Protective Bail Petition U/S 498-A Cr.P.C. what are the ingredients of protective bail? How to write the protective bail U/S 498-A Cr. P.C? The format of protective bail is given below, please make necessary changing as per the facts of the case.

Protective Bail Petition

PURPOSE OF PROTECTIVE BAIL U/S 498-A Cr. P.C:  To prevent the accused/petitioner from arrest or any other kind of threat in the area where the FIR was lodged.   

IN THE HON’BLE HIGH COURT, (name of the high court and its bench)

Crl. Misc. No._______/B/2021

In the matter of:

(Give full name, parentage, and address of petitioner)         …Petitioner

Versus

1.      The State

2.       (Give full name, parentage, and address of complainant/respondent)    …Respondents

PETITION FOR PROTECTIVE BAIL BEFORE ARREST U/S 498-A Cr. P.C IN CASE FIR NO. 1103, DATED 18.10.2021, OFFENCES UNDER SECTION  337-F(ii), 354 PPC REGISTERED IN P.S (name of the police station), DISTRICT (name of district)

Respectfully Sheweth:-

That the complainant/respondent No.2 lodged the instant baseless FIR on the basis of a fake and fabricated story and falsely implicated the petitioner in the instant case. (Copy is attached herewith as Annexure-A)

That the allegation against the petitioner is based upon false, frivolous, and mala fide intention in order to harass humiliate and pressurize the petitioner.

That the complainant is an influential lady and extending threats to the petitioner of dire consequences through police, hence the instant protective bail is being filed by the petitioner inter-alia on following: -

G R O U N D S

That the petitioner is presently residing in America and he wants to come to Pakistan in order to pursue the instant false case but due to the influence of the respondent No. 2 it is strong apprehension that the petitioner may be arrested from the airport in the instant false and factious case and if the respondent No. 2 succeeds to fulfill his nefarious designs and acts, then the petitioner shall suffer an irreparable loss.

That the petitioner has not any concerned with the present case in any manner whatsoever.

That the complainant/respondent No. 2 got registered the instant false case just to grab money from the petitioner and no offense is made out against the present petitioner.

That the petitioner has been falsely implicated in the instant case with mala fide intention and for ulterior motives by the complainant/ respondent No.2 in connivance with the local police authorities.

That the story narrated in the FIR is totally false, frivolous, baseless, and concocted and there is no ring of truth in it.

That the petitioner is ready to join police investigation as and when required and also ready to furnish adequate surety bonds to the entire satisfaction of this Hon’ble court.

Prayer:

In view of the above circumstances, it is, most respectfully prayed that the instant bail petition may kindly be accepted and the petitioner may graciously be allowed protective pre-arrest bail U/S 498-A Cr. P.C in order to approach the concerned sessions court for his bail before arrest, which is in the best interest of justice.

  Petitioner        Through        (Counsel)

 

Dated: ____________

Certificate: -

Certified as per instructions furnished by the petitioner this is the 1^st petition for protective bail before arrest on the subject ever moved before this Hon’ble Court.

 No other bail petition is pending on the subject matter up till the Hon’ble Supreme Court of Pakistan. 

…Counsel

IN THE HON’BLE HIGH COURT, (name of the high court and its bench)

Crl. Misc. No._______/B/2022

(Name of petition)      Versus the State etc.

PETITION FOR PROTECTIVE BAIL BEFORE ARREST U/S 498-A Cr. P.C

AFFIDAVIT

I, (if the petitioner is not available, then the counsel may give an affidavit on behalf of the petitioner), do hereby solemnly affirm and declare that as per information received by the petitioner/my client, the contents of the accompanying bail petition are true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.

Deponent

Verified on Oath at (name of the city) on day/month/year, that the contents of the above affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.

Deponent

IN THE HON’BLE HIGH COURT, (name of the high court and its bench)

Crl. Misc. No._______/B/2022

(Name of petition)      Versus the State etc.

PETITION FOR PROTECTIVE BAIL BEFORE ARREST U/S 498-A Cr. P.C

INDEX

Sr. No.	Description	Annex	Pages
1.	Pre-arrest protective bail petition with an affidavit		1 – 5
2.	Copy of FIR	A	6
3.	Wakalatnama

Petitioner    Through        (Counsel)