IN THE COURT OF DISTRICT SESSION JUDGE KARACHI, SOUTH

Mohsin S/o Allah Dita

Muslim, adult, R/o house No 2944/290,
Street No 2, Block -5, Shreen Jinnah Colony
Karachi ........... Accused

Versus

The State ........... Respondent

FIR No. 669/2023

U/s: 324/34 PPC
P.S.: B o a t B a s i n

BAIL AFTER ARREST APPLICATION U/S 497 Cr.P.C

It is prayed on behalf of the above named accused that this Honourable Court may be pleased to grant bail to
the above named Accused, in the case vide F.I.R No. 669/2022 on consideration of the following facts and
grounds, Inter-alia, as under.

Facts
The brief facts of the case are as follows: SIP Zafar Hussain was performing his duties as an officer when
Haseena Bibi approached and meticulously recorded her statement under Section 154 CRPC. Copies of this
statement are currently in the possession of the duty officer at PS Boat Basin. On the 23rd of November
2023, Haseena Bibi, W/o of (late) Huzoor Baksh, residing at House No. 1119, Street No. 2, Block No. 5,
near Medina Masjid, Clifton, Sikandarabad, Karachi, CNIC 31301-1143386-8, and the phone number 0303-
2118274, informed me that she resides at the aforementioned address and is employed as a labour worker.
On the mentioned date at around 1:50 PM, as I was returning from work and approaching Street No. 2, I saw
my relatives (1) Irfan S/o Allah Dita, (2) Muhammad Aslam S/o Khuda Baksh, and (3) Mohsin S/o Allah
Dita, Allah Dita S/o Allah Dita, approaching me along with three unidentified individuals on motorcycles.
They demanded the withdrawal of the FIR lodged. In response, I refused to withdraw my FIR, stating they
could do whatever they wanted. This refusal led to a serious situation where they turned violent and started
abusing me. At the same time, Mohsin S/o Allah Dita took out a pistol and fired at me, which hit my left leg
and caused injury. At the same time, People from the neighborhood came to me and those individuals ran
away. Now I declare that those people along with three unknown people came to me intending to kill me by
shooting there. Therefore I want them to be prosecuted.

Grounds
Hence this Bail application is preferred on the consideration of the following grounds:

1. That the present application under section 497 of the Code of Criminal Procedure 1973 is
being filed by the Accused for seeking a grant of bail in FIR No. 669/2022 registered at
Police Station Boat Basin.

2. That the Accused is innocent and is being falsely implicated by the complainant due to a
previous enmity between both parties
 3. That the story narrated by the Complainant in FIR is false based on misrepresentation and
misinterpretation. As per the status of the facts of the case, the pistol is not recovered.
4. That the complainant has not mentioned any reason for the claim of an attempt to murder
on the accused.

5. It is further submitted that in the aforesaid case, no identification parade has taken place
which further creates doubts in the story of the Prosecution.

6. That the Police Officials have submitted the challan in the aforesaid case and the Accused
is not required to the police for investigation.

7. That the contents of FIR are false, and baseless and do not constitute any ground for
making out any case against Applicant/Accused for committing any of the offence
mentioned in FIR, since there is no exits of reasonable grounds to believe that Accused is
guilty.

8. That, any other grounds will be raised/urged at the time of hearing on the Bail Application
with the kind permission of the Hon’ble Court.

That the accused is innocent and no useful purpose would be served by keeping him under custody
and this is a fit case for grant of bail. (It would be pertinent to mention the stage of investigation or
in case the charge sheet has been filed, whether charges have been imposed, evidence has started,
the length of the list of witnesses cited by the prosecution, etc. as these would all be mitigating
circumstances).

That the accused 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.

That the Applicant is a law-abiding citizen and not a previous convict (as instructed) nor they are
habitual, hardened, or desperate criminals and there is no chance of apprehension of tampering
with Post Arrest Bail.

That it is respectfully submitted before this Honourable court to grant a Bail of the Accused and it
will be in the greater interest of justice if the application is allowed.
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. 669/2023, for the offence of 324-34 at
Police Station Boat Basin.

Pass any other such order as this Honorable Court may deem fit and proper in the interest of
justice.

Advocate
For the Accused/applicant.

Place: Dated: