Before judicial Magistrate Peshawar

Ali s/o Khaista Gul R/o Peshawar presently prisoned in district Jail Peshawar ..... Accused/ Petitioner

VS

THE State .......................................................................Respondent

FIR No. 270 Dated 26/03/2024

U/S 337F(2).

P.S SGH.

Petition for grant of post-arrest bail to the accused petition in above mention case FIR till final disposal
of the case .

Humbly submitted:

That the accused petitioner got arrested in above mention case FIR for detail prosecution story . Copy of
FIR is annexed as annexure A.

That the accused petitioner seeks the concession of post arrest bail from this hon'ble court on the
following grounds , interalia.

GROUNDS:

1. That the local police have charged the Accused /petitioner with malafide intention and ulterior
motive .
2. That there is no prosecutable evidence available before this learned court which can be based
for the prosecution of the alleged stance of this local police .
3. That the Accused/Petitioner is not involved in beating the Complainant .

4. That the accused petitioner has no previous history in such like offences nor than any possibility
of the abscondence of the accused if hon'ble court would grant the concession of bail to the
accused petitioner.

5. That the accused petitioner is ready to furnish reliable surety bond for the entire satisfaction of
this learned court

6. That the grant of bail in such like offences is rule while refusal is an exception .
 7. That the petitioner is innocent and there is no useful purpose to keep the accused behind the
bars.

8. That the offense is not fallen in Prohibitory class of 497 CrPC.

9. That the petitioner reserves the light to raise further grounds at the time of arguments .

It is therefore humbly prayed that the Accused may be grant post arrest bail till final disposal of the case.

Petitioner

through

Muhammad Osama

And

Irfan Ullah

Advocates Peshawar

Dated / /2024.

Affidavit:

As per the information furnish by my client/petitioner no bail petition has been file earlier and the
contents of the instant petition is correct to the best of my knowledge .