IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No._____________B/2002

Muhammad Ismail S/o Kaloo, caste Shar, R/o Mauza Muhammad

Pur No. 2, Tehsil Jam Pur, District Rajan Pur.
……..PETITIONER
VERSUS
The State. …….RESPONDENT

BAIL AFTER ARREST U/S 497 CR.P.C.

Case:
F.I.R. No. 94/2002 Dated: 22.2.2002
U/s: 18-7/79 Islamic Law.
P.S. Jam Pur, District Rajan Pur.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
2. That the above-cited case was registered on the statement of Mst.
Zahran. She has stated that she is a house-wife. She was married
with one Muhammad Amin S/o Kaloo, caste Shar, R/o
Muhammad Pur No. 2; from the wedlock one daughter and four
sons were born and all are alive. Near-about 3 years ago, her
husband was died and the Ismail S/o Kaloo, caste Shar, R/o
Muhammad Pur No. 2, the real brother of her husband forced to
marry her, but she refused. On the day of occurrence, she went to
see her father by night. After having dinner, she and her father
Ghulam Rasool went to sleep. On the next day at the time of
Fajar, while she was having talks with her father, the said
Muhammad Ismail came there. Her father, while going to bring
 tea for said Muhammad Ismail. As well as her father went out
from the room, the said Muhammad Ismail forcibly caught hold
of her and after unwearing the Shalwar, tried to commit Zina-bil-
Jabbar. Fortunately, on the hue and cry of the complainant, her
two brothers attracted to the place of occurrence and had seen the
said Muhammad Ismail. Looking at the P.W.’s, Muhammad
Ismail left his shoes and succeeded to flee away from the scene.
Muhammad Ismail who wants to marry her, on the refusal, tried
to commit Zina Haram with her and fortunately, she was escaped.
Copy of F.I.R. is Annex “A”.
3. That the petitioner applied for pre-arrest bail, which was
dismissed vide order dated 11.3.2002, while the post arrest bail
petition of the petitioner was dismissed vide order dated
10.4.2002 respectively. Copies of the orders are attached as
Annexes “B & C”.
4. That the petitioner seeks concession of post-arrest bail inter-alia
on the following: -
GROUNDS
i) That the narration of F.I.R. is a concocted story and no
such occurrence has been ever happened.
ii) That the petitioner is innocent and roped up in this case
due to previous enmity and long term litigation.
iii) That the case is false against the petitioner and got
registered with ulterior motive, malafide and to meat
with evil designs.
iv) That the story of F.I.R. is unbelievable, witnesses are
interested, the behaviour of complainant is doubtful, the
conduct of the witnesses is un-natural and the
registration of case is nothing more but a mockery of
law against the petitioner.
v) That there is an un-explained delay of 2 days in the
registration of case and no plausible reason is advanced
in this respect.
vi) That the case is registered against the petitioner just to
pressurise and to extort benefits out of the litigation
 between the parties. Copies of civil suit, complaint and
suit for dissolution of marriage are Annexes “D, E &
F”.
vii) That no reasonable grounds exist to connect the
petitioner with the offence and the circumstances lead
to a case of further enquiry.
viii) That the investigation of the case is complete and the
person of the petitioner is no more required for further
investigation.
ix) That the petitioner is behind the bar and no useful
purpose can be served with the further detention of the
petitioner.
x) That no complete or incomplete challan is submitted in
the court of competent jurisdiction.
Keeping in view the above-mentioned facts, it is
respectfully prayed that this petition in hand may
graciously be accepted and the petitioner may please be
admitted to bail till the final decision of the case.
Any other writ, order, direction or relief which
this Hon’ble court deems fit, may please be extended in
the favour of petitioners to meet the ends of justice.
HUMBLE PETITIONER,
Dated: ___________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
this is the first after-arrest bail petition on
the subject matter. No such petition has
earlier been filed before this Hon’ble Court.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 In re: C.M. No. _____________/2002
In
Crl. Misc. No.______________B/2002

Muhammad Ismail Vs. The State

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth: -
That certified copies of Annexures “___________” are
not available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
APPLICANT,

Dated: __________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Misc. No._____________B/2002

Muhammad Ismail Vs. The State

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form.
2 After-arrest bail petition.
3 Copy of F.I.R. A
4 Copy of order dated 11.3.2002. B
5 Copy of order dated 10.4.2002. C
6 Copy of civil suit & complaint. D&E
7 Copy of suit for dissolution of marriage. F
8 Dispensation Application.
9 Vakalatnama

PETITIONER,
Dated: _________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176