IN THE COURT OF DISTRICT & SESSION

JUDGE WEST AT KARACHI

Cr. Bail application No:____________/2023

Muhammad Zeeshan
S/o Muhammad Kaleem
Muslim, Adult R/o House No. B- 12,
Block ( A ) Orangi Town,
Karachi West…………..…….…………………Applicant/Accused

VERSUSS

The State……………………………………….…………Respondent

FIR No.183/2023
U/S 3 (A) CNS
(Amendment) (i) 9
P.S Iqbal Market

BAIL APPLICATION UNDER SECTION 497 CR.P.C

It is respectfully prayed on behalf of the

above named Applicant / Accused that this Hon’ble
Court may graciously be pleased to enlarge him on bail
on the consideration of following facts and grounds:-

FACTS

Brief facts of the prosecution case are on 07-07-2023 I HC Syed

Qaiser Abbas along with other officials namely P.C Kamran, P.C
Muhammad Babar ,we arrested him that on finding him
suspected with the help of above officials .that on arrest and
asking he disclosed his name as Muhammad Zeeshan S/o
Muhammad Kaleem ,due to unavailability of private witnesses ,
appointed above mentioned officials as witness , while search
from his right pocket of his paint ,Charas wrapped with white
plastic found , that on weighing by digital Kanta ,the Charas
weighed 190gram , we arrested him the recovered Charas was
 sealed with number came at police station , lodged FIR and
investigation is handed over to SIO .

Photocopy of FIR No.183 /2023 is enclosed herewith and

marked as annexure ‘A’.

GROUNDS

1. That the Applicant/Accused is innocent and has been falsely

implicated in this case by the police.

2. That on face of it, Prosecution story appears to be doubtful and

no such incident has been taken place.

3. That as per the contents of the FIR the incident took place on
thickly populated and busy area but despite of that police
officials failed to produce a single independent witness.

4. That at the time of recovery, police officials failed to make

search in the present of any independent witness, hence this is
the gross violation of the 103 of CR.P.C therefore the above
mentioned alleged accused should be given the concession of
the bail.

5. That the presumption of innocence always exists in the criminal

cases, which means innocent until proven guilty.

6. That the general rule is bail not jail, and bail does not mean
acquittal but it is the transfer of custody from authority to the
surety.

7. That nothing incriminating has been recovered from the

Applicant/Accused but the police has foisted the Charas upon
him malafidely.

8. That there is no direct or indirect evidence to connect the

applicant/accused with alleged offence.
 9. That Applicant/Accused was arrested from his office whereas
CCTV camera also showing the same and CCTV footage also be
produced before Hon’ble Court.

CCTV Footage of arrest of the Accused is enclosed herewith

and marked as annexure ‘B’.

10. That all the P.Ws/Masheer are interested witnesses and

there is no apprehension of tempering with their evidence.

11. That the accused has been sent to the judicial custody and he
is more required for further investigation.

12. That the applicant/accused being local person will not abscond
away.

13. That the applicant/accused is prepared to furnish solvent

surety to the entire satisfaction of this Honourable Court .

14. That I humbly place my reliance on the following judgement of

Honourable Court .

Photocopy of the relevant case law is enclosed

herewith and marked as annexture C .

15. That further grounds would be submitted at the time of

arguments.

Karachi
Dated:17-07-2023 Advocate for Applicant/Accused
IN THE COURT OF DISTRICT & SESSION
JUDGE WEST AT KARACHI

Cr. Bail application No:____________/2023

Muhammad Zeeshan…………….…………………...... Applicant/Accused

VERSUSS

The State………………………………………………….……………Respondent

CERTIFICATE

This is to certify that this is the first bail application in

above mentioned case, prior to this no any bail application has

been moved in any court of law in this case.

Karachi
Dated: 17-07-2023 Advocate for Applicant/Accused
 VAKALATNAMA
IN THE COURT OF DISTRICT & SESSION
JUDGE WEST AT KARACHI

Cr. Bail application No:____________/2023

Muhammad Zeeshan…………….…………………...... Applicant/Accused

VERSUSS

The State………………………………………………….……………Respondent

FIR No.183/2023
U/S 3 (A) CNS (Amendment) (i) 9
P.S Iqbal Market

I, Muhammad Zeeshan S/o Muhammad Kaleem Muslim, Adult R/o

House No. B- 12, Block (A ) Orangi Town, Karachi West, do hereby
appoint and constitute Ch. Muhammad Abu Bakar Khalil, Ms.
Shagufta Parveen Khan, Ms. Nancy Dean, & Muddassir Hussain
Advocate (s) to represent me/us on my/our behalf as my/our advocate
(s) in the above matter.

I/We authorize the said advocate (s) to compromise, withdraw

and receive on my/our behalf all sums and amounts deposited in
my/our account in the above matter and/or refer the above matter to
arbitration or to compromise or to withdraw the same. I/We undertake
to appear in the above matter before the Hon’ble Court, my/our
counsel shell not be held responsible in case the matter is
dismissed/disposed off ex-parte due to my/our failure to
appear/attend the above case. I/We also undertake to pay his full
professional fee before the conclusion of this case. In case his full fee
is not paid the counsel can withdraw his Vakalatnama for the above
matter.

Dated: -08-2023
Received me on -08-2023 received from Applicant/Accused

Muhammad Zeeshan
The Applicant/Accused
Accepted
Ch. Muhammad Abu Bakar Khalil Ch. Muhammad Ibtasam Khalil
(Advo-17482-SBC-KHI) (Advo-21094-SBC-KHI)
CNIC: ______________________ CNIC: ______________________
Zubair Ahmed Sahito
(Advo-5843-SBC-HYD)
CNIC: ______________________
_________________________________________________________________
Office: 95-D, 8th Floor Farid Chambers, Abdullah Haroon Road, Sadder, Karachi.
Cell: 0300-6944460 E-mail: abubakar_khalil@yahoo.com