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    In The Court of - Add. District & Sessions Judge Karachi Central

    Uploaded by

    asadkhan.132681
    This document is a bail application submitted to the District & Sessions Judge in Karachi Central on behalf of the accused, Asif. In 3 sentences: The application requests that Asif be granted bail pending trial as he claims to be innocent and falsely implicated, the prosecution does not have substantial evidence against him, and he is willing to abide by any conditions set by the court. The application outlines the facts of the case and arrest, and provides 16 grounds for granting bail, including doubts about the investigation and recovery of items.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    In The Court of - Add. District & Sessions Judge Karachi Central

    Uploaded by

    asadkhan.132681
    22 views3 pages
    This document is a bail application submitted to the District & Sessions Judge in Karachi Central on behalf of the accused, Asif. In 3 sentences: The application requests that Asif be granted bail pending trial as he claims to be innocent and falsely implicated, the prosecution does not have substantial evidence against him, and he is willing to abide by any conditions set by the court. The application outlines the facts of the case and arrest, and provides 16 grounds for granting bail, including doubts about the investigation and recovery of items.

    Original Description:

    Bail Application under section 497 CrPC

    Original Title

    359-2018 of 23(i0-A

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    This document is a bail application submitted to the District & Sessions Judge in Karachi Central on behalf of the accused, Asif. In 3 sentences: The application requests that Asif be granted bail pending trial as he claims to be innocent and falsely implicated, the prosecution does not have substantial evidence against him, and he is willing to abide by any conditions set by the court. The application outlines the facts of the case and arrest, and provides 16 grounds for granting bail, including doubts about the investigation and recovery of items.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    22 views3 pages

    In The Court of - Add. District & Sessions Judge Karachi Central

    Uploaded by

    asadkhan.132681
    This document is a bail application submitted to the District & Sessions Judge in Karachi Central on behalf of the accused, Asif. In 3 sentences: The application requests that Asif be granted bail pending trial as he claims to be innocent and falsely implicated, the prosecution does not have substantial evidence against him, and he is willing to abide by any conditions set by the court. The application outlines the facts of the case and arrest, and provides 16 grounds for granting bail, including doubts about the investigation and recovery of items.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    IN THE COURT OF ____ ADD.

    DISTRICT & SESSIONS JUDGE


    KARACHI CENTRAL
    Cr. Bail Application No. _________/2018
    In, Cr. Case No. ________/2018

    Asif
    S/o Bahadur Ali ……………….…………………....Applicant / Accused

    Versus

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

    FIR No. 359/2018


    U/s. 23(i)-A SAA
    PS. Sir Syed, Karachi Central

    BAIL APPLICATION UNDER SECTION 497 Cr.P.C.

    It is most respectfully prayed on behalf of the applicant/ accused above named

    that this Hon’ble Court may be pleased toenlarge him bail pending trial inter-alia on

    the following facts and ground: -

    FACTS

    1. The brief facts of the FIR are that on 25-10-2018, The ASI Mr. Akbar Ali

    Abbasi of PS Sir Syed has lodged the above FIR, wherein he stated that

    accused / applicant was arrested on dated 25-10-2018 accused / applicant

    named above was arrested in crime no. 358/2018, under section 23(i)-A SAA,

    and officer made body search from accused and recovered one pistol 30 bore

    (not in working condition) with 02 live bullets. As such separate FIR no

    359/2018, u/s 23(i)-A SAA has been lodged against the applicant / accused.

    (Copy of FIR is attached and marked as annexure “A”)

    2. That on dated 26-10-2018 investigation officer produced accused / applicant

    before court of law for remand and accused remanded to Judicial Custody and

    confined in District Prison Malir, Hence this bail application on following

    grounds:
    GROUNDS

    I. That the applicant / accused is quite innocent and has falsely been implicated in

    this false and fabricated case, due to not completion the demands of police

    personals.

    II. That there is no reasonable ground to believe that the applicant / accused has

    committed the alleged offence, as such the prosecution does not possess any

    substantial evident against him.

    III. That it is not mentioned in the FIR that either recovered case property /

    weapons sealed on the spot or not.

    IV. That the said FIR is totally silent about the facts of arresting of accused and

    recovery.

    V. That as per the contents of FIR no. 358/2018 that the recovery weapon from

    applicant / accused is not working condition, therefore the section under

    section 23-(i)A SAA is not attracted against the accused / applicant.

    VI. That as per contents of FIR the distance between place of arrest and police

    station about 1 and ½ KM, whereas the incident occurred at 0130 hours and

    FIR was lodged after 1 hour delay at 0245 hours.

    VII. That nothing incriminating material has been recovered from the possession of

    the applicant / accused and if any recovery is foisted upon the applicant /

    accused, due to the police party was demanded illegal gratification from the

    accused, on refusal police party booked him in instant case.

    VIII. That the applicant was arrested on doubt basis and police indulged the

    applicant in false and fake cases without any charge even recovery of weapon

    is foisted upon the applicant / accused.


    IX. That the place of occurrence is thickly populated road and usually rush of public were

    present till late night, but complainant has failed to recorded the statements of

    locality persons and not fulfilled the requirement of investigation, it is clear

    violation of section 103 Cr.P.C, hence the matter falls for further inquiry as the

    superior courts held time and again that the basis principle is bail not jail.

    Relied upon 1998 P.Cr.L.J 1381 (Karachi).

    X. That the police has completed investigation and send to accused for jail authority and

    he no more required for any further Investigation, therefore the accused is

    entitle for bail in the instant case.

    XI. That the offence does not fall under prohibitory clause of section 497(2) Cr.P.C. and

    applicant / accused is entitle for concision of bail.

    XII. That the applicant / accused not a previously convicted nor is habitual

    offenders.

    XIII. That the applicant / accused is law- abiding citizen and there is no

    apprehension of his absconding or tempering PWs if released on bail.

    XIV. That the applicant e/ accused is ready to furnish solvent surety to the entire

    satisfaction of this Hon’ble Court.

    XV. That the applicant / accused under take to appear before this Hon’ble Court on

    each date of hearing.

    XVI. The undersigned craves permission from this Hon’ble Court to advance further

    argument at the time of hearing of this application.

    Prayed accordingly.

    Karachi.
    Dated________________ ADVOCATE FOR THE
    APPLICANT / ACCUSED

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