IN THE COURT OF HONORABLE SESSION’S

JUDGE, ISLAMABAD.
Bail Application No._______/2023

Abdullah S/o Abdul Shakoor R/o Muhala Landi Khel Armar Miana, tehsil
and district Peshawar (Presently confined in Adyala Jail Rawalpindi)

..................…. Accused/Petitioner

Versus

The State ………………….Respondent

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Case FIR No. 359/23 Dated 30.10.2023

U/S- 9(1)6b (CNSA) Police Station Sihala,
Islamabad.
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APPLICATION U/S 497 Cr.P.C FOR THE RELEASE

OF ACCUSED/ PETITIONER ON BAIL TILL THE
FINAL DISPOSAL OF THE INSTANT CASE.
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Respectfully Sheweth.

1. That the accused-petitioner has been involved by

the local police malafidely in the above mentioned
case and he is behind the bars since his arrest.
(Copy of the FIR is attached herewith).

2. That the accused-petitioner approaches this

Honourable Court for his release on bail, on the
following grounds inter-alia.

GROUNDS.

A. That nothing has been recovered from the

conscious possession of the accused-petitioner and
the recovery shown by the police is a manipulated
and concocted one.
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B. That petitioner has been dragged into a false,

frivolous and vexatious FIR and petitioner
has no concern whatsoever with the alleged
offence.

C. That there is no ocular or circumstantial evidence

available on file, which can connect the accused-
petitioner with the commission of crime.

D. That the accused-petitioner is ready to furnish

reliable sureties to the satisfaction of this
Honourable Court if released on bail.

E. That the accused-petitioner craves the permission

of this Honourable court to raise any other ground at
the time of arguments.

PRAYER:-

It is, therefore, most humbly prayed that on

acceptance of this application the accused-petitioner may
kindly be released on bail till the final decision of the
instant case.
Accused/Petitioner

Through:

MUHAMMAD IFTIKHAR KHAN

Advocate Islamabad

C E R T I F I C A T E:

As per instructions of my client this is the First bail application

and no other bail petition is pending before any court on behalf
accused/ petitioner.

ADVOCATE