IN THE COURT OF JUDICIAL MAGISTRATE CHAMAN

Amir Muhammad S/o Abdul Zahir

By caste Achakzai Adozai
R/o Toba Dobandi District Killa Abdullah
Presently confined in Sub Jail Chaman

(Accused/Applicant)

VERSUS

The State
Respondent

OFFENCE UNDER SECTION 15-E THE

BALOCHISTAN ARMS ACT 2022 (AMENDED)

APPLICATION UNDER SECTION 497 Cr.P.C.

FOR GRANT OF BAIL

The applicant/accused named above most

respectfully submits as under:-

1. That in pursuance of FIR No.24/2023 lodged by one

complainant Ubaidullah in official capacity against the

accused/applicant under the above mentioned section in

Levies Thana Dobandi, whereas, the applicant/accused

has been arrested. For perusal of facts copy of FIR is

filed and marked as annexure-“A”.

Being highly aggrieved of his detention the

accused/applicant being behind the bar prefers to

 proceed through this application under the following

amongst other grounds:-

G R O U N D S:-

a)That the accused/applicant is innocent of the charge and

they did not commit any offence whatsoever in nature

and wrongly been roped in the instant FIR by the

complainant just to blackmail and harass him, therefore,

he is entitled to be released on bail.

b)That the alleged section is not attracted to extent of

applicant/accused and the same is bailable in nature

triable by this honourable court and same does not fall

within the ambit of prohibitory clause, on this score, he is

entitled to be released on bail.

c)That nothing has been recovered from the personal

possession of applicant/accused despite the judicial

remand and no specific role has been attributed to

accused/applicant by the complainant and the

complainant with the connivance of levies Officials

involved him in the instant case/FIR, therefore, the

accused/applicant is entitled to be released on bail.

d)That the instant FIR has been lodged after thought and

preplanned with unexplained delay of 03 hours since

registration of FIR, therefore, the accused/applicant is

liable to be enlarged on bail.

 e)That no independent eye witness available on the face of

record and he has been shifted to judicial lockup. Further

accused/applicant is prepared to furnish any kind of

solvent surety bonds to the entire satisfaction of this

Honorable court, if this Hon’able court allowed the

application in his favour.

f)That the case is one of further inquiry, so in such

circumstances, the prosecution case creates doubts

within the case in question which rises benefits of doubts

shall go in favour of applicant/accused, on this sole

ground, he is entitled to be released bail.

g)That the accused/applicant through counsel reserves

further rights of arguments on each and every point of

law at the time of hearing of the instant bail application

being filed.

PRAYER:

It is therefore, respectfully prayed that keeping in view of the

facts and circumstances of the case, the accused/applicant may

kindly be released on bail in the interest of justice and fair play.

Dated: ____________/2023 Accused/Applicant

Through Counsel

CERTIFICATE:

It is certified that prior to this application no other

application of the same matter has ever been moved before any

competent court of law except the present one.

Dated: _____________/2023 Accused/Applicant
Through Counsel