IN THE COURT OF SESSIONS JUDGE,

ISLAMABAD WEST

1. Nusrat Hussain S/o Muhammad Aksar R/o Shah Allah Ditta P.O
Golra Sharif, Islamabad

2. Noshad Ali Samnani S/o Noor Ali Samnani R/o G-9, Islamabad

Petitioners

VS
The State

Respodent

FIR NO. 72/21, Dated 03-02-2021

U/S 420, 468, 471,447,34 PPC
P.S. GOLRA SHARIF, ISLAMABAD

PETITION UNDER SECTION 498 Cr.P.C FOR

BAIL BEFORE ARREST

Respectively Sheweth:
1. That the case has been registered against the petitioners on the
instance of complainant with malafide intensions and for
harassment. (Copy of FIR is attached).

2. That the case is false and frivolous to the extant of present

petitioners, no such incident as allege in the FIR took place. The
contents of the FIR are ill founded, baseless and far from truth.

3. That the petitioner having spotless carrier, good reputation

among family, colleagues and society.

4. That the story narrated in FIR is false, frivolous and concocted

one and the complainant in collaboration with the local police
only to grab money from the petitioners registered this FIR
against the petitioners.

5. That the alleged offence against the petitioners does not fall
with in the prohibitory clause of section 497 Cr.PC and the bail
in such a case must be given as a matter of right as per settled
principals of law.

6. That the petitioners was totally unaware of the that an FIR

stated above has been registered against the petitioner and as
soon as the fact come to the knowledge of petitioners, the
petitioners knocked the door of this honorable court for
discretionary relief of bail.

7. That the petitioners are innocent and have committed no offence

at all.
8. That there is further probe into the guilt of the petitioners and
petitioners is entitled for the concession of pre-arrest bail.

9. That the petitioners are ready to join investigation as per

direction by this Honorable court.

10. That the petitioners are ready to furnish reasonable surety in

case of being admitted to bail, to the satisfaction of this
Honorable Court.

In the Light of above mentioned facts and circumstances, it is,

graciously prayed that petitioners may please be granted pre-
arrest bail till the final disposal of the case in the best interest of
justice.

Ad-interim bail may also be granted.

Petitioners

Through

Muhammad Ijaz Bashir

Advocate High Court Islamabad

Certificate
 Certified that this is the 1st pre arrest bail petition being
moved in this Honorable Court as per information furnished by the
petitioners.
 IN THE COURT OF SESSIONS JUDGE,
ISLAMABAD WEST

1. Nusrat Hussain etc VS The State

FIR NO. 72/21, Dated 03-02-2021

U/S 420, 468, 471,447,34 PPC
P.S. GOLRA SHARIF, ISLAMABAD

PETITION UNDER SECTION 498 Cr.P.C FOR

BAIL BEFORE ARREST

AFFIDAVIT

We, Nusrat Hussain S/o Muhammad Aksar R/o Shah Allah Ditta, P.O Golra
Sharif, Islamabad & Noshad Ali Samnani S/o Noor Ali Samnani R/o G-9,
Islamabad, do hereby solemnly affirm and declare that the contents of bail
before arrest are true and correct to the best of our knowledge and belief
and nothing has been concealed.

DEPONENTS
Verification

Verified on oath at Islamabad on this February 4, 2021 declare that the

contents of this affidavit are true and correct to the best of our knowledge
and belief and nothing has been concealed therin.

DEPONENTS