SPECIMEN OF POST ARREST BAIL PETITION/DRAFT/FORMAT OF BAIL UNDER SECTION 497 CRPC

In the Court of Learned Area Magistrate, P.S-Golra, Islamabad

NAME OF THE PARTY

R/O Street _________, Islamabad

                                                                                         …petitioner/accused                                                      

                                        Versus

The State

                                                                                                         …Respondent

                                           FiR No            P.S           Offence                Date

                                [FIR NO / Year]    Golra           381A             02/07/2022

Application U/S 497 Cr.pc for the grant of Post Arrest Bail in a Case FIR No. [FIR NO / Year] U/S 381-A PPC Dated 02/07/2022 Registered in Golra Police Station, Islamabad

Respectfully Sheweth;

1. That through the instant bail petition, the petitioner/accused seeks post arrest bail in a case registered through FIR No. [FIR NO / Year], Dated 02/07/2021, under section 381-A of the Pakistan Penal Code at Police Station Golra, Islamabad.

                                   (Copy of FIR No. [FIR NO / Year]  is annexed herewith as annexure “A”)

2. That the above mentioned FIR got registered by the complainant namely [Insert Name] S/O [Insert Name] against unknown person whereby the police with mala-fide and personal grudges illegally detained and arrested the accused since 07/02/2022.
3. That the petitioner/accused has nothing to do with the commission of alleged offence.
4. That the petitioner is completely innocent and belongs to a very poor family that’s why police illegally arrested and detained the petitioner by use of force.
5. That the petitioner/accused is not nominated in the FIR, however, police in connivance with complainant mala-fidely involved the petitioner in the instant case.
6. That the petitioner/accused is behind the bar since 3 months and 25 days approximately.
7. That the petitioner/accused has been involved falsely in the instant case, therefore, the petitioner/accused humbly seeks the indulgence of this leaned court for the grant of post arrest bail inter alia on the following grounds.

GROUNDS

8. That the petitioner/accused is completely innocent and he has nothing to do with the commission of alleged offence.
9. That the case of the prosecution is based upon mala-fide of the police and the complainant also.
10. That there is an unexplained delay of 5months between registration of FIR and commission of alleged offence which clearly shows the mala-fide of the Complainant and police.
11. That if the petitioner/accused is released on bail, there is no chance that the petitioner/accused would tamper the prosecution witness.
12. That there is no probability of abscondance of the petitioner if he is released on bail.
13. That in aforementioned circumstance, the instant case appears to be one of further inquiry.
14. That the petitioner is law-abiding citizen of Pakistan and never thinks to take law in his hand.
15. That the petitioner is ready to provide surety bond for the satisfaction of this learned court if the post-arrest bail is granted to the petitioner.
16. That nothing incrimination and substantial material available on record, connecting the petitioner with the commission of the alleged offense in this way the complainant and local police of the case did high handedness and tried to involve the petitioner in this false and frivolous case.
17. That the petitioner is respected law-abiding citizen, having no criminal record and never ever involved in any criminal proceedings.
18. That there is no apprehension of abscondance of the petitioner or to tamper with the prosecution evidence.
19. That the case is nature of further inquiry and police does not have to need the body of petitioner/ accused.
20. That the petitioner is ready to submit bail bond to the entire satisfaction of this honorable court.            

 Prayer

It is therefore respectfully prayed that the petitioner may kindly be granted post arrest bail in the best interest of justice

                  …Petitioner

Through Counsel

Asadullah Hassan Hashmi

(Advocate High Court)

LLM-ITL (Medalist)

Certificate:
It is certified that upon instructions of the client it is the first petition for post arrest bail filed before this Honorable Court in the matter in hand.

Counsel