IN THE COURT OF ANTI TERRORISM COURT III, DISTRICT MALAKAND CAMP

COURT AT BATKHELA

Cr. Misc. (BBA) No …………………/2023

1. Mr.Ikram Muhammad S/O Musafar Khan R/O Tawheed abad

bala Batkhela Tehsil Batkhela, District Malakand.
2. Gul Kareem S/O Abdul Sattar R/O Pir Khushaal baba
TehsilBatkhela, District Malakand.
………………………. Accuseds/Petitioners

VERSUS

1. The State
2. Mr. NaikRahman PS Batkhela
……..…………………… Respondents

CASE FIR No.310. Dated: 11.09.2023

Charged U/S 324, 353, 186, 189, 141, 151, 147, 148, 143, 149, 188
PPC R/W 7-ATA
Police Station: Batkhela District Malakand

APPLICATION 498 CR.PC FOR GRANT OF PRE ARREST BAIL WITH AD

INTERM BAIL TO THE ACCUSED / PETITIONER, TILL THE FINAL
DISPOSAL OF THE CASE

Respectfully Sheweth:
1. That the accused/petitioners learned from reliable sources that
they been charged in the above noted FIR and local police is bent
upon to arrest him. (Copy of FIR attached)
2. Thatthe accused/petitioners now seeks pre arrest bail for the
following amongst other grounds:
GROUNDS:
A. That the accused/petitioners are innocent and has falsely and malafide
been involved in the instant case by the complainant without any cogent
and corroborative evidence and rather with malafide intention and
ulterior motives.
 B. That the accused/petitioners are law abiding citizens of Pakistan and
never can think to commit such like offences.
C. That the accused/petitioners were not present at the place of
occurrence on the time of occurrence.
D. That the accused/petitioners has no criminal history therefor, Theyare
entitled for concession of pre arrest bail.
E. That the accused/petitioners are ready to join investigation when and
where he was required.
F. That any other ground will be raised at the time of arguments with the
prior permission of this Hon’ble Court.

It is, therefore, most humbly prayed that by accepting this application,

the accused/petitioners may be granted pre arrest bail along with ad-interim bail,
till the final disposal of their case.

Accused/Petitioner
Through
Nasar Raza
Advocate
Dated: 27/11/2023
CERTIFICATE:
As per information supplied to me by my clients that no such like application
has earlier been filed before any forum for the present accused/petitioners.

DEPONENT
Ikram Muhammad S/O Musafar Khan
&
Gul Kareem S/O Abdul sattar
 IN THE COURT OF ANTI TERRORISM Court III, DISTRICT MALAKAND CAMP
COURT AT BATKHELA

Cr. Misc. (BBA) No …………………/2023

1. Mr.Ikram Muhammad S/O Musafar Khan R/O Tawheed abad
bala Batkhela Tehsil Batkhela, District Malakand.
2. Gul Kareem S/O Abdul sattar R/O Pir Khushaal baba
TehsilBatkhela, District Malakand.

………………………. Accused/Petitioners
VERSUS
1. The State
2. Mr. Naik Rahman Post Commander Batkhela……… Respondents

AFFIDAVIT

We, Mr.Ikram Muhammad S/O Musafar Khan R/O Tawheed abad

bala Batkhela Tehsil Batkhela, District Malakand &Gul Kareem S/O
Abdul sattar R/O Pir Khushaal baba TehsilBatkhela, District
Malakand hereby solemnly affirm and declare on oath that the
contents of the accompanying BBA petition are true and correct to
the best of our knowledge and belief and nothing has been
concealed from this Hon’ble Court.

DEPONENTS
Ikram Muhammad S/O Musafar Khan
& Gul Kareem S/O Abdul sattar