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    BBA Haroon Etc

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    kickoffkings110

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    © All Rights Reserved
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    BBA Haroon Etc

    Uploaded by

    kickoffkings110
    9 views4 pages

    Original Title

    BBA Haroon etc

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    © © All Rights Reserved

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    Copyright:

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    Download as doc, pdf, or txt
    9 views4 pages

    BBA Haroon Etc

    Uploaded by

    kickoffkings110

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 4

    IN THE COURT OF LEARNED SESSIONS JUDGE,

    RAWALPINDI

    In the matter of:

    Note: A 1. Jameel Akhtar son of Fazal Hussain


    connected bail 2. Haroon.
    petition is
    pending 3. Umer Sons of Muhammad Javed.
    adjudication All residents of Kanoha, P.O Khas, Tehsil Kallar
    before Ch. Syedan, District Rawalpindi.
    Aurangzeb,
    Learned ASJ,
    Rawalpindi.for …Petitioners
    27-04-2011 for Versus
    confirmation of
    bail.
    Counsel The State
    …Respondent

    CASE FIR NO. 124 DATED 11-04-2011, OFFENCES


    UNDER SECTION 337FV/337AI/337LII/147/149 PPC
    REGISTERED WITH P.S. KALLAR SYEDAN,
    RAWALPINDI.

    PETITION FOR BAIL BEFORE ARREST UNDER SECTION


    498 Cr.P.C.

    Respectfully Sheweth,

    1. That the petitioners are accused in the above

    mentioned case and it is alleged against them that

    they have committed the aforementioned offences.

    2. That the allegations against the accused/ petitioner

    are false, frivolous, baseless, concocted in nature and

    there is no truth in the prosecution story.

    3. That the compromise between the parties has been

    affected and the complainant of the instant case


    already sworn an affidavit in this regard. (Copy is

    attached herewith).

    4. That the instant case is result of malafide and ulterior

    motives on the part of police and the case of the

    petitioners brings into further enquiry and probe

    besides the fact that the petitioners are totally

    innocent and he has nothing to do with the said

    alleged offences.

    5. That none of the offences are attracted against the

    accused / petitioners.

    6. That the local police is after the arrest of the

    petitioners on the basis of malice and some ulterior

    motives, hence the petitioner is entitled for the grant

    of pre arrest bail.

    7. That the petitioner is previously non-convict.

    8. That the punishment of the offence does not fall within

    the prohibitory clause of Section 497 Cr.P.C and in

    such like cases bail is a rule and refusal is an

    exception.
    9. That the petitioner is ready to furnish solvent surety

    bond to the satisfaction of this Honourable Court.

    10. That the petitioner is law abiding citizen and having

    unblemished record of his life.

    11. That the petitioner is ready to join police investigation

    when and where ordered by this Honourable Court.

    In view of above, it is, therefore, respectfully


    prayed that the instant petition may magnanimously
    be accepted and petitioner be admitted to pre arrest
    bail till the final decision of the case in the extreme
    interest of the justice.

    Ad-interim bail may also be granted.

    Petitioners
    Through

    Raja Muhammad Taj


    Advocate High Court

    Raja ___________
    Advocate High Court

    Certificate:-
    As per instruction received from the petitioner, this is the
    first bail before arrest ever moved before this Honourable
    Court.

    Counsel
    IN THE COURT OF LEARNED SESSIONS JUDGE,
    RAWALPINDI

    Haroon …Petitioner
    Versus
    The State …Respondent

    CASE FIR NO. 124 DATED 11-04-2011, OFFENCES


    UNDER SECTION 337FV/337AI/337LII/147/149 PPC
    REGISTERED WITH P.S. KALLAR SYEDAN,
    RAWALPINDI.

    PETITION FOR BAIL BEFORE ARREST UNDER SECTION


    498 Cr.P.C.

    AFFIDAVIT

    That I, Haroon son of Muhammad Javed resident of Kanoha,


    P.O Khas, Tehsil Kallar Syedan, District Rawalpindi do
    hereby solemnly declare as under:-

    That the contents of attached BAIL APPLICATION are true


    and correct to the best of my knowledge and belief and
    nothing material has been concealed therefrom.

    Deponent

    Verification;
    Verified on oath at Rawalpindi on this ______day of April
    2011 that the deposition is true and correct to the best of
    my knowledge and belief and nothing material has been
    concealed therefrom.

    Deponent

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