IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No. _____________B/2002

Muhammad Hanif S/o Sakhi Muhammad, caste Rajpoort, R/o

86/ML, Tehsil Kahror Pakka, District Layya.
……PETITIONER
VERSUS
The State. ……RESPONDENT

PRE-ARREST BAIL PETITION U/S 498 CR.P.C.

In Case: -
F.I.R. No. 168/2002 Dated: 18.7.02
U/s: 380/411 P.P.C.
P.S. Fateh Pur (Layyah)

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly
been given for the purpose of their summons and citation.
2. That as per contents of the F.I.R., it is the allegation against
the petitioner that he committed theft of medicines amounting
to Rs. 600/- from the Govt. Rural Dispensary Chak No.
86/ML, where the petitioner is working as Ward Servant,
which is mere an allegation against the petitioner. Copy of
F.I.R. is attached as Annex “A”, whereas better copy is Annex
“A/1”.
3. That the petitioner seeks the concession of pre-arrest bail
inter-alia on the following:

GROUNDS
i) That the petitioner is innocent and roped up in this case
under the personal enmity and political rivalry.
ii) That the case is prima facie a conspiracy against the
petitioner and collusion between the police and the
complainant.
iii) That the contents of the F.I.R. are not giving
ingredients of any offence, thus no case prima facie
made out against the petitioner.
iv) That it is a case of private recovery, which is always
deprecated by the superior courts.
v) That on the face of it, it is a case of no evidence, even
no reference of witnesses is quoted in the F.I.R.
vi) That as per narration of the F.I.R., the person of the
petitioner is no more required for the purpose of
recovery or further investigation.
vii) That after registration of the case, the
Dispenser/Incharge concerned dispensary issued a
certificate that no such shortage was found either in
stock or in record. Copy of certificate is Annex “B”.
viii) That previously, a complaint having the story that the
petitioner had adopted the illegal practice, was
addressed to Zila Nazim, by the M. Mahmood Khan
Naib Zila Nazim Union Council No. 18, which was
forwarded to E.D.O. (Health). This application was
further forwarded to the office of the respondent No. 2
for the registration of this case. During the inquiry,
Lambardar and respectables of concerned area made
statements in favour of the petitioner and the complaint
was turned down.
ix) That the local police has no authority to register a case
against a public servant in connection with his official
responsibilities.
x) That the petitioner is previous non-convict and having
no record as well.
xi) That the petitioner has a blotless service of 12 years in
his credit.
 xii) That the local police in connivance with complainant
and under the political pressure is adamant to arrest the
petitioner. The petitioner belongs to poor but a
respectable family and his arrest will cause humiliation
and harassment along-with irreparable loss to him.
xiii) That the petitioner tried his level’s best to get the same
relief from the court of first instance, but being
encircled by the police and complainant party, it was
not possible for the petitioner. Hence, he was forced to
approach this court directly.

In view of the above submissions, it is

respectfully prayed that the petition in hand may
please be accepted and the petitioner may
graciously be blessed with the concession of pre-
arrest bail.
Any other relief which this Hon’ble Court
deems fit, may please be granted in the interest
of justice.
Humble Petitioner,
Dated: ________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first pre-arrest bail petition
moved by the petitioner. No such petition
has earlier been filed before this Hon’ble
Court.
Advocate
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

Crl. Misc. No. _____________B/2002

Muhammad Hanif Vs The State

INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Bail Petition affidavit.
3 Copy of F.I.R. alongwith better copy. A & A/1
4 Copy of certificate. B
5 Dispensation Application.
6 Affidavit.
7 Power of attorney.

PETITIONER,
Dated: __________

Through: -

Hammad Afzal Bajwa, Sheikh Muhammad Faheem,

Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. ____________/2002

In
Crl. Misc. No. _____________B/2002

Muhammad Hanif Vs The State

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth: -
1. That the above-titled application is being filed before this
Hon’ble Court, the contents of which should be considered as
part & parcel of the main petition.

2. That certified copies of Annexes “ ” are not readily

available. However, uncertified/photo state copies of the same
have been annexed with the petition, which are true copies of
the original documents.

It is, therefore, respectfully prayed that this

Hon’ble court may please dispense with the filing of
aforesaid copies of documents.

APPLICANT,
Dated: __________

Through: -
Hamad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. ____________/2002

In
Crl. Misc. No. _______B/2002

Muhammad Hanif Vs The State

DISPENSATION APPLICATION

AFFIDAVIT of: -
Muhammad Hanif S/o Sakhi Muhammad, caste
Rajpoort, R/o 86/ML, Tehsil Kahror Pakka, District
Layya.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-titled application are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of July 2002 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.
DEPONENT
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

Crl. Misc. No. _______B/2002

Muhammad Hanif Vs. The State

AFFIDAVIT of: -
Muhammad Hanif S/o Sakhi Muhammad, caste
Rajpoort, R/o 86/ML, Tehsil Kahror Pakka, District
Layya.

I, the above named deponent do hereby solemnly affirm

and declare as under: -
1. That the names and addresses of the parties have correctly
been given for the purpose of their summons and citation.
2. That as per contents of the F.I.R., it is the allegation against
the petitioner that he committed theft of medicines amounting
to Rs. 600/- from the Govt. Rural Dispensary Chak No.
86/ML, where the petitioner is working as Ward Servant,
which is mere an allegation against the petitioner. Copy of
F.I.R. is attached as Annex “A”, whereas better copy is Annex
“A/1”.
3. That the petitioner seeks the concession of pre-arrest bail
inter-alia on the following:

GROUNDS
i) That the petitioner is innocent and roped up in this case
under the personal enmity and political rivalry.
ii) That the case is prima facie a conspiracy against the
petitioner and collusion between the police and the
complainant.
iii) That the contents of the F.I.R. are not giving
ingredients of any offence, thus no case prima facie
made out against the petitioner.
iv) That it is a case of private recovery, which is always
deprecated by the superior courts.
v) That on the face of it, it is a case of no evidence, even
no reference of witnesses is quoted in the F.I.R.
vi) That as per narration of the F.I.R., the person of the
petitioner is no more required for the purpose of
recovery or further investigation.
vii) That after registration of the case, the
Dispenser/Incharge concerned dispensary issued a
certificate that no such shortage was found either in
stock or in record. Copy of certificate is Annex “B”.
viii) That previously, a complaint having the story that the
petitioner had adopted the illegal practice, was
addressed to Zila Nazim, by the M. Mahmood Khan
Naib Zila Nazim Union Council No. 18, which was
forwarded to E.D.O. (Health). This application was
further forwarded to the office of the respondent No. 2
for the registration of this case. During the inquiry,
Lambardar and respectables of concerned area made
statements in favour of the petitioner and the complaint
was turned down.
ix) That the local police has no authority to register a case
against a public servant in connection with his official
responsibilities.
x) That the petitioner is previous non-convict and having
no record as well.
xi) That the petitioner has a blotless service of 12 years in
his credit.
xii) That the local police in connivance with complainant
and under the political pressure is adamant to arrest the
petitioner. The petitioner belongs to poor but a
respectable family and his arrest will cause humiliation
and harassment along-with irreparable loss to him.
xiii) That the petitioner tried his level’s best to get the same
relief from the court of first instance, but being
encircled by the police and complainant party, it was
not possible for the petitioner. Hence, he was forced to
approach this court directly.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day of
July 2002 that the contents of this affidavit are true &
correct to the best of my knowledge and belief.

DEPONENT