IN THE LAHORE HIGH COURT, LAHORE.

Crl. Misc: No.__________/B/2012

Muhammad Haroon son of Tufail Muhammad caste Bloach r/o 36-A/4L Nizam Wala Tehsil & District Okara. (Now confined in Central Jail, Sahiwal)

...PetitionerVERSUS

1. The State.

2. Muhammad Saeed son of Ahmed Yar Caste Baloch r/o 36-A/4L, Nizam Wala Tehsil & District Okara.

…..Respondents

Case FIR No. 29/12Dated: 01.03.2012Offence U/s: 324 PPC Police Station:Shah Bhore District Okara.

PETITION UNDER SECTION 497 CR.P.C FOR GRANT OF POST ARREST BAIL TILL THE FINAL DISPOSAL OF THE MAIN CASE.

Respectfully Sheweth:

1. That the above said case was registered against the

petitioner on the statement of (Complainant)/

respondent No.2, alleging therein that on 29.02.2012

at about 6.30 am present accused petitioner while

armed with deadly weapons attacked the complainant

and made straight fire at him with intention to murder

the complainant which hit on left thigh of the

complainant. Hence the titled case was registered. The

detailed story of prosecution FIR and MLR are attached

as Annexure “A & B”.

2. That the petitioner filed an application for grant of post

arrest bail in the court of learned Magistrate Section

30, Okara which was dismissed on 29.03.2012. Copy of

bail application and order is attached as Annexure “C

& D”.

3. That thereafter, the petitioner filed an bail application

before Sessions Judge, Okara which was entrusted for

disposal to the file of Mr. Malik Muhammad Iqbal,

learned ASJ, Okara which was also dismissed vide his

order dated 09.05.2012. Copy of bail petition along

with the said dismissal order is enclosed herewith as

Annexure “E & F” .

3. That the above said case against the petitioner is

absolutely wrong, false, concocted, afterthought,

based on malafide and misrepresentation and the

petitioner has been made a victim of fabricated and

forged evidence despite his complete innocence and

seeks his post arrest bail inter alia on the following:

GROUNDS:

a). That the accused/petitioner is absolutely

innocent and committed no offence whatsoever.

The said FIR was lodged only to harass and

humiliate the petitioner.

b). That prior to this a case FIR No.365/2007 dated

03.10.2007 Offence U/s 365-B PPC P.s Shah

Bhore district Okara was registered against the

present petitioner on the ground of enticing

away the niece of the complainant which was

cancelled on the statement of the abductee/

niece of the complainant. Copy of FIR No.365/07

is annexed as Annexure-G.

c). That actually the niece of the complainant was

contracted marriage with the petitioner without

the consent of her parents and present

complainant and the spouses are living happily

and three children born during this wedlock but

the complainant has previous enmity due to the

above said marriage and involved the petitioner

due to this reason.

c). That during the course of investigation it has

been found that the petitioner is empty handed

and not made any fire to the complainant but he

was only present at the place of occurrence.

d). That the investigation of this case has been

completed and the accused/petitioner has been

sent to judicial lock-up and he is no more

required for further investigation by the local

police and their further detention will not serve

any fruitful purposes and bail should not be

withheld as punishment.

e). That nothing has been recovered from the

possession of the petitioner.

f). That the petitioner is behind the bar and no more

required or not previous record holder therefore,

the petitioner is fall category of further inquiry.

Relied upon PCr.L.J 2010 Page 1810, PLD 1995 SC

Page 34.

g). That there is no chance of accused/petitioner

abcondance and tempering with the prosecution

evidence if he be released on bail.

h). That the petitioner is ready to furnish surety

bonds for the entire satisfaction of this Hon’ble

Court if he released on bail till the final disposal

of the main case.

i). That further more available grounds will be

agitated at the time of arguments in favour of

the present petitioner.

PRAYER:

Under the circumstances and facts

discussed above it is, most humbly and respectfully

prayed that the petition may kindly be accepted and

the petitioner may very graciously be granted post

arrest bail till the final disposal of the main case.

Petitioner

Through:

M. RAMZAN NAZEER DHUDDIAdvocate High Court

CC No.PLH-42288

GHAZANFAR HUSSAIN KAMRAN Advocate High CourtCC No.PKS-42286

Office # 6, (basement), Aftab Tower, 16-Syed Mouj Darya

Road, Lahore.

CERTIFICATE:

As per instruction of the petitioner this is the 1st petition on the subject matter.

ADVOCATE

IN THE LAHORE HIGH COURT, LAHORE.

Crl. Misc:____________/B/2012

Muhammad Saif Vs. The State etc.

I N D E X

Sr.

No.

Description of Documents Dated Pages

1. Grounds of Petition 20.07.12 1-5

2. Annexure “A” Certified copy of FIRAlongwith its better copy.

1.03.12 6

3. Annexure “B” Copy of MLC 29.02.12 7

4. Annexure-C & D Copies of Bail petition with order of learned Magistrate

29.03.12 8-11

5. Annexure “E & F” Copies of bail petition And order of ASJ.

09.05.12 12-14

6. Annexure-G Copy of FIR no.365/2007 03.10.07 15

7. Power of Attorney

Petitioner

Through:

M. RAMZAN NAZEER DHUDDIAdvocate High Court

CC No.PLH-42288

GHAZANFAR HUSSAIN KAMRAN Advocate High CourtCC No.PKS-42286

Office # 6, (basement), Aftab Tower, 16-Syed Mouj Darya

Road, Lahore.

CC PGW-18925

IN THE LAHORE HIGH COURT, LAHORE.

Crl. Misc:____________/B/2011

Muhammad Waseem Vs. The State etc.

I N D E X

Sr. No. Description of Documents Dated Pages

1. Grounds of Petition 1-4

2. Annexure “A” Certified copy of FIRAlongwith its better copy.

5

3. Annexure “A” Certified copy of Order Passed by ASJ, Gujranwala.

6-9

4. Vaklatnama 10

Petitioner

Through:

Ch. Naveed Akhtar Bhatti Advocate High Court16 & 17, Justice Din Muhammad Block, District Courts, Gujranwala. CC PGW-18925

IN THE LAHORE HIGH COURT, LAHORE.

Crl. Misc: No.__________/B/2012

Muhammad Ashfiq etc. Vs. The State etc.

APPLCIAITON U/S 498 CR.P.C FOR THE GRANT OF PRE ARREST BAIL TILL THE FINAL DISPOSAL OF MAIN CASE.

Affidavit of Muhammad Ashfaqq s/o Nazir Ahmad Caste Arain r/o village Aroop, Gujranwala.

I, the above named deponent do hereby solemnly affirm and declare as under:

1. That the local police has been registered the above captioned

case against the peititoner and want to arrest the petitioner in

the above case is concocted one.

2. That is to certify that this is the 1st application of grant of pre-

arrest bail on the behalf of the petitioner in this Hon’ble Court

on the subject matter earlier application for getting the said

relief was file in the Session Court that learned Court of ASJ,

Gujranwala was pleased to dismiss the pre arrest bail of the

accused petitioner on 10.07.2012.

3. That the story setup in the crime report is vague and without

any basis and the same is neither plausible, tenable and

acceptable nor is the same appeal able to any reason or logic.

4. That the bail petition of co-accused Saif Ullah Sakar had been

granted by the learned Judicial Magistrate dated 02.07.2012

and the impugned order is attached.

5. That accused petitioner has been wrongly entangled in this

case seeks the concession of pre arrest bail on the following

inter alia amongst other

Grounds

a).That the petitioners have no nexus with the commission of

offence as will as no role was attributed to the petitioners

according to complaint petitioners were the implicated

above mentioned case due to malafidely intention.

b). That the offence U/s 420, 471 are bailable and offence U/s

468 PPC did not fall with the ambit of prohibitory clause,

prohibitory clause means bail no jail.

c). That no offence had been made out against the petitioners

because the petitioners are not the beneficiaries of the

agreement, petitioners are only the marginal witnesses and

involved in the above mentioned case due to malafide

intention on the part of police as well as complainant.

d). That the FIR was lodged after institution of civil suit and

prima facie matter had been converted with malafide

intention into criminal litigation.

e).That the petitioner/accused is quiet innocent and has

nothing to do with the alleged offence as narrated in the

FIR.

f). That the complainant got registered a false and

fabricated case against the petitioner/accused with

the ulterior motive and malafide intention.

g). That intended arrest of petitioner/accused in these

circumstances, would not serve any purpose or

advance the case of prosecution, except his

humiliation and harassment at the hand of the

Police-----Refusal of pre-arrest bail in the above

mentioned case would tantamount to punishing

accused in advance, bail before arrest was meant to

protect the innocent citizen in the event of their

involvements in criminal cases with the mala fide

intentions.

h).That the above mentioned case was purely a civil

nature case and the petitioners collusiveness will be

determined at the time of trial so the case become

one of the further inquiry.

i).That the petitioner is neither desperate nor hardened

criminal. Petitioner have not a previous convict or

record holder and has clean and unblemisher record or

his career. Petitioners belongs to the respectable

family and the member of eminent labourer family and

is earning his livelihood by putting hard labour in

these hard days within the parameter of law and rules

of the country therefore, there is no likelihood of the

petitioner’s absconsion or tempering with the

prosecution evidence.

j).That the petitioners are ready to furnish reasonable

surety for his attendance in this Hon’able Court as well

as in any other trial Court on each and every date of

hearing in the like amount to the entire satisfaction of

this Hon’ble Court that this Hon’ble Court may order.

i).That other available grounds will be agitated at the

time or arguments.

DEPONENT

VERIFICATION:

Verified on Oath at Lahore this 13th day of July, 2012 that the contents of the above affidavit are true and correct to the best of knowledge and belief and nothing has been concealed therein.

DEPONENT

IN THE LAHORE HIGH COURT LAHORE

C. M No. /2012IN

W.P. No. /2012

Muhammad Arshad Vs. SDPO etc.

APPLICATION U/S 151 CPC FOR THE GRANT OF INTERIM RELIEF

Respectfully submits as under:

1. That the above titled writ petition has been filed in

this honourable court but not fixed so far for

hearing.

2. That all the facts are narrated in writ petition

which is read as integral part of this application.

3. That the petitioner has good arguable, prima facie

case in his favour and very bright chance of

success of the petitioner.

4. That the balance of the convenience lies in the

favour of the petitioner.

5. That if the injunction prayed is not granted to the

petitioner, the petitioner would suffer irreparable

loss to his rights.

P R A Y E R;

It is, therefore, very humbly and

respectfully prayed that this application may very

kindly be accepted and the respondents may very

kindly be directed, not to harass the petitioner without

lawful authority in the best interest of justice.

Petitioner

Through:

MUHAMMAD KHAN DAALAdvocate High Court

103-Jinnah Law Chambers, Sub-Divisional courts, Jaranwala.

CC. P-FB-16465

DATED:-

IN THE LAHORE HIGH COURT LAHORE

C. M No. /2012IN

W.P. No. /2012

Muhammad Arshad Vs. SDPO etc.

(STAY APPLICATION)

AFFIDAVIT OF Muhammad Arshad son of Muhammad Younas Caste Sial r/o chak No.466 J.B Tehsil Sumandri District Faisalabad.

===================

I, the above named deponent do hereby solemnly affirm and

declare that the contents of accompanying Petition attached with

the affidavit are correct to the best of my knowledge and belief

nothing has been misstated and concealed therein.

DEPONENT

VERIFICATION:

Verified on Oath at Lahore this 9th day of July, 2012 that the contents of the above affidavit are true and correct to the best of knowledge and belief and nothing has been concealed therein.

DEPONENT