IN THE COURT OF SESSIONS JUDGE, LAHORE

B.A: NO._____________________/2018
1. Abdul Majid S/O Allah Ditta Caste Insari R/O Mauza
Kamas Tehsil and District Lahore.
(Presently Confined In District jail, Lahore)
ACCUSED/PETITIONER
VERSUS
1. THE STATE
2. Muhammad Shafiq S/O Muhammad Latif Caste Rajpoot
R/O Mauza Kamas Tehsil and District Lahore.
RESPONDENTS

Case FIR No: 404/14 Dated: 17.10.2014

Offences U/S: 365, 302, 201, 34, PPC
Police Station: Manga Mandi, Lahore.
PETITION UNDER SECTION 497Cr.PC. FOR BAIL AFTER ARREST
Respectfully Sheweth:-
1. That the petitioner has been arrested in case FIR No.404/14
dated 17.10.2014 registered U/S 365, 302, 201, and 43 PPC.
2. That the very brief version of FIR is to effect that on
07.10.2014 at about 07:00PM my real brother Naseer alias
Bagga S/O Muhammad Latif aged 30 years was present at
our house. He received telephone call of an unknown
person on his Mobile No.0306-4161806 and after that he
went out. He is not back till today. We have tried for his
 search but in vain. I am of the view that some unknown
person may have killed my brother. Today I came to the
Police Station for registration of the case and recovery of
my brother.
3. That the police investigated the case and submitted an
incomplete challan in the court on 08-12-2014.
4. That the petitioner is in custody from 12-11-2014 and is
now in judicial custody detained in district jail, Lahore.
5. That the case against the petitioner is essentially of further
inquiry for the following reasons:

a) That the petitioner was not named in the FIR and he was
implicated in this case by the complainant through his
supplementary statement dated: 11-11-14, while the
date of FIR is 17-10-2014. This delay of 24 days is
unexplained and shows the mala fide of the complainant.
b) That no eye witness of the alleged occurrence is present
on the record. And the case is of heresy evidence which
is not admissible in the eye of law.
c) That the case is of extra judicial confession which is also
not admissible in law.
d) That the alleged weapons (churri) were recovered on 25-
11-2014 from the houses of Abdul Majeed and Amanat
Ali on the same day which were visited by the police
earlier. Recovery after the lapse of such long time from
the residence create doubt in the case.
e) That some bones were recovered from Rohi Nala by the
police. No evidence was produced which can show that
those were shifted by the accused. There was is witness
in this regard.
f) That the Punjab Forensic Science Agency report does not
tell anything regarding the blood on the recovered
weapons (churri). There is no finding to the extent that
the blood is of the deceased Naseer alias Bagga.
 g) That the recovered articles with the bones are fake and
planted one just to strengthen the case against the
petitioner.
h) That the petitioner is in jail for the last four years and the
trial is not concluded yet.
i) That the petitioner has falsely been involved in the above
mentioned case with mala fide intentions and ulterior
motives in connivance with the local police merely to
humiliate the petitioner.
j) That the petitioner is ready to furnish bail bonds as to the
entire satisfaction of this Hon’ble Court in case he is
granted bail.
k) That the petitioner is previously non-record holder and a
law abiding citizen of Pakistan.
PRAYER:
It is, therefore, prayed that petitioner may kindly be granted
bail.
…………PETITIONER
Through:

Dated: 22.02.2018 Adnan Liaqat Ch.

Advocate High Court
4. Mozang Road, Lahore

Muhammad Usman Ch.

Advocate High Court
4. Mozang Road, Lahore
CERTIFICATE:-
As per the instructions received from the petitioner
this is first petition before this Hon’ble Court on the titled
subject.

Advocate