar vide letter
dated 20-02-2020 wherein a request was made for fixation of the
matter for another date due to paucity of time and arrangement for
participation of Doctor Adnan through Video Link, however,
ultimately the above said application dated 23.12.2019 under
section 401(2) Cr.P.C. was dismissed vide order dated 27-02-2020.
Copies of the letter dated 20-0-2022 and order dated 27-02-2020 is
attached herewith as ANNEXURE-F,G.

30. That the order dated 27-02-2020 was passed without adequate
opportunity of hearing and judicious application of mind, rather, the
same suffered from extraneous considerations of political vendetta
as the Government in Punjab was headed by Pakistan Tahreek-e-
Insaaf whose Leaders have throughout been open in their expression
against the petitioner and his party; neither the reports of imminent
Doctors both foreign and local including Government appointed
team of Doctors nor Lab Reports and Medical Tests were considered,
rather, the same were not given any weight without any evidence to
the contrary. Moreover, no effort was made to hold an inquiry into
the then Health status of the petitioner through the mechanism
provided in the order dated 16-11-2019 read with the contents of
the undertakings both by the petitioner and his brother Mian
Muhammad Shahbaz Sharif. Even the Periodic Medical Reports
submitted before the Hon,ble Lahore High Court Lahore were not
taken into account. On the face of the record, order dated 27.02.2020
was passed in a slipshod, whimsical and capricious manner.

31. That in the meanwhile, the above noted appeal was fixed for hearing,
petitioner moved various CMAs including 215 of 2020 spraying
therein to forgo the requirement of the petitioner’s surrender and to
decide appeal on the basis of record in terms of Section 423 of Cr.P.C.
but the said requests were declined vide orders dated 01-09-2020,
10.09.2020 and 15.09.2020 and the petitioner was not afforded right
of audience inter alia on the ground of having been declared as
absconder vide order dated 09-09-2020 in ACR No. 06/2020 passed
by Hon,ble Accountability Court No.III, Islamabad and an order of
non-bailable warrants of arrest dated 03-09-2020 in ACR No.
 15/2020 passed by Hon,ble Judge Accountability Court No.1 Lahore.
Copies of orders passed in Crl. Appeal No. 121/2018 are attached
herewith as ANNEXURE-H.

32. That the petitioner could not enter appearance in the above noted
appeal and the same was ultimately dismissed vide order dated
23.06.2020 with the following observations:- “Appellant may file an
application before this Court, as and when he surrenders or is captured
by the authorities, for decision of the appeal on merits ----”.

33. That the non-appearance of the petitioner was neither deliberate

nor intentional or malafide, rather, he was prevented from returning
back to Pakistan on account of circumstances beyond his control
whose background has been explained at great length in writ
petition No. 3333 of 2023 which is fixed for hearing for today. For
brevity of pleadings, the contents of the said writ petition are sought
to be read herein as an integral part.

34. That the petitioner had himself volunteered to come back to

Pakistan, he is surrendering before this Hon,ble Court and submits to
due process of justice so as to seek resurrection / restoration of the
above noted appeal and its decision on merits in accordance with
law inter alia on the following:-

GROUNDS

a. That the petitioner did not jump bail nor misused this concession,
rather, as a matter of record, he was on bail in all cases against him
and he went abroad with the permission of Court of competent
jurisdiction.

b. That the absence of the petitioner before this Hon,ble Court was
neither intentional nor deliberate or mala-fide, rather, he was unable
to enter appearance due to Medical advice and circumstances
beyond his control, unfortunately, his health condition could not
improve and the requisite procedures got delayed on account of
Covid-19 pendamic, on account of the peculiar background and
nature of various serious ailments, he was consistently advised not
to travel and stay in close proximity of Healthcare facilities in
 London for ongoing treatment and planned interventions which facts
are duly reflected in the Medical Reports, particularly reports dated
04th and 21st December 2019, 30th January 2020, 12th February 2020,
18th March 2020, 28th April 2020, 26th June 2020, 26th August 2020,
04th September 2020 and 28th January 2022. The said reports were
submitted in due course before the Hon,ble Lahore High Court
Lahore in terms of its order dated 16-11-2019 in writ petition No.
68815/2019. Copies of Medical Reports are attached herewith as
ANNEXURE-I/I-8.

c. That it is pertinent to mention here that all the above said reports
were filed before the Hon,ble Lahore High Court Lahore in writ
petition No. 68815/2019 which is still pending and the order dated
16.11.2019 is still intact and the same was never recalled or
modified, it was fixed once for hearing on 20.01.2020 on which date,
Learned Law Officer sought adjournment. It is pertinent to mention
here that both the Federal Government or the Provincial
Government despite being headed by an arch rival political party
never approached the Hon,ble Lahore High Court Lahore and
challenged the veracity of the above said reports being filed in due
course of time and duly reported on Media nor any move was made
to seek recalling or modification of the order dated 16.11.2019. Copy
of order sheet is attached herewith as ANNEXURE-J.

d. That on the face of the record, order dated 27-02-2020 by

Government of Punjab was passed without adequate opportunity of
hearing and judicious application of mind, rather, the same suffered
from extraneous considerations of political vendetta as the
Government in Punjab was headed by Pakistan Tahreek-e-Insaaf
whose Leaders have throughout been open in their expression
against the petitioner and his party; neither the reports of imminent
Doctors both foreign and local including Government appointed
team of Doctors nor Lab Reports and Medical Tests were considered,
rather, the same were not given any weight without any evidence to
the contrary.
e. That the order dated 27-02-2020 was prompted by malafide
intention as no effort was made to hold an inquiry into the then
Health status of the petitioner through the mechanism provided in
the undertaking forming part of order dated 16-11-2019 in writ
petition No. 68815/2019. Even the Periodic Medical Reports
submitted before the Hon,ble Lahore High Court Lahore were not
taken into account. On the face of the record, order dated 27.02.2020
was passed in a slipshod, whimsical and capricious manner.

f. That the order dated 27-02-2020 by the Government of Punjab was

also bad in law as neither the opinion of the Hon,ble Judge
Accountability Court nor the record of the case was requisitioned in
terms of section 401(2) Cr.P.C.

g. That it is a matter of public knowledge, that both the Federal

Government and Provincial Government were headed by Pakistan
Tahreek-e-Insaaf, and its Chairman was Mr. Imran Ahmad Khan Niazi
was Chief Executive / Prime Minister at the relevant time whose grudge
and animosity against the petitioner was a matter of public knowledge.
In this peculiar background with political connotations, petitioner’s
application was dismissed in an unjust and unfair manner actuated by
Political bias and malice.

h. That after a long delay on account of unforeseen circumstances

beyond human control such as Covid-19 Pendamic, and other
medical complications, the requisite procedure could only be carried
out during last November where after the petitioner had to undergo
for follow up examinations in June 2023 whereas the latest report by
his Doctor was issued on 01-10-2023, copies of the Medical Reports
and Clinical Tests have been submitted before the Hon,ble Lahore
High Court Lahore in writ petition No. 68815/2019. Attested copies
of the same are attached herewith as ANNEXURE-K.

i. That it is also a matter of public knowledge that the petitioner

having a background of a political leader of the Largest Political
Party having the honour of being three times Prime Minister was
constrained to limited public exposure and mobility, he could not
address any public meeting, rather, he was bound down to wear
 Mask throughout this time on account of the complicated nature of
ailments and compromised position of immunity.

j. That the petitioner is patriotic Pakistani and has great love and
affection with his homeland, he had not stayed away on his own
volition and has always been desirous of coming back to Pakistan to
play his role and to make his contribution towards her progression
but he was unable to do so on account of his health condition till the
completion of Medical procedures particularly in the background of
suffering of heart attack in incarceration at Adyala Jail and the then
treatment meted out to him.

k. That any hypothesis of deliberate abscondence is not reconcilable

with the petitioner’s conduct and track record which is an exemplary
one as he while being Prime Minister joined the Investigation before
JIT as and when required, volunteered to come back to Pakistan from
abroad to appear before the Trial Court and face the trial throughout,
filed a formal application for adjournment for pronouncement of
judgment in his presence which was dismissed and judgment of
conviction and sentence dated 06-07-2018 in ACR No. 20/2017 was
passed in his absence, however, in respect of rule of law, the
petitioner again came back from abroad with his daughter and
surrendered to custody and thereafter filed criminal appeal and
other petitions to seek legal remedies in due course.

l. That the petitioner came back to Pakistan along with his daughter
voluntarily in respect of the rule of law and surrendered to order of
imprisonment and thereafter sought bail upon suspension of
sentence in due course of law, he did not jump the concession of bail
and went abroad with the permission of the Court which permission
was never recalled.

m. That the above conduct of the petitioner is inconsistent with

hypothesis of any guilt, petitioner’s voluntary return to Pakistan to
face the trial and again after announcement of judgment of
conviction dated 06-07-2018 in ACR No. 20/2017 and his surrender
to due process of law are sufficient and self-explanatory of his
resolve for respect of rule of law.
n. That the judgment of acquittal dated 29-09-2022 in favour of the Co-
Convicts in Avenfield Reference (ACR No.20/2017) and Audio Cum
Video Leaks of the Hon,ble Judge Accountability Court (Muhammad
Arshad Malik Late) with forensic analysis go a long way to expose
that the filing of the references against the petitioner was prompted
by considerations of political engineering. Copy of the judgment
dated 29-09-2022 is attached herewith as ANNEXURE-L.

o. That the petitioner was earlier denied right of audience inter alia on
the grounds of issuance of non-bailable warrants of arrest issued
against him vide order dated 03-09-2020 in ACR No. 15/2020
passed by Hon,ble Judge Accountability Court No.1 Lahore and order
dated 09-09-2020 in ACR No. 06/2020 passed by Hon,ble
Accountability Court No.III, Islamabad declaring him as an
absconder; it is pertinent to mention here that the petitioner has
since been acquitted in ACR No. 15/2019 vide order dated
24.06.2023 whereas operation of warrant of arrest against him in
ACR No. 06/2020 has since been suspended by the Learned
Accountability Court Islamabad. Copies of the orders are attached
herewith as ANNEXURE-M,N.

p. That although the petitioner has not fully recovered yet and he is not
in ideal state of health yet, at this juncture when the Country is faced
with worst ever crises of Economy and other fronts, the petitioner
has decided to come back to homeland.

q. That the petitioner is entitled to the relief at the anvil of a number of

fundamental rights including but not limited to right of access to
justice, treatment in accordance with law, life, liberty, dignity, due
process of law, fair trial and equal protection of law.

r. That the petitioner shall suffer irreparably whereas no prejudice

shall occur to the cause of the prosecution if the petitioner is granted
protective bail to enable him to avail legal remedies permissible
under the law in terms of the order dated 23-06-2021 passed by this
Hon,ble Court.
PRAYER:-

In view of the submission made above it is humbly prayed as

under:-

i. Above noted Crl. Appeal No. 121/2018 may kindly be resurrected /

restored to its original position along with all interim, incidental and
ancillary orders connected therewith and the same may kindly
decided on merits in accordance with law in the interest of justice.

ii. Any other relief deemed appropriate in the peculiar circumstances

of the case be also awarded.

Petitioner / Appellant

Through

[AZAM NAZEER TARAR] [MUHAMMAD AMJAD PERVAIZ]

Advocate Advocate
Supreme Court of Pakistan Supreme Court of Pakistan
C.C. NO. P-LH-10025 C.C. NO. P-LH-13490