SAMPLE / SPECIMEN / DRAFT OF POST ARREST BAIL IN NARCOTICS CASE

IN THE COURT OF THE LEARNED ADDITIONAL SESSIONS JUDGE, SARGODHA

CRIMINAL MISC. NO.___/2025

ABC……,
Caste Rajpoot, R/o Kotli Qazi, District Mandi Bahauddin

…Applicant/Petitioner

VERSUS

THE STATE

…Respondent

APPLICATION FOR POST-ARREST BAIL UNDER SECTION 497 CR.P.C. ON BEHALF OF THE ACCUSED/PETITIONER MURTAZA S/O MUHAMMAD SHABIR IN CASE FIR NO. 611/25 DATED 04.05.2025 U/S 9(1)3B OF THE CONTROL OF NARCOTIC SUBSTANCES ACT, 1997, REGISTERED AT POLICE STATION ___________.

RESPECTFULLY SHEWETH:

1. That the petitioner has been falsely implicated in the above-mentioned case; he seeks indulgence of this Hon’ble Court for grant of bail after arrest.
2. That the petitioner was arrested on 05.05.2025 and since then he is behind the bars; the FIR was registered on 04.05.2025 at about 03:20 PM with an unexplained delay of almost one day, which casts serious doubt on the veracity of the prosecution story.
3. That the prosecution story is concocted, self-assumed, and fabricated, having no nexus with the actual facts and realities. The entire case has been maneuvered with malafide intentions to falsely implicate the petitioner without any concrete or independent evidence.
4. That the alleged recovery is said to have been made during daytime in a public place where many people were present, yet no independent witness has been cited, which makes the entire recovery process highly doubtful.
5. That the offence does not fall within the ambit of the prohibitory clause of Section 497 Cr.P.C., as the sentence for the alleged quantity does not mandate capital punishment or life imprisonment.
6. That the petitioner has no previous criminal recordand is a law-abiding citizen. His character and antecedents are clean and untainted.
7. That the petitioner has no concern whatsoever with the alleged offence, and his implication is a result of police highhandedness and personal vendetta, which is evident from the manner in which the case has been built.
8. That the investigation of the case has been completed, and no further recovery is to be effectedfrom the petitioner; hence, his further incarceration serves no useful purpose.
9. That there is no apprehension of abscondingby the petitioner nor any chance of tampering with prosecution evidence or influencing witnesses.
10. That bail is a rule and jail is an exception; the continuous detention of the petitioner amounts to pre-trial punishment, which is against the settled principles of justice.
11. That the petitioner undertakes to fully cooperate with the trial and to comply with all conditions that may be imposed by this Hon’ble Court.
12. That the petitioner is ready to furnish sound and solvent suretyto the entire satisfaction of this Hon’ble Court.

PRAYER
In view of the above submissions, it is therefore most respectfully prayed that this Hon’ble Court may graciously be pleased to grant post-arrest bail to the petitioner in the interest of justice, equity, and fair play.

Any other relief deemed just and proper in the circumstances of the case may also be granted.

…Petitioner

Through
Asadullah Hassan Hashmi, Advocate

LLM-ITL(Medalist)
Mehdi Hassan, Advocate

Dated: __ / __ / 2025