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| post-arrest Bail petition in HC |
Purpose: To seek the remedy of post-arrest bail Under-Section 497 Cr-P-C from the High Court after exhausting the remedies from the courts below.
BEFORE THE HON’BLE HIGH COURT, BENCH (name)
Crl.Misc No._____________/B/2022
In the matter of:
(Full name of petitioner along with parentage and complete
address) …Petitioner
Versus
The State (the
stat is the necessary party)
(Full name of the complainant along with parentage and complete
address) …Respondents
PETITION FOR BAIL AFTER ARREST UNDER SECTION 497 Cr-P-C IN CASE
FIR NO. 01, DATED __________, OFFENCES UNDER SECTION ( )PPC REGISTERED WITH POLICE STATION (name),
DISTRICT (name)
Respectfully Stated: -
That the allegation leveled against the petitioner is false,
frivolous, and baseless. (Copy of FIR is attached).
That later on, the petitioner was apprehended by the local police
and he filed his post-arrest bail petition before the learned area magistrate,
which was dismissed by the same court vide order dated (__). Thereafter, the
petitioner filed his post-arrest bail before the learned Sessions Judge, (_),
which was entrusted to the court of learned Addl; Sessions Judge, (_), who
pleased to dismiss the same vide order dated (__) Copies of orders and grounds
of bail petitions are annexed as Annexure-…...
That the petitioner seeks his post-arrest bail from this Hon’ble
court on the following: -
G R O U N D S
That the allegation leveled against the petitioner in the
above-captioned case is false, baseless, and ill-founded.
That the petitioner is absolutely innocent and has falsely been
implicated in the instant case with mala fide intentions by the complainant in
connivance with local police.
That the petitioner has maliciously been roped in the instant case
for unjustified harassment, humiliation, and or ulterior motives.
That the petitioner has no concern in any manner with the instant
case but due to malice of the concerned police, the petitioner has been booked
in the instant case.
That the story narrated in the FIR is baseless, frivolous, and
concocted, the same is not befitting in the circumstances and has falsely been
cooked up with malice to achieve nefarious design at the end of a prosecution.
That the present accused is previously non-convicted in any case
and seeks bail in the present FIR.
That the case against the petitioner is one of the further
inquiries and there is not even a scintilla of evidence that could connect the
petitioner with the commission of any offense.
That the petitioner belongs to a respectable family, having a
blotless career.
That the petitioner is ready to furnish adequate surety according
to the satisfaction of this Hon’ble Court.
PRAYER
Under the circumstance, it is, therefore, most respectfully prayed
that the instant petition may kindly be accepted and the petitioner may kindly
be granted bail after arrest till the final disposal of the main case.
Petitioner
Through Counsel
Dated: (_)
Certificate: -
Certified as per instructions received by my client this is the 1st
bail petition on the subject ever moved before this Hon’ble Court.
No other petition on the subject matter is pending up till
the Hon’ble Supreme Court of Pakistan
…Counsel
NOTE: for filing of bail petition
before the high court.
Power of Attorney or
wakalatnama be filed along with the petition.
The accused/petitioner signs Wakalatnamana.
It should be clearly mentioned whether it is the first, second, or
third petition before this court is being filed.
The copies of the orders of the courts below along with bail
grounds and a copy of FIR must be attached.
All relevant documents are necessary to be filed along with the
bail petition.
No need for an affidavit of the accused, in case of a post-arrest bail petition.
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