Bail Before Arrest Format (General) to Session Court (Sample )

IN THE COURT OF SESSIONS JUDGE RAWALPINDI

 

 

 

 

 

 

Zafran Khan son of Muhammad Zaman resident of House No. 1, Street No. 5, Mohallah Shah Chan Chiragh, Rawalpindi 

Petitioner

Versus

The State   

Respondent

         

PRE ARREST BAIL PETITION U/S 498 CR.PC, IN CASE FIR NO 577 DATED 18-06-2016 OFFENCE UNDER SECTION 337F(II) PPC, P.S WARIS KHAN, RAWALPINDI 

 

Respectfully Sheweth:

1. That the story narrated in the FIR is false, frivolous, baseless and concocted. 
2. That the petitioner is innocent and has not committed the offence mentioned in the FIR. 
3. That the petitioner has been involved in the instant FIR with malafide intentions and ulterior motives. 
4. That the offences mentioned in the FIR do not fall within the ambit of prohibitory clause of section 497 Cr.PC.
5. That there are grounds for further inquiry into the guilt of petitioner which makes out the case to be one of further inquiry under section 497 (2) Cr.PC.
6. That there is no apprehension of abscondence of the petitioner or to temper with the prosecution evidence.
7. That the Petitioner is previously non-convict by any court of law.
8. That the petitioner would suffer an irreparable loss, if arrested by the police.
9. That the petitioner is ready to join the police investigation when and where required by the police.  

PRAYER  

Under the circumstances, stated above, it is therefore humbly prayed that the instant petition may kindly be accepted and the petitioner may kindly be granted bail before arrest. 

Ad interim bail is also prayed for. 

 

Petitioner

 

Through

 

Mehmood Alam 

Advocate High Court 

 

CERTIFICATE 

As per instructions received, it is certified that this is the first petition for bail before arrest being moved before this Honorable Court. 

Counsel 

 

 

 

 

 

 

 

IN THE COURT OF SESSIONS JUDGE RAWALPINDI

 

Zafran Khan          Versus        The state

         

PRE ARREST BAIL PETITION U/S 498 CR.PC, IN CASE FIR NO 577 DATED 18-06-2016 OFFENCE UNDER SECTION 337F(II) PPC, P.S WARIS KHAN, RAWALPINDI 

 

AFFIDAVIT 

I, Zafran Khan son of Muhammad Zaman resident of House No. 1, Street No. 5, Mohallah Shah Chan Chiragh, Rawalpindi do hereby solemnly affirm and declare as under:

 

That the contents of the accompanying petition are true and correct to the best of my knowledge and belief and nothing has been concealed there from.

                                                                                            Deponent

                                                         

Verified on oath at Rawalpindi on this _____day of July, 2022 that the contents of the above said affidavit are true and correct.

                                                                                            Deponent