BEFORE THE JUDICIAL MAGISTRATE TEHSIL

KHWAZA KHELA DISTRICT SWAT

CASE No____________/2023

Asad S/o Khan R/o Shalpin Tehsil Khwaza Khela

(Petitioner /Accused)
VERSUS
The State through Najeebullah Khan
(Respondents)

INDEX

S. No Descriptions of Documents Annex P. No

1 Memo of Application
2 Certificate
3 Copy of FIR A
4 Wakalat Nama

Applicant / Petitioner
Through Counsel

Ibrar Ahmad Khan Adnan Khan

Advocate, High Court Advocate, High Court

The Legal Brain Law Chamber Khwaza Khela, Swat

 BEFORE THE JUDICIAL MAGISTRATE, TEHSIL
KHWAZA KHELA DISTRICT SWAT

CASE No____________/2023

Asad s/o Khan R/o Shalpin Tehsil Khwaza Khela

(Petitioner /Accused)
VERSUS
The State through Najeebullah Khan
(Respondents)

CASE FIR NO. 911 DATED: 30/12/2022.

UNDER SECTION 457, 380 PPC POLICE STATION
KHURSHEED KHAN SHAHEED KHWAZA KHELA
DISTRICT SWAT

BAIL APPLICATION UNDER SECTION 497 CRIMINAL

PROCEDURE CODE FOR THE RELEASE OF ACCUSED /
PETITIONER IN THE ABOVE TITLED CASE TILL THE
FINAL DISPOSAL OF THE CASE.
Respectfully Sheweth,

1. That the accused / petitioner has been behind bars in the

above-mentioned case. (Copy of FIR annexed as
annexure “A”).

2. That the accused / petitioner is praying for the post arrest

bail in the above-mentioned case on the following
grounds.

GROUNDS:
1) That the Accused / Petitioner has not committed the above
mentioned offence. The complainant falsely implicated the
accused / petitioner in the above-mentioned case.

2) That the applicant is innocent and has been falsely implicated

in the above-mentioned FIR. The applicant has been charged
under Sections 457 and 380 of the Pakistan Penal Code.

3) That the applicant is a permanent resident of Shalpin Tehsil

Khwaza Khela and has been living there with his family for
the past many years. The applicant is a law-abiding citizen
and has never been involved in any criminal activity before.

4) That there is no corroborative independent, impartial, and

trustworthy piece of evidence to support allegations against
the Accused / Petitioner.

5) That the Accused / petitioner is behind the bars and keeping

the accused / petitioner behind the bars will serve no purpose
to the prosecution. Therefore, the Accused / petitioner may
graciously be released on bail for the greater benefit of the
society.

6) That the Accused / Petitioner is ready to furnish surety bonds

for the satisfaction of this against court.

7) That the offense does not fall in prohibitory clause of section

497 Cr. PC and thus it is humble submission that bail may be
granted.

8) That there is no eye-witness available of the offence which

allegedly took place between the petitioner / accused and the
complainant.
9) That the applicant is a [insert profession] and is the sole
breadwinner of his family. If he is not granted bail, his family
will suffer immensely. The applicant is ready to furnish a
 surety and comply with any other conditions that the court
may impose.
10) That there is further scope of inquiry into the guilt of
accused / petitioner, the accused is no more required for
further investigation to the local police.
11) That it is the fundamental right of the applicant to be
granted bail unless there are reasonable grounds to believe
that he has committed the alleged offence. In the present
case, there is no evidence against the applicant, and the
charges against him are based on mere allegations.

In view of the above, it is most respectfully prayed that the

Accused / Petitioner may kindly be granted bail in the above-
mentioned FIR, and he may be released from custody subject to
such terms and conditions as this Hon'ble Court may deem fit
and proper.

Accused /
Petitioner
Through Counsel

Ibrar Ahmad Khan Adnan Ali Khan

Advocate, High Court Advocate, High
Court

The Legal Brains Law Chamber Khwaza Khela, Swat

 BEFORE THE JUDICIAL MAGISTRATE TEHSIL
KHWAZA KHELA DISTT SWART
CASE No____________/2023

Asad………………………… (Petitioner /Accused)

VERSUS
The State through Najeebullah Khan
(Respondents)

CERTIFICATE
It is certified that as per information furnished by my client /
Petitioner it is the first ever application on its subject matter and
no such like other petition has earlier been filed or pending
adjudication before this Honorable Court.

Counsel

Ibrar Ahmad Khan Adnan Ali Khan

Advocate, High Court Advocate, High Court

The Legal Brains Law Chamber Khwaza Khela, Swat