IN THE COURT OF SESSIONS JUDGE, LAHORE.
B.A.No.______________/2024
Usman Sarwar son of Muhammad Sarwar resident of House No.425,
Model Town Extension, Lahore.
PETITIONER
VERSUS
THE STATE.
RESPONDENT
CASE FIR NO: 2440/24 Dated: 10.10.2024
OFFENCE U/S: 406 PPC.
POLICE STATION: Faisal Town, Lahore.
APPLICATION UNDER SECTION 498 Cr.P.C. FOR THE GRANT OF
PRE-ARREST BAIL.
Respectfully sheweth:-
1. That the petitioner has got apprehension of arrest in the above
titled case, which has been registered at the instance of
complainant, who intentionally and deliberately concealed the
actual and true facts for ulterior motives. For detailed
Prosecution Story copy of FIR is attached herewith as
ANNEXURE-A.
2. That the petitioner being quite innocent, surrenders himself
before the Honorable court and seeks his pre-arrest bail inter-
alia on the following:-
GROUNDS
a) That the petitioner is absolutely innocent and has falsely been
implicated in this false case with the malafide intention of the
complainant and active connivance of the local police.
b) That from bare perusal of the contents of the FIR it is quite clear
that the ingredients to constitute the alleged offence are
missing and the alleged offence is not constituted.
c) That the local police is chasing the petitioner for his imminent
arrest, if he is arrested, he will be humiliated in the eyes of
relatives, friends and society.
d) That the petitioner is quite innocent, law abiding citizen and has
nothing to do with the alleged offence. That there is no
apprehension of the petitioners’ abscondance or tempering
with the evidence of the prosecution, if he is granted bail.
e) That the petitioner is previously non-convicted and is clean
antecedent in his character and role.
f) That the complainant just to tease, harass, humiliate and
blackmail the petitioner for ulterior motives, concocted a false
story and involved the petitioner in this false case by joining
hands with local police, which needs further probe and inquiry,
entitling the petitioner for concession of bail as a matter of
right.
g) That there is an inordinate and unexplained delay in lodging FIR
which makes the case highly doubtful and entitles the petitioner
for grant of bail. Furthermore even from the contents of the FIR
no offence is made out.
h) That there is no direct or indirect material available with the
prosecution to connect the petitioner with the commission of
the alleged offence.
i) That the petitioner is ready to abide by the conditions of bail to
be imposed by the honorable court.
j) That the other grounds available to the petitioner shall be
submitted at the time of arguments.
k) That the petitioner is ready to furnish surety to the satisfaction
of the Honourable court for his personal appearance before the
Honorable court and even during trial.
PRAYER:-
Under these circumstances, it is, therefore, most respectfully
prayed that instant application may kindly be accepted and
petitioner may kindly be granted pre-arrest bail till the final
decision of this case.
It is further prayed that ad-interim bail may kindly be
granted in favor of petitioner till the final disposal of instant
application.
PETITIONER
Through:
FARRUKH AMIN RANA
Advocate High Court,
MOHSIN QAMAR RANA
SHAKEEL AHMAD JOIYA
Advocate High Court Advocate High Court
5-link Fareed Kot Road,Lahore.
Dated:17.10.2024
CERTIFICATE
As per instructions this is 1st petition on the subject before the
Honourable court.
ADVOCATE
IN THE COURT OF SESSIONS JUDGE, LAHORE.
B.A.No.______________/2024
Usman Sarwar ….Vs…The State.
(APPLICATION UNDER SECTION 498 Cr.P.C. FOR THE GRANT OF PRE-ARREST BAIL.)
AFFIDAVIT
Of Usman Sarwar son of Muhammad Sarwar resident of House
No.425, Model Town Extension, Lahore.
I, the above named deponents do hereby solemnly affirm and
declare as under:-
That the contents of accompanying bail petition are correct
and true to the best of my knowledge and belief, nothing
incriminating has been concealed therein.
DEPONENT
VERIFICATION:
Verified on oath at Lahore on 17.10.2024 that
the contents of this affidavit are correct and true to
the best of my knowledge and belief
DEPONENT
