IN THE COURT OF DISTRICT AND SESSION JUDGE

FEROZEWALS SHEIKHUPURA.

Bail Petition No.--------------of 2020.

Abid Ali S/O Asghar Ali Caste Syyal R/O Syyalin Wali

Gali Nai Bhaini Ps Sharqpur Sharif District

Sheikhupura. (Petitioner).

VS

The State

Case FIR No.624/19 dated 22/9/19.

Offence under Section 324/302/148/149.

PS.Sharqpur Sharif.

PETITION UNDER SECTION 497 OF CRPC FOR THE GRANT

OF BAIL AFTER ARREST.

Respectfully Sheweth:-

1. That as per allegation levelled by the

complainant is that on 22/9/2019 at about 9 am

the younger brother of the complainant Zubair

was going in the street and was stopped and

beaten by accused Shabbir but the matter was

patched up. After that accused Abid

Ali,Tanveer Ahmad ,Shabbir Ahmad and the

present petitioner Ali,all armed came in front

of the house of the complainant. When the

father of complainant came out and tried to

 settled down the matter but the said accused

started firing which hit different parts of the

body of deceased hence instant FIR.

2. That the petitioner seeks after arrest bail on

the following grounds:-

A. That the above said case has been got

registered against the petitioner at police

station Sharqpur Sharif.

B. That that the petitioner is innocent, the

above said case is false and frivolous, and

the petitioner has been falsely implicated

in the said case due to the mala fide of the

complainant and the police as well.

C. That the earlier bail petition of the

petitioner has been dismissed as withdrawn

on 2.5.20 by the court of Mr.Shahid Sikander

Learned ASJ Ferozewala District

Sheikhupura.The copy of the order is

attached with the petition.

D. That a valid compromise has been effected

with the complainant and he is ready to

submit an affidavit before this honourable

court.

E. That the whole story of the FIR is false

frivolous and concocted and the present

petitioner has no concern with this alleged

occurrence.

F. That no such occurrence as mentioned in

the FIR has been taken place and the

 petitioner has been falsely implicated in

the said FIR.

G. That as per FIR the petitioner has been

mentioned armed with Pump Action gun

while during the investigation a fake

recovery of the pistol has been planted by

the police.

H. That on the very same day of occurrence

the complainant made a supplementary

statement and made some dishonest

improvement, which makes the case of the

prosecution doubtful.

I. That as per FIR only single fire has been

attributed to the petitioner the injury of

which has been declared F3 in the MLC.

J. That the case of the present petitioner is

of two versions one is of the complainant

and while other came out after the

investigation.

K. That the investigation of the said case

has been completed and the petitioner has

been sent to judicial Lock up.

L.That the bail of the co-accused namely

Ali,shahzad as well asghar Ali has been

granted by this honourable court on

10/12/2019.The copy of the order is also

attached with the petition.

M. That the bail of other co-accused namely

Tanveer Hussain has also been granted by

MR.Justice Ch.Mushtaq Ahmad Lahore High

 Court Lahore on the same role. The copy of

the order is attached with the petition.

N. That despite of the physical remand

nothing has been recovered from the

present petitioner and if there is so it has

been planted which has no value in the eyes

of law.

O. That there is contradiction between oral

and medical evidence, which makes the case

of the complainant doubtful.

P. That the MLC has also been obtained by the

complainant mala fidly with the help of the

Doctor.

Q. That the present petitioner is respectable

citizen and without any criminal record

and is law abiding citizen.

R. That the investigation of the said case

has been completed and the petitioner is

behind the bars no more require for the

purpose of further investigation to the I.O.

S.That It is further submitted that there is

no incriminating material available on the

record which connects the petitioner with

this alleged occurrence.

T. That due to the above-mentioned reasons

the case of the present petitioner comes

into the ambit of further inquiry hence the

petitioner is entitled for the relief of

post arrest bail.

 U. That the petitioner is ready to submit

surety bonds in case of the bail granted by

this honourable court.

V. That the petitioner would not misuse the

concession of bail in case of bail granted

by this honourable court.

Prayer

Under these circumstances it is most respectfully

prayed that the petition of the present

petitioner for grant of post arrest bail may

very kindly be accepted and the petitioner be

released. Any other relief, which this

honourable court deems fit may also,

awarded.

Petitioner

Through Counsel

Malik Manzoor Ahmad(Advocate High Court)