IN THE COURT OF JUDICIAL MAGISTRATE LAHORE PS Lorry Adda Lahore.

BAIL P.NO ______________________________________ 2009 Abu Bakar s/o Abdul Ghaffar, R/o House No. D/1719 Shahalam Gate, Lahore. Petitioner Vs The State Respondent Case FIR No. PS Lorry Adda Lahore. 489-F PPC Lahore 756/2008 Dated:24-10-2008

Offence Under Section District:

_________________________________

Petition under Section 497 CR PC for the Grant of Post arrest Bail
Respectfully Sheweth: That the above titled case has been registered on the complaint of one Shabeer Hussain Bajwa s/o Muhammad Din, resident of Band Khokhar Road, Badami Bagh, Lahore. According to the contents FIR it is alleged that the complaintent give 12 lakh Rs to someone for sending his nephew Sabir Ali out of country (Canada) a year ago w ho was not succeeded in his commitment to send his nephew out of the country who give complaint a Cheque of Abu Bakar of Rs.4 lakh of Bank Alfalah bearing No.0644160 of Shahalami Branch which deposited by the complaint in his Bank UBL which dishonored NOTE: that the story of FIR is not clear that how the petitioner involved in this matter.

2. That the petitioner has arrested and sends to the judicial lockup. 3. That the petitioner is innocent and the allegation is absolutely false baseless, concocted and based upon malafied intention, otherwise, he has nothing to do with alleged occurrence, prays for the concession of post-arrest bail, inter-alia, on the following:

GROUNDS
a. That the petitioner is absolutely innocent and has falsely been
implicated in this case with malafied intention of the complainant as well as active connivance of the local police. That actually the petitioner has wrongly aligated because the petitioner had no concern with the alleged FIR.

b. That prima facie no case is made out against the petitioner

and the petitioner is quite innocent, because the real matter is like that the person whom taken the money from the Complainant to send his nephew to Canada has come out through FIR NO 191/2009 which was also Registered with the instance of present Complainant against his partner Ghulam Rasool, The contents of this FIR are clear that the Complainant had given Rs.16 Lakh to Ghulam Rasool for sending his nephew out of country (Canada) which made this case of further inquiry.

c. That according to own showing of FIR, the complainant did

not give Rs.12, 00,000/-to the petitioner for sending his nephew and allegedly the person whom complainant given the said amount present FIR is silent which create reasonable doubt which is good ground of further inquiry.

d. That the matter between the parties is that of civil nature as

the petitioner runs his business in the name of Baber Traders and there are business relationship inter-se parties. The complainant and Ghulam Rasool being Directors of Imran Sports received a post dated cheque as against proposed supply of Gents Leather wallets to the petitioner but They did supply said articles where as the petitioner asked them for the Return of Cheque several times or give his articles as per contract but they put no ears on it and maliciously got dishonored the cheque and lodged this false case. The office bearer one of partner of complainant also issued a receipt in token receiving of cheque as advance. Copy of Partnership deed IQRAR NAMA is attached

e. That the petitioner is a businessman, he is not having

business of traveling agency and is also not engaged with business of sending the people abroad. The Copy of NTN No. and certificate of Anjuman Tajran Shalami.

f. That the petitioner has involved in this case with malafied

intention, two FIR has also been lodged of same offence

which clarifying the ulterior motives of the complainant there is no truth behind the lodging present FIR JUST an intention to get some money from the petitioner which the petitioner never taken from complainant any manner what so ever.

g. That the petitioner never involved in any criminal case and

having no record at all.

h. That the offences do not fall within the prohibitory clause of

section 497 Cr. P.C

i. That there is 11 days delay in lodging FIR which is totally un

explained which made this case of further inquiry.

j. The hole story as narrated in the FIR is totally concocted one. k. That the petitioner is law-abiding citizens and has no shady
past of such like cases. And the petitioner is maliciously arrested in this false case.

l. That there is no need of petitioner any more because he is

send to the judicial lockup.

m. That the petitioner is ready to furnish surety bond for the

entire satisfaction of this Honorable Court.

Prayer
It is therefore, respectfully prayed that this petition may kindly be accepted and petitioner may kindly be admitted to post-arrest bail till the final decision of this case.

Petitioner Through

Muhammad Kamran Siddique Advocate High Court Zahid Law Associates 2nd Floor Nawa-I-Waqt Building Shahra-e- Fatima Jinnah Lahore

IN THE COURT OF SESSION JUDGE LAHORE.

B.A .NO ______________________________________ 2009

Abu Bakar s/o Abdul Ghaffar, R/o House No. D/1719 Rang Mahal, Lahore.

Petitioner

Vs
The State Respondent
Case FIR No. PS Lorry Adda Lahore. 489-F PPC Lahore 756/2008 Dated:24-10-2008

Offence Under Section District:

Petition Under Section 498 CR PC for the Grant of Interim Bail

AFFIDAVIT OF

Abu Bakar s/o Abdul Ghaffar R/o

House No. D/1719 Rang Mahal, Lahore.

I, the above named deponent solemnly affirm and declare as under;

That the Contents of the accompanying petition are correct and true to the best of dependants knowledge and belief and nothing has been concealed

there from. Moreover, the deponent has not filed any other petition except the instant petition in any other Court.

DEPONENT
Abu Bakar

Verification
Verified on oath at Lahore on this 28th day of April 2009 that all the contents of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT
Abu Bakar

IN THE COURT OF SESSION JUDGE LAHORE.

BA . No. ______________________________________ 2009

Abu Bakar s/o Abdul Ghaffar, R/o House No. D/1719 Rang Mahal, Lahore.

Petitioner

Vs
The State Respondent
Case FIR No. 756/2008 PS Lorry Adda Lahore. Offence under Section 489-F PPC

_________________________________ Petition Under Section 498 CR PC for the Grant of Interim Bail

INDEX
Sr.No. 1. 2. 3. 4. 5. 6. 7. 8 . Description of documents Bail Application Affidavit Copy of ORDER SESSION COPY OF ORDER H.C Copy of FIR NO194/2009 A copy of iqrarnama ACCOPY OF PARTNERSHIP DEED copy of NTN No. Annexure Pages 1 to 4 5 6 to 10 11to14 15 16 17to18 19

A A1 B C D E

9. 10

COPY OF CERTIFICATE POWER OF ATTORNEY

20 21

Petitioner
Through

Muhammad Kamran Siddique Advocate High Court

Zahid Law Associates 2nd Floor Nawa-I-Waqt Building Shahra-e- Fatima Jinnah Lahore.