IN THE COURT OF SESSIONS JDUGE, LAHORE

B.A No._____________/2023

Sheikh Imran Zahid son of Sheikh Zahid Kamal,

Resident of House No. P-1365/8, Mohallah Kartaar
Pura, Rawalpindi.
…Petitioner
Versus

The State
…Respondent

Case F.I.R. No. 3158/23

Dated: 21.09.2023
Offence Under Section 462-I PPC
Police Station Ghaziabad
District Lahore.

PETITION UNDER SECTION 498 CR.PC FOR THE

GRANT OF PRE-ARREST BAIL.

Respectfully Sheweth:

1. That the false, frivolous and baseless registered

against the petitioner. For detail prosecution
story copy of the F.I.R is enclosed as ( ANNEX
“A” ).

2. That the bail before arrest is being sought in the

titled case, inter alia, on the following:-

GROUNDS
(i) That the allegation against the petitioners
as narrated in the F.I.R. is absolutely false
and the petitioners have been roped in the
instant case by the complainant as well as
the local police with malafide intention and
to achieve some ulterior motive for ill-will
and ill-gain.

(ii) That the complainant by concealing all the

facts and circumstances of the case and
joining hands with the local police
registered the FIR No.3158/2023 offence
under section 462-I PPC with malafide
intention and ulterior motives, which
clearly shows the malafide intention of the
complainant, local police and Investigating
Officer.

(iii) That the offence under section 462-I PPC

not fall in prohibitory clause of section 497
Cr.PC.

(iv) That admittedly there is an inordinate

delay of 4 Months in registration of the
case for which no plausible explanation
has been given by the complainant.

(v) That the case against the petitioners is a

case of further inquiry and falls within the
ambit of section 497(2) Cr.PC.

(vi) That the petitioners are respectable

citizens of the State. The Police is out to
arrest them and in case of their arrest,
they would likely to suffer an irreparable
loss to their reputation.

(vii) That the petitioners are ready to join the

investigation as and when required by the
Police.

(viii) That there is no apprehension of the

petitioners’ abscondance or tampering with
 the prosecution evidence, if the petitioner
is released on bail.

(ix) That the petitioners are ready to furnish

surety bonds to the entire satisfaction of
this Honourable Court.

In view of the above submissions, it is,

therefore, most respectfully prayed that the petitioner
may kindly be granted bail before arrest in the titled
case till the final disposal of the case. Meanwhile,
an ad-interim pre-arrest bail may very kindly be
granted till the final disposal of this bail application.

Dated: 25.9.2023 Petitioner

Through

(MUHAMMAD IQBAL GHANI)

Advocate High Court,

(SOHAIB SALEEM CH.)

Advocate High Court,
3-First Floor, Al-Qadar Centre,
1-Mozang Road, Lahore.
 IN THE COURT OF SESSIONS JDUGE, LAHORE

Bail Application No._____________-B/2023

Sheikh Imran Zahid

Vs
The State

(Application under Section 498 Cr.PC for the grant of

Pre-arrest bail)

Case F.I.R. No. 3158/23

Dated: 21.09.2023
Offence Under Section 462-I PPC
Police Station Ghaziabad.
District Lahore.

AFFIDAVIT OF Sheikh Imran Zahid son of Sheikh

Zahid Kamal, Resident of House No. P-
1365/8, Mohallah Kartaar Pura,
Rawalpindi.

I, the above named deponent do hereby

solemnly affirm and declare as under:-
1. That the deponent has filed the above titled Bail
application before this Honourable Court, in which no
date of hearing has so far been fixed.

2. That whatsoever has been stated in the accompanying

petition is correct to the best of my knowledge and
belief and nothing has been concealed.

Deponent
Verification:
Verified on Oath at Lahore this 25 t h day of
September, 2023 that the contents of the above
affidavit are true and correct to the best of my
knowledge and belief.

Deponent
 IN THE COURT OF SESSIONS JDUGE, LAHORE

Bail Application No._____________-B/2023

Sheikh Imran Zahid

Vs
The State

I N D E X

Sr. Description of Documents Annex Page

No.

1. Application U/S 498 Cr.PC for 1-3

grant of pre-arrest bail.

2. Affidavit to above 4

3. Copy of the FIR No.3158/2023. “A” 5

4. Power of attorney 6

Dated: 25.9.2023 Petitioners

Through

(MUHAMMAD IQBAL GHANI)

Advocate High Court,

(SOHAIB SALEEM CH.)

Advocate High Court,
3-First Floor, Al-Qadar Centre,
1-Mozang Road, Lahore.