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February 20, 2021

FORMAT – SPECIMEN - PRE-ARREST BAIL PETITION IN CASE POLICE FIR

 PRE-ARREST BAIL PETITION IN CASE FIR NO.1 DATED 22/10/2018 CHARGE UNDER SECTION 409-PPC 5(2) P.C ACT POLICE STATION ACE BUNER

Before the Special Judge Anti-Corruption Peshawar

        

B.B.A No_________ of 2018

        

 Ali Taj S/o                 R/o Shahbaz Ghari District and Tehsil Mardan.

                                                                           (Petitioner)

                                                                         Versus                                                                                      

1.   The State.

2.   ACE Buner                                                             (Respondents)

 

PRE-ARREST BAIL PETITION IN CASE FIR NO.1 DATED 22/10/2018 CHARGE UNDER SECTION 409-PPC 5(2) P.C ACT POLICE STATION ACE BUNER

    

Respectfully sheweth,

 

1.    That Accused petitioner has been booked in FIR No. 01 dated 22/10/2018 charge under section 409-PPC 5(2) P.C Act Lodged at Police Station ACE Buner.  (Copy of FIR is attached as annex. A)

 

2.    That accused/petitioner is innocent and falsely been implicated by the complainant, with mala-fide intention in the case mentioned above.

 

3.    That case of the prosecution is doubtful, distrustful, and uncertain; thus, no useful purpose would be served by dragging the accused because the charge level against the accused is a mere allegation which is not sufficient to connect the accused with the commission of an offence.

4.    That accused petitioner is a retired and sick person, the concept of the pre-arrest bail is to prevent the humiliation of citizens at the hand of police.

 

5.    That the information of substandard material of construction in question is based on presumption self-made opinion thus case required further inquiry. 

 

6.    That accused petitioner is ready to furnish surety bonds to the satisfaction of this Honourable court; there will be no chance of their absconding.

 

 

So, it is therefore prayed that on acceptance of this petition, the pre-arrest bail of the petitioner may please be confirmed till the final disposal of the case.

                                Dated:  26/10/2018

                                                                     Accused/petitioner                                                             

            Through,

                                                           Advocate High Court

AFFIDAVIT

I Ali Taj solemnly affirm that the content of this petition are true and correct to the best of my knowledge and belief, and nothing has been concealed from this Honourable Court.

 

                                                                                        DEPONENT

 

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