IN THE COURT OF SESSIONS JUDGE, LAHORE.

B.A. No.___________________/2024

ABC s/o ——–Resident of —————-

                                                                                                    Petitioner_

V e r s u s

The State

_Respondent

CASE FIR No.                      ___/20__   

Dated                                      0.0.20

Offence U/Ss.                         _________, P.P.C.

Police Station.                        _________, Lahore.

BAIL APPLICATION U/S 498 CR.P.C FOR THE GRANT OF PRE-ARREST BAIL.

1. That on 0.0.20 the above-mentioned case has been registered against the petitioner in police station _________, Lahore. Copy of the F.I.R. is annexed as Annexure-A.

2. That the accused petitioners were involved in the above mention case due to the malafide intention of the complainant as well as local police, otherwise the accused / petitioner is quite innocent.

3. That the above-mentioned case has been Registered against the petitioner is false frivolous, baseless and concocted, with malafide intentions and ulterior motives of the complainant and police.

4. That the allegations leveled against the petitioner are totally false and petitioner has no concern with the commission of the alleged offence.

5. That there is great apprehension of arrest of the petitioner by the local police so, the petitioner seeks the pre arrest on the following amongst other,

G R O U N D S

• That the petitioner is falsely implicated under ulterior motive and with malafide intention to harass and black mail the petitioner, has got registered the above noted false case.

• That nothing incrimination and substantial material available on record, connecting the petitioner with the commission of the alleged offence in this way the complainant of the case did high handedness and tried to involve the petitioner in this false and frivolous case.

• That the petitioner is respected law-abiding citizen. The local police bent upon to arrest the petitioners and he will suffer irreparable loss to his respect and family honor.

• That the afore-mentioned case is falsely registered against the petitioner and the case requires further inquiry.

• That there is no apprehension of abscondence of the petitioner or to temper with the prosecution evidence.

• That the petitioner is ready to join the police investigation as and when required by the police for proving her innocence.

• That the petitioner is ready to submit bail bonds to the entire satisfaction of this honorable court.

• That the petitioner humbly seeks to raise additional grounds at the time of the arguments.

Prayer

It is therefore respectfully prayed that the petitioner may very kindly be granted ad – interim pre arrest bail, till the final disposal of this petition.

Petitioner

                         Through

                                                            ABC

                                                            Advocate High Court