IN THE COURT OF ILLAQA MAGISTRATE POLICE

STATION MIRANPUR, MAILSI

Muhammad Azhar S/O Muhammad Mumtaz Cast Wadd

Residence of Bakhshu Wad Tehsil Mailsi District Vehari
.......Petitioner

VERSUS
1.The State
2. Mukhtiar Hussain S/O M. Akram R.O Mitha Asar

...…Respondent

CASE FIR NO: 452/23, Dated; 16.11.2023

OFFENCE U/S: 380/337-H2, 427, 452, 324/411,
148,149 PPC
POLICE STATION: City Mailsi

PETITION U/S 497 Cr.P.C FOR GRANT OF

POST-ARREST BAIL TO THE PETITIONER
HUMBLY SHEWETH:
1. T h a t t h e a b o v e m e n t i o n e d c a s e h a s b e e n r e g i s t e r e d a t
the instance of the complainant without nominated any
person and now false and fabricated allegation levelled
by the concerned I.O against the petitioner and the
petitioner after formal investigation sent to judicial
lock-up. For further detail copy of FIR is attached
herewith. Annexure.......“A”.

G R O U N D S:
a. T h a t t h e p e t i t i o n e r i s q u i t e i n n o c e n t i n t h i s
case and has nothing to do with the commission
of alleged offence as mentioned in the FIR .
b. That there is unexplained delay of 11-days in
lodging the FIR which shows that the said FIR
has been lodged after though and consultation,
which makes the story of the prosecution highly
doubtful.
 c. That infect complainant and other also attack
and injured the petitioner in this regard a FIR
No. 451/23 registered against the complainant.
For further detail copy of FIR is attached
herewith. Annexure.......“A”.
d. That most of the accused persons are declared
innocent during course of investigation.
e. T h a t t h e r e i s n o d i r e c t o r i n d i r e c t e v i d e n c e
available on record to connect the petitioner
with the commission of offence.
f. That there is no any recovery effected from the
petitioner if any shows is false and fabricated.
g. That case of the petitioner is one of further
inquiry and probe.
h. That the petitioner is behind the bars, since his
arrest, investigation of the case has been
completed and the petitioner is no more
required for the purpose of any further
investigation.
i. That there is no useful purpose would be served
to the State by keeping the petitioner behind
the bars for an indefinite period.
j. That the petitioner is respectable citizen of the
country and previously non-convicted and non-
record holder.
k. That there is no apprehension of absconding or
tempering with the prosecution evidence, if the
petitioner is released on post arrest bail.
l. That the petitioner is ready to furnish bail bond
to entire satisfaction of this Honourable Court
in case he fortunate enough to have relief
prayed for.
m. That further grounds will be agitated at the
time of final arguments.
PRAYER:
In view of above submissions, it is,
humbly prayed that post-arrest bail may
kindly be granted to the petitioner till the
final decision of this case in the inter est
of law and justice.

PETITIONER
Through :
(Muhammad Akram Khan) Advocate High Court