Bail Application

IN THE COURT OF SESSIONS JUDGE SHAHEED
BENAZIRABAD.
A. B.A No OF 2019
Kando son of Tooh Chandio

Muslim, Adult, R/O Village Gul Muhammad
Chandio, Taluka Kazi Ahmed, District Shaheed
Benazirabad …….….. …………………Applicant/accused
VS
The State…………..……………………….………….Opponent
Crime No: 264/2019, P.S,Kazi Ahmed

U/S 506/2, 353, 225, 224, 341, 147, 148 PPC
ANTICIPATROY BAIL APPLICATION

UNDER SECTION 498, Cr. P.C.
It is prayed on behalf of the applicant/accused, that

this honorable court may be pleased to admit him on pre
arrest bail in the above case/crime on the considersation of
the fallowing facts and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that

complainant, ASI Muhammad paryal Kalhoro lodged his FIR
at police station Kazi Ahmed, on 5-12-2019, at about 1430
hours, alleging therein that, today complainant along with his
subordinate staff wearing police dresses with police
ammunition, on government vehicle No. SPD-747, along with
driver departed from Nawab Wali Muhammad under entry
No. 8/4-11-2019, at about 1830 hours for patrolling and
capturing proclaimed offender and absconder accused within
their beat, during patrolling various places, at about 2000
hours, complainant party arrested the proclaimed offender
who is involved in crime No. 279/2018, U/S 3/4 PEHO, crime
No. 26/2019, U/S 5 Gambling Act, crime No. 62/2019 U/S
3/4 PEHO of P.S Kazi Ahmed, namely Jumma son of Sultan
Chandio R/O Village Muhammad Chandio, Taluka
Nawabshah at Jhalo Masjid Stop, who made cries, on his
cries, relatives of that persons namely Manthar son of
Muhammad Ismail Chandio having Hatchet, Meehon son of
not known Chandio having Lathie, Kando son of not known
Chandio having Lathie, Saddique son of Sultan Chandio
having having Hatchet all R/O Village Muhammad Chandio
and 15/16 unknown persons having lathies were came there,
who were seated at hotels situated neat Jhalo Masjid Stop,
who all seeing cleary and would be indentified if seen again,
who all restrained/deterred the complainant party from their
legal duties and by pushing the complainant party rescued
the proclaimed offender namely Jumma Chandio and went
away by extending murderous threats to the complainant
party by stating that if the complainant party chased behind
them they will face consequences and other accused persons
blocked the raod by keeping bricks and other things on road,
thereafter complainant party opened the road by removal the
bricks on the road, looking to the circumstances, complainant
party did not arrest any person and also informed the whole
situation to their officers, who ordered him to lodged the FIR,
hence this FIR.
After registering of the FIR, applicant/accused was

unaware about such lodgment of this false FIR against him,
but when police of PS Kazi Ahmed is started hunting for the
applicant/accused, malafidly, to arrest him , finding him not
there have left the threats to come again to arrest the
applicant/accused, when applicant/accused came to know
about this false FIR registered against him, hence this pre
arrest bail application on the following grounds.
-: G R O U N D S :-
1. That the case registered against the applicant/accused and co
accused is false and fabricated one, he has committed no any
alleged offence, but he has been falsely implicated by the
complainant with malafide intention for ulterior reasons.
2. That admittedly FIR is delayed about one day without furnishing

any plausible explanation, which goes to show that after
deliberation and consultation, each and every things has been
managed by the complainant by applying his sharp mind just to
dragged the applicant/accused and co accused in false criminal
cases.
3. That it is further worth to mention here that, the complainant

stated in his FIR, that when complainant party arrested the
proclaimed offender Jumma Chandio, he made hue and cries
and on his cries, so many peoples came there along with their
respective weapons, but there is no any single mark, injury,
scratch, or any caused sustained by any person from
complainant side or on their government vehicle, so this things is
creating highly doubt in prosecution story, so case of
applicant/accused is doubtful and he is entitled for pre arrest
bail.
4. That it is further worth to mention here that, complainant party

disclosed names of some persons along with their parentage and
addresses, so who it can be possible, that on first time,
complainant knows the persons with their parentage, so this
things is creating highly doubt in prosecution story, which goes
to show that each and every things have been managed by the
5. That place of incident shown by the complainant is very thickly

populated area, as so many peoples are residing surrounding
there, but except police officials, there is no any independent
witness cited in the FIR, who corroborates the version of
complainant.
6. That there is no specific role, part injury on the other

applicant/accused and co accused person, while there are
general allegation upon the applicant/accused.
7. That at the time of alleged incident, applicant/accused was not

present there and he was unaware about his false implication in
the present case.
8. That applicant/ accused is not hardened criminal nor desperate

nor previous convict as per instruction.
9. That applicant/ accused possessed good reputation in his

vicinity.
10.That it is well settled principle of law that if a single doubt arose

in prosecution story, then each and every benefit should go in
favour of the accused party at bail stage.
11.That there is no any previous criminal record against the

applicant/ accused.
12.That PWs cited in the FIR, he is pocket person and subordinate

staff of complainant.
13.That there is no appreshanssion of tempering with the evidences

as all the PWs are inrerested and subordinate staff of the
complainant
14.That applicant/accused is ready to furnish solvent surety to the

satisfaction of this honorable court
15.That orther ground will be urged at the time of arguments.

DATED _____________ ADVOCATE FOR
APPLICANT/ACCUSED
CERTIFICATE
This is Certify that this is 1st Pre Arrest Bail

application on behalf of the applicant/accused, prior to this
no other ABA or bail on behalf of the applicant accused is
pending before this Honourable court. As per instruction.
ADVOCATE FOR APPLICANT/ACCUSED

IN THE COURT OF DISTRICT & SESSIONS JUDGEG
SHAHEED BENAZIRABAD.
B. A. No: OF 2019.
Naseer Ahmed son of Rehmo Ghori

Muslim, Adult, Presently confined at
District Jail Shaheed Benazirabad……...….Applicant/accused
VS
The State…………….……… .…………………………Opponent
Crime No: 72/2019, P.S, Bandhi

U/S 269, 270, 273, 336-B PPC.
BAIL APPLICATION
UNDER SECTION 496 Cr. P.C.
It is prayed on behalf of the applicant/accused, that this

Honorable Court may be to pleased to release him on bail in
the above case/crime, on the consideration of the fallowing
facts and grounds:-
-: F A C T S :-
Briefly facts leading to present case are, that

complainant, ASI Mohram Din Khashkheli lodged his FIR at
police station Bandhi, on 25-09-2019 at about 1220 hours,
today complainant along with his subordinates with police
ammunition on government mobile No. SPD 769 along with
driver HC Ali Gul under entry No. 08/25-09-2019 at about
1115 hours were departed for patrolling within their beat,
during patrolling veroius places, complainant got spy
information, Naseer Ahmed Ghori has been sealing the Z-21
Gutka in his shop, which are infectious for human being, after
getting such information, complainant party went towards
pointed places, when at about 1130 hours complainant party
reached at shop of Naseer Ahmed Ghori, where they saw one
person was standing at his shop and in his front one plastic
bag was lying, who by seeing the complainant party tried to
escape away, on the suspicious basis complainant party
stopped their vehicle laid down from it encircled him and
captured him, due to non availability of private mashir, HC
Ghulam Akbar and PC Rano Khan were acted as mashirs,
who inquired about his name, address e.t.c, in which captured
person disclosed his name to be applicant/accused, from his
body search two notes of 100/100 were recovered from his
side pocket, same were secured by the police, thereafter
complainant party checked the said plastic bag, in which 4 full
packets of Z-21 Gutka were lying, thereafter complainant
party sealed the said plastic bag and inquired about the said
bag from the captured person, who disosed that same is mine
and I am sealing the same on money, therefore applicant
accused was arrested in above case crime, complainant party
prepared such mashirnama before the mashirs and lodged
present FIR, hence this FIR.
After registration of the FIR, applicant/accused was

arrested, who is in judicial custody, hence this bail application
on the following grounds.
-: G R O U N D S :-
1. That the case registered against the applicant/accused is false
and fabricated one he has committed no any alleged offence but

he has been falsely implicated by the complainant with malafide
intention for ulterior reasons.
2. That in fact no such incident, whatsoever stated in the FIR has
ever taken place, but this whole drama has been staged by the
complainant and his sweet obligor witnesses with malafide
intention for ulterior reasons, while actual facts are that, due to
police policy complainant of this case has been hired to lodge
false and factitious FIRs against the innocent person including
applicant/accused, otherwise applicant/accused is totally
innocent and he has committed no any alleged offence.
3. That Z-21 Ghutka and amount etc have been foisted upon the
applicant/accused, otherwise he has no concerned with the

alleged recovery.
4. That complianant failed to associate independent witnesses
having the populed area there is voialtion of 103 Cr PC.
5. That all sections applied in the FIR are bailable.
6. That all PWs cited in the FIR are interested witnesses of the
complianant and are sweet obligor.
7. That as per contents of the FIR nothing has been committed but
this whole drama has been staged by the complainant with

malafide intention.
8. That there is no apprehension of the tampering with the
evidence, as all the PWs are sweet obligor of the complainant.
9. That applicant accused is ready to furnish solvent surety to the
satisfaction of this Honourable Court.
10. That other grounds will be urged at the time of arguments.
DATED__________ ADVOCATE FOR

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application of

the applicant/ accused, before this Honourable court, prior to
this no bail is pending on behalf of the applicant/accused
before this Honourable court.
Advocate for applicant/accused

BENAZIRABAD.
B.A No OF 2019
Aslam son of Shahmeer Chandio

Presently confined in District Jail
Shaheed Benazirabad ….. …………………Applicant/accused
VS
The State………………..……………………….………….Opponent
Crime No: 27/2019, P.S, Pubjo

U/S 324, 337 Lii, Aii, Ai, 504, 147, 148 PPC.
BAIL APPLICATION
It is prayed on behalf of the applicant/accused,

that this honorable court may be pleased to release him, on
bail in the above case/crime on the considersation of the
fallowing facts and grounds:-
-: F A C T S :-
complainant, Ali Hassan son of Muhammad Khan Dahri
lodged his FIR at police station Pubjo on 25-07-2019 at about
1900 hours, alleging therein that, complainant is doing Harpa
and is residing at above mentioned address, there is previous
dispute of complainant with Jinsar son of Shahmeer Khan
Chandio, they were annoyed with complainant and extending
threats him that they will see them and will kill them, on 17-
07-2019 complainant along with his brother Muhammad
Ishaque Dahri were gathered went to their land for looking
[2]
after the cow and then they both looking after the same went
towards their village when at about 5:00 Pm evening time,
they reached at Jamal Shah link Road near land of Haji Jaffar
Dahri where they saw, each Aslam having pistol in his hand,
Jinsar having hatchet in his hand, Iqbal having iron rod in his
hand, Akram and Gul Bahar having lathies in their hands all
sons of Shahmeer Chandio All R/O Village Ali Nawaz
Chandio, Taluka Kazi Ahmed , they all came there from their
house’s side, on their coming they stopped the complainant
party, meantime, Aslam by aiming his pistol upon them by
giving hackles saying that complainant party has been already
fought with them, so today they will not spare them and will
kill them, due to fear of weapons complainant party remained
silent, meantime, Jinsar with intention to commit murder
caused hatchet blow to the brother of complainant
Muhammad Ishaque on his head and also Iqbal chandio
caused iron rod blow to him on his head, who by raising cries
fell down on earth, other accused having lathies they caused
lathies blow to brother of complainant on his different part of
body, on his cries, cousin of complainant Ali Asghar son of
Tooh Dahri and other villagers by giving hackles were rushed
towards them, accused persons by seeing them caused kickes
and fists blows to complainant party and stated that today
they will save themselves, but they will come again and will
kill them by saying so all accused persons run away towards
their house , meantime complainant party saw the blood was
oozing from the head of brother of complainant and he
sustained injury on his left side of hand he became
unconscious, thereafter complainant party arranged the
vehicle and then they took him at Pubjo police station for
[3]
taking letter of medical and shifted him at hospital of Shahpur
Jahania, where doctor referred him to PMCH Nawabshah and
then they shifted him at PMCH Nawabshah after getting free,
complainant came at PS and lodged present FIR.
After registration of FIR, applicant/accused was

arrested, who is in judicial custody hence this bail application
on the following ground.
-: G R O U N D S :-
16.That the case registered against the applicant/accused and co
accused is false and fabricated one, he has committed no any
complainant and his witnesses with malafide intention for ulterior
reasons.
17.That admittedly FIR is delayed more then 7 days, without

furnishing any plausible explanation, which goes to show that after
deliberation and consultation, each and every things has been
managed by the complainant by applying his sharp mind just to
dragged the applicant/accused and co accused in false criminal
cases.
18.That it is further worth to mention here that, the complainant stated
in his FIR, that there is previous dispute between the complainant
and applicant/accused, but he failed to show any reaons, that in
what manner or in what object, such enimity has been arise in
between them, so this thing is creating highly doubt in prosecution
story, and the case of the applicant/accused is requires further
inquiry.
19.That it is surprisingly worth to mention here that, complainant

stated that all accused persons having deadly weapons, except the
[4]
brother of complainant, neither complainant caused any injury nor

he tried to rescue his brother from the cluthes of accused persons
his role in this whole story is silent and quit, so this thing is creating
highly doubt in prosecution story and the case of the
applicant/accused is requires further inquiry.
20.That place of incident shown by the complainant is very thickly

populated area, as so many peoples are residing surrounding there,
but except counsin of complainant, no any independent witness
cited in the FIR who corroborate the version of complainant.
21.That no injury is on the part of the cousin of complainant,

applicant/accused has been shown with direct role with malafide
intention, so it is verified from the contents of the FIR, that, there is
no specific role, part injury on the other applicant/accused and co
accused persons, while there are general allegation upon the
applicant/accused.
22.That applicant/ accused is not hardened criminal nor desperate nor

previous convict as per instruction.
23.That applicant/ accused possessed good reputation in his vicinity.

24.That it is well settled principle of law that if a single doubt arose in
prosecution story, then each and every benefit should go in favour
of the accused party at bail stage.
25.That no any injury sustained by the brother of complainant or

anyone, if any sustained same are self suffered.
26.That medical certificate if obtained by the complainant party same

is false and managed one.
27.That there is no any previous criminal record against the applicant/

accused.
[5]
28.That PWs cited in the FIR, he is pocket family member of

complainant and is pocket person of complainant.
29.That there is no appreshanssion of tempering with the evidences as

all the PWs are inrerested and family member of the complainant
30.That applicant/accused is ready to furnish solvent surety to the

satisfaction of this honorable court
31.That orther ground will be urged at the time of arguments.
DATED _____________ ADVOCATE FOR
APPLICANT/ACCUSED
CERTIFICATE
This is certify that this is 1 st bail application on

behalf of the applicant/accused, prior to this no other bail on
behalf of the applicant accused is pending before this
Honourable court. As per instruction.

IN THE COURT OF SPECIAL JUDGE OF CNSA AND
SESSIONS JUDGE SHAHEED BENAZIRABAD
Special case No. of 2019
Dildar @ Dillo son of Toohar @ Soomar Chandio

Shaheed Benazirabad ….. …………………Applicant/accused
VS
Crime No: 116/2016, P.S, Kazi Ahmed

Offence, 9/B, CNSA ,
BAIL APPLICATION
It is prayed on behalf of the

applicant/accused, named above, that this Honourable Court
may be pleased to release him, on bail in the above
crime/case, on the consideration of the fallowing facts and
grounds:-
-: F A C T S :-
Briefly facts of the case are that, Complainant, ASI

AD/SHO Kareem Bux Lakho lodged his FIR at police station
Kazi Ahmed, on 9-05-2019, at about 1900 hours, alleging
therein that, today complainant along with his staff each HC
Muhammad Rasheed, PC Munwar Ali, PC Pir Ashraf, PC
Mumtaz Ali wearing police dressing having polices
amonation on government vehicle No: SP 175 along with
driver PC Piyaro Khan under entery No: 18 Dateted 9-5-2019
[2]
at about 1715 hours were departed for petrolling within there
limits, during petrolling various placeses when they reached
link road leading towords Lakhat, at about 1800 hours at
Lakhat Mouri, where thay saw one person was coming in
front how by seeing the police mobile towards him, that
person tried two run away towards eastern side of shakh ji
tap, due to suspicious basis, police party stopped their
vechile laid down from it, encircled him and very tactfully
captured him, due to non availability of private Mashir, Hc
Muhammad Rasheed and PC Munawar Ali ware acted as
Mashir , who inquired about name, address of captured
person , who disclosed his name to be applicant/accused,
from his body search complain party recoverd one shopper of
white colour from his right side pocket and saw, in which two
pieces of chars were lying, and also recovered one note of Rs
100 from his right side pocket, the said chars was waited
which became 800 grams same was sealed, captured person
was inquired about chars, who disclosed that he was selling
the chars , acussed was arrested ubder above mentioned
crime, thereafter, such Mashirnama was prepared before the
Mashirs, with their signatures, the accused and recovered
property were brought at police station and present FIR was
lodged.
After registration of FIR, the applicant accused was

arrested, and challan has been submitted before concerned
court , hence this bail application on behalf of
applicant/accused with following grounds.
[3]
-: G R O U N D S :-
and fabricated one, he has committed no any alleged offence,
but he has been falsely implicated by the complainant with
malafide intention for ulterior reasons.

ever taken place, but this whole drama has been staged by the
complainant just to show false implication of the
applicant/accused in present case by foisted such quantity of
alleged Chars upon the applicant/accused, so that he come in
his illegal terms, otherwise applicant/accused is innocent he
has no concerned with the alleged offence.
3. That due to Eid Ul Fittar occasion, police as usually

demanded illegal Kharcha amount from the innocent person
and on refusal they by foisting alleged Chars or other things
falsely implicated the innocent person including
applicant/accused.
4. That nothing has been recovered from the applicant/accused,

but, amount and chars as alleged has been foisted upon the
applicant/accused with malafide intention for utlrior reasons.
5. That place of incident is managed one and same has been

shown knowingly and deleberatly just to make this false case
otherwise, applicant accused has no concerned with the
alleged offence.
[4]
6. That there is voilatin of section 103 Cr, PC.

7. That applicant/acused is rotting in jail since his arrest without
any fault and indefinite period.
8. That as per ingredient of section 9/B CNSA, which is

misapplied by the police, which is not attracting to the present
case.
9. That prosecution story is uncoroborative, unsupported and

without any substantiation and same is false and fabricated
one.
10.That the applicant/accused has possessed good reputation in

his vicinity present case is nothing but complainant has no left
lack to show his efficiency, just to blackmail and pressurize him.
11.That case has been challaned, applicant/accused is no more

required for further investigation.
12.That nothing has been committed by the applicant/accused

but this whole drama has been staged by the complainant.
13.That it is settled principle law that if the single benefit of

doubt arose in prosecution story, then each every benefit of
doubt should go in favour of the applicant/accused at bail
stage.
14.That complainant has not shown size, shape and further

description of chars, but only shown chars in the contents of
the FIR, which creating highly doubt in prosecution story.
[5]
15.That no purchaser or further location has been discribed by

the complainant party but there is only foistation of the chars
upon the applicant/accused with malafide intention for ultior
reasons.
16.That complainant party not shown any measurement articles

for weighting about the Chars but only shown quantity of
Chars 800 grams, which is clear malafide part of complainant
17.That from the contents of the FIR it be indicated that,

complainant has been hired to make such stereotyped story.
18.That there is no apprehension of absconsions of the

applicant/accused who is ready furnish solvent surety to
19.That other ground will be urged at the time of hearing when

the entire papers will be available.
Dt__________ ADVOCATE FOR

APPLICANT/ACCUSED
CERTIFICATE
This is certify that this is 1 st bail application on

behalf of the applicant/accused, prior to this no other bail on
Honourable court .

N THE COURT OF CIVIL JUDGE AND JUDICAL
MAGISTRATE –I KAZI AHMED
B. A. No: OF 2019.
Javaid son of Haroon

Presently confined in District Jail Shaheed
Benazirabad…………………………………..Applicant/accused
VS
The state ………………………………………………….Opponents
Crime No. 96/2019, P.S Kazi Ahmed

U/S 3/4 , PEHO.
BAIL APPLICATION

applicant/accused, that this Honorable Court may be pleased
to release him, on bail in the above case/crime on the
consideration of the fallowing facts and grounds:-
-: F A C T S :-

complainant, ASI Kareem Bux Lakho lodged his FIR at police
station Kazi Ahmed, On 21-04-2019, at about 1900 hours,
alleging therein, that today complainant along with his staff
each HC Muhammad Rasheed, PC Ali Akbar, PC Muhammad
Rafique with police ammunition, on government vehicle No.
SPE 175 along with driver PC Rasool Bux, under entry No. 16
[2]
dated 21-04-2019, at about 1645 hours, were departed for

patrolling within their beat, during patrolling when they
reached at Juna Mouri, where they got spy information, that,
Javaid Kumrani by installing the Bathi of Desi Liqour by
preparing Desi Liqour sell out the same, after getting such
information, complainant party went towards pointed place,
when at about 1730 hours, they reached at Juna Mouri, near
house of Javaid Kumrani, they saw, one person was standing
at the adjacent of the house, his near, 2 white colour of plastic
gallons, one plastic Drum of blue colour, one Deghra were
lying there, who by seeing them tried to run away, on the
suspicious, complainant party stopped their vehicle, laid
down from it very tactfully encircled him and captured him,
due to non availability of private mashir, HC Muhammad
Rasheed PC Ali Akbar were acted as mashir, inquired about
the name, address etc from captured person, who disclosed
his name to be applicant/accused, from his body search,
nothing was recovered except wearing dress, recovered 2
plastic gallon were checked and opened it, in which 10/10
litters of Desi Liqour were lying, in which 1/1 litter of Desi
Liqour took for chemical analysis and remaining Desi Lioqur
were sealed separately, further they saw, recovered plastice
Drum and Deghri, which were used for preparing Desi Liqour
were empty, same was secured by the police, further accused
disclosed, that he by making desi Liqour sell out the same,
accused was arrested under above mentioned case/crime,
such mashirnama was prepared before the mashirs along with
their signatures, thereafter accused and recovered property
brought at police station where present FIR was lodged.
[3]
After registration of the FIR, the applicant/accused was

on the following grounds .
-: G R O U N D S :-
1. That the applicant/accused is innocent and had committed no

complainant with the malafide intention for the ulterior
reasons.
2. That the case property have been foisted upon the

applicant/accused, just to show false implication of the
applicant/accused.
3. That no such type of incident whatsoever stated in the FIR has

ever taken place but this whole drama has been staged by the
complainant with malafide intention for ulterior reason, while
actual facts are that, due to some persomal grudge and
hindrance, the opponent party of the applicant/accused is
hired to the complainant of this case, just to lodge this false
FIR against the applicant/accused, otherwise,
applicant/accused is totally innocent.
4. That nothing was recovered from the exclusive possession of

the applicant/accused and alleged property have been clearly
foisted upon the applicant/accused.
5. That the place of incident has been shown by the police,

which is thickly populated area but no one indepdedant
[4]
witness has been cited by the police, and complainant

knowingly and deliberately by managing things with his
subordinate staff has lodged present FIR.
6. That complainant with malafide intention on the command of

opponent party of the applicant/accused falsely implicated
the applicant/accused, just to bow him in this false case and
put the applicant/accused behind the bar.
7. That there is violation of sec tion 103 Cr PC.
8. That alleged recovered Desi Liqour have been shown as

recovered and its quantity have been shown 10/10 litters
without measuring by measuring articles, which creating
highly doubt in prosecution story, even otherwise, the
quantity for sample has not been shown, the actual
measurement that how much Desi Liqour were sealed
separeatly for chemical analysis, so it be indicated that things
have been managed by the complainant and his staff with
malafide intention for utlrior reasons.
9. That malafide part of the complainant is that, he shown in his
FIR, that police party took 1/1 bottle of Desi Liqour from the
alleged gallons for chemical analysis, but complainant party
failed to disclosed proper description of bottle, size, colour,
company, so this things is creating highly doubt in
prosecution story, so case of applicant/accused is required
further inquiry.
[5]
10.That there is no previously record of such type against the

applicant accused, so as per contents of the FIR it be indicated
that, each and every thing has been cooked up.
11.That section applied in the FIR doesn’t fall within the

prohibitory clause of section 497 Cr, PC.
12.That it is a settled law that bail should not be treated a

punishment and every single benefit of doubt should goes to
the applicant event at bail stage.
13.That applicant/accused is ready to furnish his solvent surety

to the satisfaction of this Honorable court.
14.That other ground will be urged at the time of arguments.
DATED__________
CERTIFICATE
This is to certify that this first bail application
on behalf of the applicant/accused, prior to this no any bail or
other case has been filed before this Honourable Court by the
applicant accused.

IN THE COURT OF SESSIONS JUDGE
SHAHEED BENEZIRABAD
A.B.A No. OF 2019
Adnan @ Soomar @ Porho son of Bahadur Jatoi

Muslim, Adult, R/o Village Lakhat, Taluka Sakrand
District Shaheed Benazirabad …………………....Applicant/accused
VS
The state ………………………………………………..…….Opponents
Crime No. 20/2018, P.S Lakhat

U/S 353, 225, 224, 148, 149 PPC.
ANTICIPATOTY BAIL APPLICATION

It is prayed on behalf of the applicant/accused ,

that this Honorable Court may be pleased to admit him on pre
arrest bail, in the above case crime, on the consideration of the
-: F A C T S :-

complainant, SHO Muhammad Daud Rind lodged his FIR at
police station Lakhat, on 6-11-2018 at about 1830 hours,
alleging therein that, today complainant along with his staff
each HC Soomar Khan, PC Anwar Ali, PC Altaf Hussain, PC
Niaz Hussain were duly armed with officials weapons, on
government vechilce No. SPC 171, along with driver PC
[2]
Hakim Ali, were departed under entry No. 14 dated 6-11-

2018, at about 1700 hours, for patrolling with their beat, when
complainant party lead from Bachaoo when at about 1715
hours, they reached at Pir Chararo Jhang Pathak, where they
saw, from eartern side of Jhang, three persons were came at
Bacha Band, in which one person of proclaimed
offender/absconder namely Mir Hazar son of Rasool Bux @
Banhoon having KKs, and were two unknown persons, who
at once see the police mobile, Mir Hazar made straight fire
upon the police mobile and two persons took out their pistol
and also made firing run towards Jhang, the complainant
party laid down from it and saw fire was hit on the door of
driver side, the complainant party very tactfully chased
behind the accused, the accused persons made making brust
just to create harassment and terrify, the complainant party
also made firing and tried to closely encircled them, such
encounter was made about 10 minutes, the police accused the
Mir Hamzo along with KKs, HC Soomar Khan PC Anwar
were made as mashir, and will prepare the mashirnama,
meantime, on the side of village Lakhat each Dadlo having
KKs, Deedar having DDBL, Sohrab having pistol, Mohram
having Pistol, Mitho having Pistol all sons of Rasool Bux @
Bhanoon, Bilawal @ Billo, Wazeer, both having KKs, Sher
Muhammad, Neen, both having Pistol, they all by making
firing and made brust came there and also dettered the
complainant party from their duties, accused Deedar caused
butt blow of his back side pistol to complainant on his left
shoulder, and all accused resuced the accused absconder
accused Mir Hamzo along with KKs from the complainant
party, thereafter accused Sohrab also hit of his back side of
[3]
weapon to HC Soomar Khan on his left side of eye and torn

his cloth, thereafter all accused by making firing run away
towards Jhang/jungle, complainant party chased behind
them, but due to darkness all accused succeeded to run away,
thereafter complainant party went to PS and lodged the
presnt FIR. Hence this FIR.
After registering of the FIR, applicant/accused was

unaware about such lodgment of this false FIR against him,
but when police of PS Lakhat is started hunting for the
applicant/accused, malafidly, to arrest him , finding him not
there have left the threats to come again to arrest the
applicant/accused, hence this pre arrest bail application on
the following grounds
-: G R O U N D S :-
15.That the case registered against the applicant/accused is false

and fabricated one, and he has committed no any alleged
offence, things has been managed by the complainant with
his subordinate staff with malafide intention for ulterior
reason, otherwise applicant/accused is innocent, and
committed no offence.
16.That nothing has been committed by the applicant/accused, it

is surprinsingly worth to mentioned here that, the name of
applicant/accused was not mentioned in the FIR, but police
after consultation and deliberation, on the connivance of
some political persons given the name of applicant/accused
[4]
in challan sheet, just to show false implication of the
applicant/accused, otherwise, no such type of incident has
ever taken place and applicant/accused is totally innocent.
17.That malafide part of the complainant is that, he stated in his

FIR that, all accused having deadly weapons made firing
upon the complainant party, on that account, police party
also made firing upon the accused persons, and such
encounter was continued about 10 minutes, but no anyone
have sustained firearm injury, so this thing is creating highly
doubt in prosecution story, and case of applicant/accused is
requires further inquiry.
18.That there is malafide part of the complainant party is that, at

the time of alleged incident, applicant/accused was not
available at the place of offence, but police malafidly given
the name of applicant/accused in challan sheet just to oblige
the some political persons.
19.That malafide part of the complainant is that, he failed to

chased behind the accused persons and also failed to
captured anyone from the accused person, so this things is
shown the negligency of complainant party, as they are failed
to performed their duties, but they with malafide intention
make this false story and also implicated the persons of their
choice in this false case.
20.That applicant/accused was unaware about such lodgment of

FIR registered against him, but when police of PS Lakhat is
started hunting for the applicant/accused, raided his house
[5]
and have left the threats to come again and arrest him, then
applicant/accused came to know above false FIR has been
registered against him with malafide intention by given the
name of applicant/accused in challan sheet.
21.That there is no any specific role, part is assigned to the

applicant/accused, mere there are general allegation upon
the applicant/accused, just to show his false implication.
22. That the place of incident has been shown by the police,
which is thickly populated area, but no one independent
23.That there is violation of section 103 Cr PC.
24.That applicant/accused possessed good reputation in the

vicinity and he is not involved into such acitivities but he has
been roped by the police with malafide itnention
25.That applicant accused is not convicted previously, as per

instruction.
26.That it is settle principle law that, if any single doubt arose in

prosseuction story, then each and every benefit of the doubt
should goes in favour of the applicant/accused at bail stage.
27.That there is no apprehension of the tampering with the

evidence as applicant/accused he is ready to furnish solvent
surety to the satisfaction of this Honourable Court.
[6]
28. That applicant/accused is ready to furnish his solvent surety
to the satisfaction of this Honorable court.
29. That other ground will be urged at the time of arguments.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this first bail application on behalf of the
applicant/accused in respect of the above case/crime, prior to this
no any ABA, or Bail has been filed before this Honourable Court by
the applicant accused.

IN THE COURT OF SESSIONS JUDGE
SHAHEED BENEZIRABAD
A.B.A No. OF 2019
Adnan @ Soomar @ Porho …….………………....Applicant/accused
VS
The state ………………………………………………..…….Opponents
Crime No. 20/2018, P.S Lakhat

U/S 353, 225, 224, 148, 149 PPC.
AFFIDAVIT
I, Adnan @ Soomar @ Porho son of Bahadur Jatoi,

Muslim, Adult, R/o Village Lakhat, Taluka Sakrand District
Shaheed Benazirabad, do hereby state on oath as under:-
1. That I am applicant/accused in the above case, hence fully

conversant with the facts of the present case.
2. That accompanying application and its affidavit has been

drafted under my instruction, the contents are same true and
correct.
3. That I have committed no offence I have been falsely implicated

by the complainant with malafide intention for the ulterior
reasons otherwise I am innocent.
4. That Police of PS Lakhat is behind me and have raided my

house, have left the threats to come again to arrest me.
Whatever stated above is true and correct to the best of

my knowledge and belief.
I know the Deponent Deponent.
Advocate
MAGISTRATE –I KAZI AHMED
B. A. No: OF 2019.
1. Ghulam Rasool @ Lajoo son of Dodo Khan Jatoi

2. Ghulam Sarwar son of Dodo Khan Jatoi
Both confined in police lockup at Kazi Ahmed

District Shaheed Benazirabad
………………….Applicants/accused
VS

U/S 3/4 , PEHO.
BAIL APPLICATION

applicants/accused , that this Honorable Court may be
pleased to release them, on bail in the above case/crime on
the consideration of the fallowing facts and grounds:-
-: F A C T S :-

complainant, SIP Imam Bux Mari lodged his FIR at police
station, Kazi Ahmed, on 28-01-2019, at 1300 , alleging therein
that, today complainant along with his staff, PC Ghulam
Murtaza , PC Mansoor Ali , with police ammunition, on police
mobile No. SP-508 along with driver Rasool Bux, departed
from police station, under entry No. 8 dated 28-01-2019, at
about 1100 hours, they were patrolling within their beat,
various places, when they reached at Lakhat leading towards
link raod, near Lakhat Mouri, at about 1200 hours, where
complainant party saw that, two persons were standing at
Mouri, from their front, two gallon of 20/20 litters of white
colour were lying there, who by seeing the complainant party
by taking the gallons tried to run away, the complainant party
got down from the mobile, and apprehended the run away
persons containing the gallons, the complainant tried to act
for private Mashir but not found, so PC Ghulam Murtaza PC
Mansoor Ali were made mashirs, thereafter complainant
paty inquired about the names etc from captured persons, on
which first accused disclosed his name to be Ghulam Rasool @
Lajoo son of Dodo Khan Jatoi, from his body search the
complainant party secured 5 notes of 100/100 from his side
pocket, and also complainant party checked the gollon of 20
litters and saw that, in which Desi liquor was lying,
meantime, complainant party took one bottle Desi liquor for
chemical analysis and sealed the same, and other remaining
Desi liquor were sealed seperatly, 2nd person disloced his
name to be Ghulam Rasool son of Dodo Khan Jatoi, from his
body search complainant party secured one violet from his
front pocket in which 3 notes of 100/100 was secured by the
police and also recovered one watch from his left side of hand,
copyright of Rado company of gold colour, complainant party
checked the gollon of 20 litters and saw that, in which Desi
liquor was lying, meantime, complainant party took one
bottle Desi liquor for chemical analysis and sealed the same,
and other remaining Desi liquor were sealed seperatly further
accused disloced that, the same Desi liquor is their property
and they used to sell out the same and also standing there for
selling purpose, however accused have been arrested under
above mentioned sections, such Mashirnama was prepared
before Mashirs thereafter, accused along with recovered
property brought at police station, where present FIR was
lodged, hence this FIR.
After registration of the FIR, the applicants/accused
were arrested, who are in judicial custody, hence this bail
application on the following grounds .
-: G R O U N D S :-
30.That the applicants/accused are innocent and had committed

no alleged offence, but they have been falsely implicated by
the complainant with the malafide intention for the ulterior
reasons.
31.That the case property and currency notes have been foisted
upon the applicants/accused, just to show false implication of
the applicant/accused.
32.That no such type of incident whatsoever stated in the FIR has

complainant with malafide intention for ulterior reason, while
actual facts are that, on the day of above false FIR, the
applicants/accused were present at Naaz Hotel situated at
Kazi Ahmed, and were taking tea, where complainant along
with his subordinate staff firstly inquired about the names,
parentage and others information from the
applicants/accused, and then without showing any reason or
warrant took the applicants/accused in police mobile and
went to PS Kazi Ahmed, where complainant party demanded
unwarranted and illegal amount from the
applicants/accused, on their refusal, complainant as usually
on order of his higher officers falsely implicated the
applicants/accused in the above case with malafide intention.
33.That nothing was recovered from the possession of the
applicants/accused and alleged property have been clearly
foisted upon the applicants/accused.
34.That the place of incident has been shown by the police,

35.That complainant with malafide intention on the command of

his higher officers on regular basis falsely implicated the
innocent person including applicants/accused, otherwise,
applicants/accused are not concerned with the alleged
offence, and they are totally innconet.
36.That there is violation of sec tion 103 Cr PC.
37.That alleged recovered Desi Liqour have been shown as

recovered and its quantity have been shown 20/20 litters
without measuring by measuring articles, which creating
highly doubt in prosecution story, even otherwise, the
quantity for sample has not been shown , the actual
measurement that how much Desi Liqour were sealed
separeatly for chemical analysis, so it be indicated that things
have been managed by the complainant and his staff with
malafide intention for utlrior reasons.
38.That malafide part of the complainant is that, he shown in his

FIR, that police party took 1/1 bottle of Desi Liqour from the
alleged gallons for chemical analysis, but complainant party
failed to disclosed proper description of bottle, size, colour,
company, so this things is creating highly doubt in
prosecution story, so case of applicants/accused are required
further inquiry.
39.That there is no previously record of such type against the

applicant accused, so as per contents of the FIR it be indicated
that, each and every thing has been cooked up.
40.That section applied in the FIR doesn’t fall within the

41.That it is a settled law that bail should not be treated a

42.That applicants/accused are ready to furnish their solvent

surety to the satisfaction of this Honorable court.
DATED__________
CERTIFICATE

applicant accused.

BENAZIRABAD.
B. A. No: OF 2018.
Muhammad Younis son of Muhammad Ayoob Machi

Muslim, Adult presently confined, in District
Jail shaheed Benazirabad ……………… Applicant/accused
VS
The State ……………….……….…………………………

Opponent

U/S 23-A Sindh Arms Act 2013.
BAIL APPLICATION

Honorable Court may be pleased to release him, on bail in the
above case/crime on the consideration of the fallowing facts
and grounds:-
-: F A C T S :-

complainant, ASI Abdul Latif lodged his FIR at police station
Kazi Ahmed, on 23-11-2018, at about 0930 hours, alleging
therein that, today complainant along with his subordinate
staff with police ammunition, on government vehicle No. SP
356 along with driver, under entry No 2 dated 23-11-2018 at
about 0805 hours, were departed from PS for patrolling duty,
during patrolling duty, when complainant party reached at
Kando Kalhoro Link road, at about 0830 hours, they reached
at Malwah Mouri Stop, where they saw one person was
coming on road, who by seeing the complainant party tried to
runway backwards, due to suspicious, the complainant party
at once stopped their vehicle, laid down from it
[2]
very tactfully encircled him and captured him, due to non

availability of private mashir, HC Muhammad Paryal PC
Abdul Kareem were made as mashir, who inquired about
name etc from captured person, who disclosed his name to be
applicant/accused, from his body search , the complainant
party recovered one pistol 30 bore along with magazine from
his left side of fold side of shalwar,the same pistol was
unloaded in which 4 bullets 30 bore were recovered from its
magazine, the captured person was inquired about the name
licensed of pistol and its magazine, who disclosed same was
unlicensed, the accused was arrested under above section,
such mashirnama was prepared before the mashirs, the
accused and recovered property was brought at police station
where instant FIR was registered. Hence this FIR.
After usual investigation the police of police station

Kazi Ahmed, arrested the applicant/ accused, who is in
judicial custody, hence this bail application with following
grounds.
-: G R O U N D S :-
1. That case registered against the applicant/accused is false and
fabricated one, he had committeed no any alleged offence, but he

has been falsely implicated by the police with malafide intention
for ulterior reason.
2. That in facts no such incident whatsoever stated in the FIR has
complainant with malafide intention, while actual facts are that,
as per police policy and due to some highly influence, the
complainant of this case is being hired to registered this false FIR
against the applicant/accused, otherwise, no such type of
incident has ever taken place, and applicant/accused is totally
innocent.ook place but the whole drama has been staged by the
complainant, just to show his efficiency otherwise, otherwise
applicant/ accused have no concerned with the alleged offence.
3. That the pistol and bullets in-question has been foisted upon the
[3]
applicant/accused and applicant/ accused has no concerned

with the alleged weapon, but complainant just to drag the
applicant/accused before the competent court of law has lodged
present FIR by leveling allegations upon the applicant/accused .
 That place of incident shown in the FIR is thickly populated area

such place is not like to commit offence easily which is populated
area even nothing has been committed but this whole drama has
bene staged by the complainant and his staff with malafide
intention for utlrior reasons.
4. That malafide part of the complainant is that, if any alleged
weapon was recovered from the applicant/accused then he

sealed the same at spot, but as per ingridents of FIR, there is no
mentioned by complainant that, he sealed the alleged weapons at
spot for chemical analysis, so this things is creating highly doubt
in prosecution story, so case of applicant/accused is requires
further inquiry.
5. That there is violation of section 103 Cr, PC.
6. That there are general allegation against the applicant accused,
just to bow down the applicant otherwise alleged story is made

out on false assertions.
7. That all the PWs are police officials and are sub ordinate of the
complainant hence they are interested witnesses.
8. That applicant accused possessed good reputation in the vicinity
and he is not involved into such acitivities but he has been roped
by the police with malafide itnention
9. That applicant accused is not convicted previously.
10. That it is settle principle law that, if any single doubt arose in

[4]
11. That there is no apprehension of the tampering with the evidence
as applicant/accused he is ready to furnish solvent surety to the

DATED__________
CERTIFICATE
This is to certify that this is first bail application on behalf of

the applicant/accused before this Honourable Court, prior to this
no any bail application has been filed by the applicant/accused
before this Honourable Court or before any other competent court
of law.

IN THE COURT OF CIVIL JUDGE & JUDICIAL
MAGSITRATE –I KAZI AHMED.
B. A. No: OF 2018.
1. Sharif son of Pairo Solangi

2. Asif son of Muhammad Umar Solangi
Both …………………………. ..… .Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

U/S 337-A (ii), F(i), 504, 34 PPC
BAIL APPLICATION
It is prayed on behalf of the applicants/accused , that

this Honorable Court may be pleased to release them, on bail
in the above case/crime, on the consideration of the fallowing
facts and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant,

Ahmed lodged his FIR at police station Kazi Ahmed,On 15-08-
2018, at 1630 hours, alleging therein that, he is residing at
above mentioned address, there is dispute over the common
path with the Piyaro Solangi,on 14-08-2018, complainant
along with his brother Ghayo Khan and cousin Shamhuddin,
and friend Innayat son of Muhammad umar Chandio were
gathered towards the Government Koh for their work, when
at about 8:00 Am, when complainant party reached at
common path near Village Panjho Solangi, where they saw,
accused each Piyaro son of Dodo Khan Solangi having
Hatchet, Sharif son of Piyaro having Hatchet, Asif son of
Muhammad Umar having Pistol, Ameer Bux son of Wali
Muhammad Solangi having Lathi, All R/O Village Panjho
Solangi, Taluka Kazi Ahmed, District Shaheed
Benazirabad,were standing there, accused Asif by aiming his
pistol upon the complainant party stated that, complainant
party did not come into their terms over the common path, so
today they will teach them lesson, by saying so, accused
Piyaro , Sharif, and Ameer Bux, tried to caused blow to the
complainant, but brother of complainant Bhagiyo Khan tried
to resuce the complainant, on which accused gave Lathies and
Hatchet blow to the brother of complainant, which hit him on
his right side of leg and other part of body, they also pushed
the complainant, thereafter complainant saved his broterh by
giving name of Quran Pak, then they all went away towards
their house, thereafter complainant along with brother got
medical latter and got treated his brother at Government
Hospital Kazi Ahmed, then he came at police station and
lodged such FIR, however, during fought, the articles of
brother of complainant viz amount of Rs, 2000/- and one
china mobile phone and one gold Doro which was fell down
on earth and same was take away by accused persons hence
this FIR.
After registration of FIR, police of Kazi Ahmed arrested

the applicant /accused, who is in
__________________________, hence his bail application with
following grounds.
-: G R O U N D S :-
44.That the case registered against the applicants/accused are
false, baseless, fabricated, they have committed no any
alleged offece, but they have been falsely implicated by the
45.That there is delay for lodging of the FIR about one day,
which is unexplained at all.
46.That in fact no such incident whatsoever stated in the FIR has

ever taken place, but this whole drama has been made by the
complainant with malafide intention, while actual facts are
that, complainant is Zamindar and belonging with some
ruling party, so on general election he commanded the
applicants/accused party to caste their votes to his party, on
refusal of the applicants/accused party, complainant party
keeping annoyance, grudge, hindrance, and by managing
thigns with local police, implicated the applicants/accused in
this false case, otherwise applicants/accused are innocent and
committed no any alleged offence.
47.That it is further submitted that, complainant is person of

some define nature, he also used to give the amount to
different persons, and received the same with interest
amount, so applicants/accused being poor persons they also
used to take the some amount with complainant, and within
time they paid the whole amount but complainant with
malafide intention demanding the interest amount from the
applicants/accused, on which applicants/accused are
requested him that, they will paid the whole amount which
are given by them, on which complainant being person of
highly contacts threatened that, if the applicants/accused will
not pay him illegal, unwarranted amount then they will face
troubles, for which result such false implication of the
applicants/accused are made out, otherwise,
applicants/accused are totally innocent.
48.That no any injury are sustained by the complainant party,

and if he sustained same are self suffered, and if any medical
certificate are obtained by him same are false, baseless and
manipulated , and managed one.
49. That sections applied in the FIR are not attracting to the
present case, same are misapplied.
50.That amount, mobile and gold Doro are foisted upon the
applicants/accused by the complainant party.
51. That place of incident is thickly populated area, but no any
idependent witness are shown in the FIR, all the witnesses
shown in the FIR are close relative of the complainant and are
pocket persons.
52. That the case of the applicants/accuse are of further inquiry
to determine that who is the aggressor.
53.That the implication of the applicants/accused on the face of

it is false fabricated untrustworthy and highly unbelievable
and is without any independent witness which makes entitle
to applicants/accused for grant of bail .
54.That the applicants/accused have possessed good reputation
in their vicinity as well as they are not hardened criminal nor
disparate nor previous convict, as per instruction.
55.That all the PWs cited in the FIR are pocket persons of the
complainant, hence they are interested witnesses.

evidence as all the PWs are interested witnesses of the
complainant.
57.That applicants/accused are prepared to furnish their solvent
58.That other grounds will be urged at the time of arguments.

59.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application on

behalf of the applicant/accused before this Honourable Court, prior
to this no any bail application has been filed by the
applicant/accused before this Honourable Court or before any
other competent court of law.

MAGISTRATE-I KAZI AHMED
B. A. No: OF 2018.
Mirzo son of Obhayo Machi

Presently confined in police lockup at
PS Kazi Ahmed …..………………..… .Applicant/accused
VS
The State …………………………..………………Opponent

OFFENCE U/S 380 PPC.
BAIL APPLICATION
UNDER SECTION 497, Cr.P.C.

Honorable Court may be pleased to release him on bail in the
above case/crime on the consideration of the fallowing facts and
grounds:-
-: F A C T S :-

complainant, Shahmeer lodged his FIR at police station Kazi
Ahmed, On 01-06-2018, at 1130 hours, alleging therein that, he
has shop of _________, at his village, and he running the same
by himself,On 29-05-2018, complainant as usually closed his
shop, and slept away by lying cot in front of his shop, electric
bulbs were alightened, when at about 1145 hours, some voice
was listen to the complainant and he awoken and saw that,
one Mehtab son of Fadho Machi having Mobile Phone, Ali
Hassan @ Chako having Mobile Phone in his hand, both sons
of Ghulam Hussain Machi, Mirzo son of Obhayo, and one
unknown accused person, who have been seen in the light of
bulb and would be identified if seen again, thereafter
complainant by raising cries of theft theft, on his cries,
villagers peoples namely Muhammad Bux son of Muhammad
Usman Kori, Moosa Khan son of Rasool Bux Kori, and others
peoples were rashed towards there by giving Hackles, who
also seen the abovementioned accused along with Mobiles
Phones when they was runnig, and they were succeeded to
run away by taking advantage of darkness, thereafter
complainant before the witnesses saw that, one nokia mobile
Phone, and one China Mobile Phone detailed below, and
amount of Rs 20,000/- which was lying in pocket of
complainant were missed, and same was stolen away,
thereafter complainant met with accused persons, who asked
to the complainant that, he given Faisla and also pay panelty
amount, but who only kept the complainant on false hopes,
and today refused to give Faisla, hence this FIR.
After registration of FIR, police of PS Kazi Ahmed,

arrested the applicant/accused, who is in police lockup at PS
Kazi Ahmed, hence this Bail application with following
grounds.
-: G R O U N D S :-

and fabricated one, he has committed no any alleged offence, but
he has been falsely implicated by the complainant with malafide
intention for ulterior reasons.
2. That there is inordinate delay in lodging of the FIR more then 3

days, without any plausible explanation which goes to show that
the same has been lodged after deliberation and consultation as
such false implication of the applicant/accused in present case
can not be ruled out.
3. That malafide part of the complainant is that, he has not shown

any description, model, or any other things in the FIR, besides,
complainant also not shown the numbers of currency notes, or
any other description, which shows that, each and every things
has been cooked up by the complainant only for dragged the
applicant/accused in this false case, so case against the
applicant/accused is requires further inquiry.
4. That no such incident whatsoever stated in the FIR is ever taken
place but whole drama has been engineered by the complainant
with malafide intention as well as no recovery was made from
the applicant/accused but complainant malafidly implicated the
applicant/accused in this false case, otherwise
applicant/accused is not concerned with alleged offence.
5. That no specific role, part, overt act has been assigned against the
applicant/accused, as such case against the applicant/accused
requires further inquiry.
6. That the offence doesn’t fall within the prohibitory clause of

section 497 Cr PC.
7. That it is settled principle law that , if any single doubt arose in

prosecution story, so each and every benefits of doubt goes in
favour of applicant/accused at bail stage.
8. That there is no any overt act or direct evidence regarding the

allegation leveled against the present applicant/accused.
9. That applicant/accused is behind the bar, hence he is not

required for the purpose of investigation.
10.That the complainant did not disclosed proper description of the

alleged stolen property which makes the case doubtful.
11.That the applicant/accused has possessed good reputation in his

vicinity as well as he is not hardened criminal nor disparate nor
previous convict, as per instruction.
12.That all the PWs cited in the FIR are pocket persons of the
complainant, hence they are interested witnesses.
13.That there is no apprehension of the tampering with the evidence
as all the PWs are interested witnesses of the complainant.
14.That applicant/accused is prepared to furnish solvent surety to

the satisfaction of this Honourable Court.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application on behalf of

applicant/accused, before this Honourable court, prior to this
no bail or ABA is pending on behalf of the applicant accused
before this Honourable court or any other competent court of
law, as per instruction.
ADVOCATE FOR
APPLICANT/ACCUSED
IN THE COURT OF DISTRICT & SESSSION JUDGE
SHAHEED BENAZIRABAD
Cancellation of B. A. No. of 2017.
Muhammad Afzal …………….VS ………………………..The

state
Muhamamd Saeed son of Abdul Rasheed

Arain Muslim Adult R/O Golimar Nawabshah
District shaheed Benazirabad ……………………. Complainant
Versus
Muhammad Afzal son of son of Sabir Ali

R/O House No 188 –B -300, Muhalla Street No 1
Quidaabad Landi, Karachi, now confined in
District Jail Shaheed Benazirabad ……….Opponent/Accused
Crime No: 273/2017, P.S, A Section

Nawabshah
OFFENCE U/S 489-F PPC
APPLICATION
FOR CANCELLATION OF BAIL
UNDER SECTION 497, (5) Cr. P.C.
It is prayed on behalf of the complainant,
that this Honorable Court may be pleased to Cancel the Bail of
the d opponent/accused in the above case/crime and to
commit them in custody of the police, in the above
case/crime on the consideration of the fallowing facts and
grounds:-
-: F A C T S :-

Muhamamd Saeed lodged his FIR, at police station A section
Nawabshah on 09-09-2017 at about 1430 hours, alleging
therein that, applicant accused Muhammad Afzal had
obtained a sum of Rs. 34,00,000/- as laon from the applicant
accused and in return
[2]
he gave a post dated cheque No 32369416, dated 20-8-2017, for

Rs. 34,00,000/- of account No -0109000238345676, drawn at
UBL, the complianant then presented the said Cheque into the
Bank, ut cheque given by the applicant/accused to the
complianant was dishonoured by the Bank, the complianant
then obtained such Memo and approached the applicant
accused and apprised him of dishonouring of the cheque,
who kept the complianant on hopes and promises and
ultimately refused, the complianant then went and lodged
such FIR.
After registering of the FIR applicant/accused was

arrested, who is in judicial custody, however, Bail application
has filed by the applicant accused, before the Honourable
Court of judicial Magistrate-III, who after hearing allowed bail
application and by ordering dated 22-09-2017, to release the
applicant accused, to furnish solvent surety or PR bonds, for
satisfaction of Honourable court, on the basis of prohibitory
clause under section 497 (2) Cr, PC, hence this application for
cancellation of Bail on the following grounds .
-: G R O U N D S :-
60.That order passed in favour of the applicant/accused which is

against the principle law and justice and equities.
61. That applicant/accused is greedy type and he by opening his

greedy face, obtained laon amount from the complianant with
business purpose, and at the time of collecting amount such
things are reduced in writing, however, it is clear crystal that,
applicant accused has obtained huge laon amount Rs.
34,00,000/- , however, looking to the judicial mind, and
looking to the aspect of the case the amount is principle and
huge amount, which has clearly been collected by the
applicant accused before the witnesses, who are mariginal
witnesses but learned trial court without applying judicial
mind and wihtout touching to the merit of case also
prejudiced complainant and allowed bail application of
applicant accused only on the ground
[3]
of prohibitory, so prohibitory ground is not sufficient ground

to allow the bail of applicant accused, however, looking to the
aspect of the case and learned trial judge it be indicated
observed that, learned trial judge was interested with
applicant accused and could not considered such huge
principle amount, which is wasted and given to the applicant
accused so, case of the complianant was fit for cancellation of
bail of the applicant accused, but learned trial judge did not
consider.
62.That as per contents of the FIR, the facts of the FIR which are
showing genuiness of the case and applicant accused has
committed cheating by dishonestly, however, when applicant
accused collected suc huge amount by showing name
Pharmacy company, but after collecting amount, it be
indicated that such pharmacy company shown by the
applicant accused which was forged, fake and result of which
is that complianant has been caused damages and losses.
63.That admittedly offence is cognizable offence, and learned

trial judge should have to cancel the bail of the applicant
accused and he had to award the sentence to the applicant
accused, but learned trial court did not appreciate to the
material, evidence, facts, aspect of the case and without
applying judicial mind has allowed bail application of the
applicant accused.
64.That only for the evidence purpose and to show congent

reason fot he case, the cheque is enough to prove the case of
the complainant but, despite of that, learned trial court did
not consider the above matter and also allowed the bail
application of the applicant accused.
65.That learned trial judge was in knowledge that memo has

been obtained on cheque and applicant accused is defaulter,
and he has collected such huge amount but despite of that,
bail of the applicant accused has been allowed and
complianant has been caused damages .
66.That in view of justice, it is factual condition that, if the

applicant
[4]
accused would be allowed in such serous and heinous

matters, then, complainant party will prejudice from their
right and object of filing of the case by the complainant side,
which shall stand unfruitful, gratuitousness.
67.That as per aspect and contents of the FIR, the applicant

accused is not entitled for relief of bail but his bail relief is
liable to be cancelled and he may be continually ordered to
undergo the jail for completion period as per definition of
section 489-F PPC.
68.That order of relief of bail of the applicant accused may be

dismissed and cancelled.
69.That other grounds will be urged at the time of arguments

COMPLAINANT
IN THE COURT OF DISTRICT & SESSSION JUDGE
SHAHEED BENAZIRABAD
Muhammad Afzal …………….….VS ………………………..The

state
Muhamamd Saeed …………….. …………………….

Complainant
Versus
Muhammad Afzal ……………………...

……….Opponent/Accused

Nawabshah
OFFENCE U/S 489-F PPC
AFFIDAVIT
I, Muhamamd Saeed son of Abdul Rasheed Arain

Muslim Adult R/O Golimar Nawabshah District shaheed
Benazirabad , do hereby state on aoth as under:-
1. That I am complianant in the above matter hence fully

2. That accompanying cancellation bail application has been

drafted under my instruction the contents of the same are
true and correct.
3. That bail application of the applicant accused may be

released and order maybe passed to put him under jail
custody continually till the completion period under
definition of section 489-F PPC.
knowledge.
I know the deponent deponent
Advocate
IN THE COURT OF SPECIAL JUDGE OF ATNI

TERRORISM SHAHEED BENAZIRABAD
B. A. No: OF 2017.
Muhammad Juman son of Muhammad Siddique Keerio

VS
The State ……………….……….…………………………Opponent
Crime No: 207/2017, P.S, Sakrand

U/S 23-A Sindh Arms Act.
BAIL APPLICATION

applicant/accused , that this Honorable Court may be pleased
-: F A C T S :-

complainant, ASI Ali Muhammad Dhalo, lodged his FIR at
police station Sakrand, on 21-7-2017, at about 0830 hours,
alleging therein that, today complainant along with PC
Ghulam Rasool, PC Mehboob Ali, PC Muswar Ahmed, with
police ammunition, on police Mobile No SP 201, along with
driver PC Wajid Memon, under the entry No. 33/21-7-2017, at
about 0530 hours, departed within their beat for patrolling,
various places, when at about 0730 hours, they reached
Sakrand Sarhari road near Hashim Rasti, where they saw, one
person was standing there, who by seeing the police party
tried to run away, the complainant party suspected, and
stopped their vehicle, the complainant party got down with
their staff and very tactfully captured to the persons, the
captured persons were inquired about their name , residence
etc, who disclosed his name to be applicant accused, the
complainant tried to make private Mashir but not found, due
to non availability ,of the private Mashirs PC Ghulam Rasool
and PC Mehboob Ali, were made mashirs, the police
conducted body search of arrested accused, from his right side
of shalwar one pistol recovered which secured by the
complainant party, the pistol was unloaded, which was of 30
bore, containing the magazine in running condition without
licenses, the from the Magazine 3 live bullets were recovered,
which were unloaded, the pistol and magazine and its bullets,
were sealed, further body search was conducted of the
arrested accused from his side pocket of shirt one note Rs. 50
recoovered which was secured by the police, the arrested
accused was inquired about pistol and its license, who
disclosed to be unlicensed, the complainant also arrested the
accused under section 23-A Sindh arms act 2013, such
mashirnama was prepared before Mashirs, the arrested
accused and recovered property were secured, and brought at
police station where present case has been registered.
After usual investigation the police arrested the

applicant/ accused , the applicant/accused is in judicial
custody hence applicant/accused got filed present bail
application before this Honourable court on the following
grounds.
-: G R O U N D S :-

complainant with the malafide intention for the ulterior reasons.
14. That there is altercation in between the applicant accused party
and Manzoor Ali party, there are series of the FIRs lodged by tbe
both parties, so Manzoor party joined the hands with police of
District Shaheed Benazirabad, being political person having
highly influence, got lodged this false FIR against the applicant
accused by managing things with police by hiering the
complainant of this case, just to take undue advantage otherwise
nothing has been committed but this whole drama has been
staged by the complainant .
15. That no such incident whatsoever stated in the FIR was ever took
place but the whole drama has been staged by the complainant,
just to show his efficiency otherwise, otherwise applicant/
accused have no concerned with the alleged offence.
16. That the pistol in-question has been foisted upon the
applicant/accused and applicant has no concerned with the
alleged weapon, but complainant just to drag the
present FIR by leveling allegations upon the applicant accused .
17. That place of incident shown in the FIR is thickly populated area

intention for utlrior reasons..

20. That case property as alleged have been foisted upont he
applicant accused, by the complainant just to make this false case

with malafide intention for ulterior reasons.




APPLICANT/ACCUSED

B. A. No: OF 2017.

VS

BAIL APPLICATION
-: F A C T S :-

police ammunition, on police Mobile No SP 201, along with
driver PC Wajid Memon, under the entry No. 33/21-7-2017, at
about 0530 hours, departed within their beat for patrolling,
various places, when at about 0730 hours, they reached
Sakrand Sarhari road near Hashim Rasti, where they saw, one
person was standing there, who by seeing the police party
tried to run away, the complainant party suspected, and
stopped their vehicle, the complainant party got down with
their staff and very tactfully captured to the persons, the
captured persons were inquired about their name , residence
etc, who disclosed his name to be applicant accused, the
complainant tried to make private Mashir but not found, due
to non availability ,of the private Mashirs PC Ghulam Rasool
and PC Mehboob Ali, were made mashirs, the police
conducted body search of arrested accused, from his right side
of shalwar one pistol recovered which secured by the
complainant party, the pistol was unloaded, which was of 30
bore, containing the magazine in running condition without
licenses, the from the Magazine 3 live bullets were recovered,
which were unloaded, the pistol and magazine and its bullets,
were sealed, further body search was conducted of the
arrested accused from his side pocket of shirt one note Rs. 50
recoovered which was secured by the police, the arrested

grounds.
-: G R O U N D S :-







APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail

application of the applicant accused, before this Honourable
court, prior to this no bail is pending on behalf of the
applicant accused before this Honourable court.

MAGISTRATE –II DAUR
B. A. No: OF 2017.
Sadam Hussain son of Sajjan Ali

Jamali, Muslim Adult R/O Village Achar Khan
jamali, Taluka Daur, District shaheed
Benazirabad ……………..……………...….Applicant/accused
VS
The State…………….……….…………………………Opponent
U/S 269, 270, 273 PPC.
BAIL APPLICATION

applicant/accused, that this Honorable Court may be to
accept the surety of the applicant accused and release him, on
bail in the above case/crime on the consideration of the
-: F A C T S :-
Briefly facts leading to present case are, that

complainant, HC Imdad Hussain Shar lodged his FIR at police
station Bandhi, On 14-9-2017 at about 17:30 hours, alleging
therein that, the complianant along with his staff, PC Ali
Murad, PC Jameel Hussain, with police ammintion, on police
Mobile No./ SPC 999, along with
[2]
driver PC Umar Hayat, under Roznamcha entry No 14 dated

14-9-2017, at about 1530 hours, departed for patrolling, within
their beat, various places, when they reached at Rehman Abad
Chowk, where complianant got spy information, that, one
person sadam Hussain who at Van stop Bandhi chowk, is
selling Main Puries and GHutka openly on his Cabin, after
getting such information, the complianant party departed at
pointed place, when they reached at pointed place, where
they saw, in front side one person by keeping main Puries and
Ghutka was selling the same, the complianant party got down
and encircled the accused, secured the main Puries and
Ghutka, due to non availability of the private Mashirs, the PC
Murad, PC Zmeer made Mashirs, the accused was inquired
about his name and address, who disclosed his anme to be
Saddam Hussain, police saw 5 pocket of Z-21 Ghutkas, and 5
packets of JND Ghutka were lying there,f rom his body
search, from side pocket complianant party received total Rs.
200/-, accused was inquired about the Ghutka, on which he
disclosed that he used to sale on the money, however, the
Ghutka and Main Puries are infectious for humen beings ,
therefore applicant accused was arrested in above case crime
hence this FIR was lodged.
After registration of the FIR, applicant accused was

[3]
-: G R O U N D S :-
alleged offence, but he has been implicated in this false case with
malafide intention.
12. That in fact no such incident, whatsoever stated in the has ever
taken place but this whole drama has been staged by the
complainant and his sweet obligor witnesses just to degrade the
applicant accused.
13. That main Puries , Ghutka and amount etc have been foisted
upont he applicant accused, otherwise he has no concerned with

the alleged recovery.
14. That complianant failed to associate independent witnesses
having the populed area there is voialtion of 103 Cr PC.
15. That all sections applied in the FIR are bailable.
16. That all PWs cited in the FIR are interested witnesses of the
complianant and are sweet obligor.

malafide intention.
[4]

APPLICANT/ACCUSED
CERTIFICATE


3rd Bail Application
Allah Dad son of Ghulam Mustafa Wassan

presently confined in District Jail
shaheed Benazirabad ….. …………………Applicant/accused
VS
Crime No: 102/2016, P.S, Duar

Offence, 9/C, CNSA ,
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that, Complainant, SIP Abrar

Hussain Rind lodged his FIR at police station Daur, On 13-11-
2016 at about 2000 hours, alleging therein that, today
complainant along with his staff, HC Hazar Khan, PC Rano
Khan, PC Sajjad Hussain, C Ghulam Murtaza, with police
ammunition wearing police dress, on police mobile No SPD
748, along with driver, HC Muhammad Ayoob, under the
entry No. 20,
[2]
dated 13-11-2016, at about 1830 hours, departed for patrolling

within their beat, when at about, 1900 hours, they reached,
near Dargah Mitho Fakeer, where complainant party saw on
the light of the mobile, one person was standing near the
Dargah, who by seeing the police vehicle, tried to run away,
the police party got down from the vehcle and very tactfully
encircled him, and captured him, due to non availality of the
private Mashir, HC Hazar Khan, PC Rano Khan were made
Mashirs, the arrested accused was inquired about his name
and address etc, who disclosed his name to the applicant
accused, the complainant party suspected and conducted
body search, from his fold of shalwar one black shopper was
recovered, same was secured in cutody of the police, which
was opened, in which one large piece of chars and one small
piece of chars detailed bellow were recovered, same was
weighted on spot, which became 1070 grams, the chars was
sealed on spot at once, from his body search, police recovered
Rs. 150 detailed bellow, which were secured by the police, the
police party also inquired about the amount and chars, on
which he disclosed that, above chars is his, and same amount
is earned from the above sold out chars, he is already
involved in crime No. 100/2016, under section 401, 398, PPC
of PS Daur, so applicant accused kept chars in his possession
illegally, he has been arrested under section 9/C, CNSA,
thereafter, such Mashirnama was prepared before the
lodged.
[3]
After registration of FIR, the applicant accused was

arrested, However, first and second bail applications of the
applicant accused are dismissed in the above case, moreover,
applicant/accused is behind the Bars since 10 months, for
indefinite period, during that period, the complianant has
been examined, in the above case and his witnesses have no
interest to appear before this honourable court with purpose
to adduce their evidence, so, there is highly contradiction in
the above case on behalf of the complianant/prosecution side,
there is no corroborative version or congent substantiation
against the applicant accused, while present case is nothing
but he has been implicated in the above case hence this 3 rd bail
application, on the following grounds .
-: G R O U N D S :-
20.That the applicant /accused is innocent and had not

committed the alleged offence and he has falsely been
implicated in present case with malafide intention for the
ulterior reasons.
21.That in fact no such incident, whatsoever stated in the FIR has

ever taken place, but complainant by managing things just to
show false implication of the applicant in present case has
foisted such quantity of narcotics substance upon the
applicant/accused, so that he come in his illegal terms
otherwise applicant/accused is innocent he has no concerned
with the alleged offence.
22.That nothing has been recovered from the applicant

[4]
accused, but, amount and chars as alleged has been foisted

upon the applicant accused with malafide intention for utlrior
reasons.
23.That place of incident is managed one and same has been

alleged offence.
24.That there is voilatin of section 103 Cr, PC.
25.That as per provision of section 9/C CNSA and according to

quantity of the chars/Narcotics substance the case of the
applicant accused is on border line of 9/B and 9/C CNSA.
26.That applicant acused is rotting jail since 10 months, without
indefinite period.
27.That as per ingredient of section 9/C CNSA, which is

case.
28.That the recovery of chars, amount etc, which has been foisted
upon the applicant /accused just to implicate the applicant
accused in this false case.
29.That prosecution story is uncoroborative, unsupported and

one.

his vicinity present case is nothing but
[5]
complainant has no left lack to show his efficiency, just to

blackmail and pressurize him.
31.That case has been challaned, applicant accused is no more

32.That complainant has been hired by ruling party just to

implicate the applicant accused in this false case.


stage.


reasons.

[6]



APPLICANT/ACCUSED
CERTIFICATE
This is certify that this is 3rd bail application on

behalf of the applicant accused, prior to this no other bail on
Honourable court .
IN THE COURT OF CIVIL JUDGE & JM-II NAWABSHAH
B. A. No OF 2017.
Abdul Samad son of Abdul Khalique Lund

Muslim, Adult presently confined in
District Jail shaheed Benazirabad ……Applicant/Accused
VS
The State ………………………………..…………………..Opponent
Crime No. 35/2017, PS Balu Ja Quba

U/S 381-A PPC.
BAIL APPLICATION
applicant/accused, named above, that this Honorable Court
case/crime on the consideration of the following facts and
grounds:-
-: F A C T S :-

namely Zubair son of Abdul Hameed Arain lodged his FIR at
police station Balu Ja Quba, on 09-09-2017, at about 2230
hours, alleging therein that, he is running his business for
selling Ice through Phatta at Ali Resturant Nawabshah,
complaiant having his Chingchi Rishchaw No. A 34644,
Model 2007, at the place of Body Phattha is installed in the
said Rikshaw
[2]
for boarding Ice, the complaiannat parked his Rikshaw at the

place of istall of Ice, and he was slept on install at about 4:00
Am, the complainant woked up on the commotion where he
saw on the electrical light, that Abdul Sammad son of Abdul
Khalique Lund R/O Taj Colony Nawabshah, who start the
Rikshaw of complainant and Amir son of Zulfiqar Dahri R/O
Ghulam Hyder shah colony Nawaabshah were sitting with
him, they went away toward sothren side, on the Rikhshaw of
complainant, where complainant informed his brother
Muhammad Ali and his father Abdul Hmaeed Arain, and
they were started to search the Rikhshw and accused persons,
where complainant party received a information that, the
Rikhshaw of complainant have available at Jona Mori towards
Nawabshah Kazi Ahmed Road by accident condition,
complainant party were gone towards Jona Mori where the
received the information, the Rikshaw of the complainant was
accident with motorcycle by accused persons, the accused
Abdul Sammad Lund received the injury and accused Amir
Dahri along with Abdul Sammad went away on the Rikshaw
of complainant, thereafter complainant party searched to
Riksahw and accused persons, but the complainant not be
found to the accused person and his Rikshaw, hence this FIR.
After registration of the FIR, applicant accused has been

arrested and he confined in judicial custody at District Jail
Shaheed Benazirabad, hence this bail application on the
following grounds.
[3]
-: G R O U N D S :-
1. That the applicant/accused is innocent and he has been falsely
implicated by the police with the malafide intention.
2. That applicant/accused is under age and he is not involved in
the present case, and he is not aware about the above offence, the
police have been arrested to applicant accused from his house.
3. That when the relative of the applicant accused received the
information that, the applicant accused has been arrested by the

police in the above case crime and now he is in judical custody,
thereafter the father oof the applicant accused contected with the
complainant.
4. That after the metting of the father of applicant accused and he
disclosed that, police has been arrested to his son in your case
crime, where the complaiant informed that, I am not aware that,
the complainant narracted that the applicant accused is not
culprit and he is not involved in case of complainant, but
complainant disclosed the name of applicant accused before the
police in doubt actually the applicant accused is not involved in
the present case.
5. That the applicant accused is under age and he is not involved in
such type of cases in past.
6. That there is no eye witness of the offence shown by the
complainant in his FIR.
[4]
7. That the complainant is ready to sworn his affidavit in favour of
applicant accused for granting the bail.
8. That section applied in the FIR which is clearly misapplied and
not attracting to the present case.
9. That above circumstances the applicant accused is innocent and
he has been falsely implicated in the present case and he is

entitled for the conssesion of bail.
10. That the investigation has been completed by the I.O from the
applicant accused as he is in judical custody and he is not more

required for investigation.
11. That the case against the applicant accused doesnot fall within
the embit of section 497 Cr, PC.

12. That the case of applicant accused is fit for further inquiry,
though the applicant accused is entitled for the consession of

bail.
as applicant/accused is ready to furnish solvent surety to the


APPLICANT/ACCUSED
[5]
CERTIFICATE
This is to certify that this first bail application on

behalf of the applicant/accused prior to this no any bail or
other case has been filed by the applicant/ accused before this
Honourable Court or other competent court of law.
Advocate for Applicant/accused

Ali Asghar son of Allah Bachayo Rind

Muslim, Adult Presently confined in
District Jail shaheed
Benazirabad …………..... …………………Applicant/accused
VS
Crime No: 57/2017, P.S, Jam Dattar

BAIL APPLICATION
grounds:-
-: F A C T S :-
Brief facts of the case are that, Complainant, SIP, Nazeer

Hussain Rind lodged his FIR at police station Jam Dattar, n
18-8-2017, at about 21-20 hours, alleging therein that, today
complianant along with his staff PC Ali Asghar, PC Mukhtiar
Ali, with police ammunition, on police Mobile No. SPD, 771,
along with driver PC Yaseen, under entry No 16 dated 18-8-
2017,
[2]
at about 1830 hours, departed within their beat for patrolling

various places, when at about 2045 hours, reached at Jam
Sahib graveryard, where on the head light of the mobile, he
saw one person was standing at graveyard, who having
Plastic shopper in his hand, he by seeing police tried to run
away, the complianant suspected, and stoped the vehicle, he
along with his staff very tactfully enricled and captured him,
the complianant party secured shopper lying in the hands of
the person, the complianant party tried to arrange private
Mashir, but not found, so HC Ali Asghar, PC Mukhtiar Ali
were made mashirs, the accused was inquired about his name
and address who disclosed his name to be applicant accused,
the shopper was opened, in which one large piece and four
small pieces of chars were lying, from his body search, police
secured amount of Rs. 200/- from his side pocket, the chars
was weighted on spot, which became 1050 gram, the chars
was sealed seprated for chemical analysis, the accused was
inquired about chars, who disclosed that, he used to sale the
chars, on money, thereafter he has been arrested in the above
case crime, such Mashirnama was prepared before Mashirs,
hence this FIR.
After registration of FIR, the applicant/accused was

arrested, who has been shown in the above false case, and is
confined in judicial custody, hence this bail application on the
following grounds .
-: G R O U N D S :-
[3]
committed the alleged offence and he has falsely been implicated

in present case with malafide intention for the ulterior reasons.

42.That applicant accused is labour type, while prior to this he is

not involved into such activities .
43.That nothing has been recovered from the applicant accused,

applicant accused with malafide intention with malafide
44.That malafide part of the complainant is that, applicant is

running donkey cart, on the day of lodging of the FIR he was
coming by his own way, and then police stpped forcefully
firstly demanded amount and used filthly language thereon
applicant accused refused to give amount, on which he was
brought by the police and implicated in this false case
otherwise applicant accused has no concerned with the
alleged offence.
45.That malafide part of the complainant, is that, he has shown

place of incident at jam Sahib graveyard, which
[4]
is area of Jam Sahib Town and there is shrine of Sakhi Jam Dattar
and there is no such place to commit offence or sale the chars but
complianant by mananging thigns with his sweet obligor
witnesses has implicated the applicant accused in this false case.
46.That there is violation of 103 Cr PC.
47.That malafide part of the complainant is that, he has shown

one big and four small pieces of chars , and there is no further
descprtion of such chars so it be indicated that each and every
thing has been narrated by complianant which is false and
fabrcaited .
one.

lack to show his efficiency, just to blackmail and pressurize
him.

required for further investigation

[5]

stage.


reasons.
55.That there is no previous such type record and applicant is
not involved into such activities but due to reason mentioned
above and due to high influence of police, this FIR has been
lodged on false and fabricated assertions.



APPLICANT/ACCUSED
[6]
CERTIFICATE
This is certify that this is first bail application of the

applicant/accused prior to this no bail has been filed before
this or other competent court of law.

IN THE COURT OF CIVIL JUDGE & FAMILY JUDGE
NAWABSHAH
B. A. No: OF 2017.
Shaman Ali son of Ali Muhammad Khaskheli

presemtly confined in District jail shaheed
Benazirabad ……..……………….….Applicants/accused
VS
The State ………….……….…………………………Opponent
Crime No: 139/2017, P.S, Airport

Nawabshah
U/S 379 PPC
BAIL APPLICATION

applicants/accused, that this Honorable Court may be to
release them on bail in the above case/crime on the
-: F A C T S :-

complainant, Janwar Khan lodged his FIR at police station
Airport Nawabshah, on 30-8-2017 at about 1600 hours,
alleging therein that, complainanat is a govermnet servant in
Army, he has owened cattle detailed bellow, at morning time
about 09:30 PM, the complainant roped, he gaot and she goat
in front of house, after half hour, the complianant came out
from
[2]
house, he saw, he goat and she goat were not roped there,
thereafter complainant and Abbas shah, Asghar Ali Malak in
their gathering departed to search the same, thereafter
complianant party came to know that his cattle has stolen by
namely Shaman Ali son of Ali Muhammad Khasheli R/O
Magsi stop Nawabshah, who was by taking the same going
away, hence this FIR.
After registration of the FIR, the police of PS Airport

arrested the applicant/ accused, who is in Judicial lockup,
hence this bail on the following grounds .
-: G R O U N D S :-
70.That the applicant/accused is innocent and had committed no

alleged offence, but he has been implicated by the
complianant with malafide intention for ulterior reasons.

complianant with malafide intention.
72.That malafide part of the complianant is that he has only

staged that accused by taking above cattle were going but he
has no shown side, description and other proof of departure,
only he has implicated the applicant accused with malafide
intention just to drag him in this false case.
73.That section 379 PPC is misapplied and same is not attracting

to the present case.
[3]
74.That story narrated in the FIR which is unseen and same is

made on false assertions, it be indicated that same story is
belind one and is stereotyped.
75.That malafide part of the complianant is that, it is imposible to
commit theft in front of house of the complianant, no one saw
the accused but as per story narrated in the FIR only
complianant and his sweet obligor witnesses saw the
applicant accused which creating highly doubt in prosecution
story which makes the case false and fabricated one.
76.That applicant accused has no concerned with the alleged

offence.
77.That thigns have been made stereotyped.
78.That nothing has been shown and narrated specifically but

whole drama has been made by complianant just to put
pressure upon the applicant accused so that he may oblige
him.
79.That it is settle principle law that if any single doubt arose in

prosecution story, then each and every benefit of the doubt
should goes in favour of the applicant/ accused at bail stage.

evidence as all the PWs are sweet obligor of the complainant.
[4]
81.That applicant accused is ready to furnish solvent surety to


APPLICANT/ACCUSED
CERTIFICATE


Mujjan son of Gul Hassan Korejo

shaheed Benazirabad …... …………………Applicant/accused
VS
Crime No: 159/2017, P.S, B section

Nawabshah
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that, Complainant, SIP,

Muhammad Daud Rind lodged his FIR at police station B
section Nawabshah on 18-8-2017, at about 1700 hours, alleging
therein that, today complainant along with HC Shahmir, PC
Ghulam Akbar, PC Ghulam Mustafa, PC Ghulam Khan, with
police ammunition, on police mobile No. SPC 319, along with
driver Zameer Hussain, under entry No. 26 dated 18-8-2017,
at about
[2]
14:45 hours, departed within their beat, for patrolling, various

places, when at about 1600 hours, they reached at at Top of
dirty Pond near Jamshed Colony Line Par Nawabshah, where,
he saw, one person having plastic black shopper, who by
leading road was coming towards northern side, he by seeing
the police party tried to run away, the police suspected, very
tactfully stopped the vehicle and he along with his staff
encircled him and captured containing black shopper of
plastic, which was secured in possession of the police, the
police party tried to arrange private Mashirs due to non
availability of the private Mashirs, HC, Sher Muhammad, PC
Ghulam Akbar were made Mashirs, he was inquired about his
name and address, who disclosed his name to be applicant
accused, the applicant opened the plastic black shopper, in
which 8 small and large pieces of chars were lying , which
were wiegted on digital Kanta, which became weighted 2000
grams, all chars was sealed for chemical analysis including the
plastic black shopper, from the body search of the accused
amount Rs. 400/- were recovered, on the inquiry, he disclosed
that above chars is his, he used to sale on the money,
thereafter accused was shown in the above case crime due to
keeping chars in his possession, such Mashirnama was
prepared before Mashirs, hence this FIR.

confined in judicial custody, hence this bail application on the
following grounds .
[3]
-: G R O U N D S :-

ulterior reasons.


61.That malafide part of the complainant is that, on the day of

lodging of the FIR, applicant accused along with his family
members, was came at Nawabshah town for shopping
purpose, when at about 2:00 PM, during the shopping, when
complainant saw amount in the hand of the applicant, he by
showing his greedy nature, and put evil eyes over the amount
of the applicant, he came and demanded amount, on refusal
of he applicant, the applicant has been shown in above false
case and confined in above case.
[4]
62.That malafide part of the complainant, is that, he has shown

place of incident Ganda Nalla near Jamshed Colony
Nawabshah, but same place is colony and populated
residential area, there is no such place to commit offence in
broadday light, but complainant by mananging thigns with
his sweet obligor witnesses has implicated the applicant
63.That there is violation of 103 Cr PC.

64.That malafide part of the complainant is that, he has shown
big and small 8 pieces of chars but he has not shown quantity
of big and small pieces of chars but by foisting the same upon
the applicant accused has implicated him in this false case.
65.That chemical report has been sent after three days for
chemical ballistic analysis, so there is malafide part of the
complainant that each and every thing has been shown falsely
and malafidly.

one.

him.

required for further investigation
[5]


stage.

reasons.


[6]


APPLICANT/ACCUSED
CERTIFICATE

IN THE COURT OF SESSSION JUDGE SHAHEED

BENAZIRABAD
B. A. No: OF 2017.
Naseer Ahmed son of Salahuddin Qazi

R/O Hussaini Raod line Par Nawabshah
now confined at Police station
B section Nawabshah ………………...….Applicant/accused
VS
The State…………….……….…………………………Opponent
Nawabshah
U/S 337-J 269, 270, 273 PPC.
BAIL APPLICATION

release him, on bail in the above case/crime on the
-: F A C T S :-

complainant, SIP Khan Muhammad Jamali lodged his FIR at
police station B section Nawabshah, on 27-8-2017, at about
1830 hours, alleging therein that, today complainant along
with his staff PC Dur Muhammad, PC Nisar Ahmed, PC
Khalid Parvez, PC Wali Muhammad, with police ammunition,
on police Mobile
[2]
No SPM-218, along with driver PC Muhabat Ali, under entry

No 20, dated 27-8-2017, at about 1630 hours, departed for
patrolling from police station towards City, various places,
when they reached at Ghasita Road Line Par Nawabshah,
where, police party got spy information that, one Shahzor
vehicle No KQ-3833 Sindh, colour white, in which some
persons by taking poisning Eggs are taking away to sale out
the same at different places, which are harmful for the
makinds, and due to eating the same death can be happened,
the complainant after receiving such information, he along
with his staff, departed towards pointed place, where
complainant party started checking of different places, when
at about 1715 hours, they saw one person was coming on one
shahzor vehicle, No KQ 3833, Sindh, from the eastern side
Ghasita Road , in which four persons were seated, the
complainant party asked them to stop, the driver of the
vehicle tried to skip away, but police party very tactfully
encircled the vehicle, due to non availability of the private
Mashirs, PC Dur Muhammad, PC Nisar Ahmed were made
Mashirs, the driver was inquired about his name and address,
who disclosed his name to be Shahnawaz, from his body
search, side pocket of the shirt amount of Rs. 1000/- were
recovered, another disclosed his name to be Wajid son of Haji
Khan Qambrani, from his body search amount of Rs. 500 were
recovered,, Naseer Ahmed son of Sallahuddin Kazi from his
body search Rs. 500/- were recovered, Sardar son of Mubeen
Jamali from his body search police secured amount of Rs.
2000/-, the police party saw in
[3]
the mobile, 50 live Pettties/Parcels were lying there, in which

unuseable eggs were lying, in each Parcel/Patie 350 eggs were
lying, out of which smell was coming, the accused also
disclosed that, they used to sale above unuseable eggs in
diffirent bakkaries in the city, and above amount is of
unuseable eggs, the police party secured the same, and 24
eggs were sealed separately for chemcail analysis, and
complainant party also inquired about Shahzor vehicle and its
documents, on which driver disclosed to be unlicensed,
therefore he has been shown under section 337-J, 269, 270, 273,
PPC, arrested them, the vehicle has been proceeded under
Karvai of 550 Cr PC. such Mashirnama was prepared before
the Mashirs, the arrested accused along with recovered
property brought at police station, and where complainant
party stated that the accused persons are selling the un-
useable eggs at diffirent places, which are harmful for
makinds, and death can be happened on eating the same eggs,
hence this FIR.

-: G R O U N D S :-
malafide intention.
[4]
22. That in fact no such incident, whatsoever stated in the has ever
applicant accused and put him behind the bar for ulterior
reasons, the actual facts are that, co-accused shahnawaz being
driver, by getting order of parcel was going by his own way , on
the same alleged date, police party knowingly and deliberately
encircled the applicant party and also after conducting checking,
the complainant party demanded unwarranted Kharcha amount
from the applicant party, on which applicant party refused,
thereon, complainant party being police official, on the awe of
the officials weapons by showing their powers, snatched each
and every thing and amount from the applicant party, and also
by arraning 24 eggs from diffirent places, which he sealed
separately to send the chemical analysis, otherwise, without any
measurement of checking the eggs and without any knowledge
how it can be possible that eggs were un-use-able or not but
looking to the malafide part of the complainant it be indicated
that, each and every thing has been managed by the complainant
and his sweet obligor witnesses.
23. That further malafide part of the complainant is that, eggs are
being kept in flexible place while they may not became

unuseable, so if they will be kept in open sky or at any
unsheltered place, then they can be un-use-able, so complainant
by taking advantage and by using sharp mind has implicated the
applicant accused and others in this false case.
[5]
24. That malafide part of the complainant is that, if the all eggs were
un-useable then he would have to send the same for chemical

analaysis but, complainant failed to perform his duty and also by
managing this false story has implicated the applicant accused in
this false case.
25. That nothing has been committed but this whole drama has been
staged by the complainant.
26. That place of incident is very thickly populated area and same is
business point and area, but police did not associate any private
mashir, and knowingly deliberatly by showing false incident has
violated of section 103 Cr, PC
27. That malafide part of the complainant is that, without any harm,
injury, losses or damages to the mankinds, how it can be

possible, that complainant came to know that, same eggs are un-
userable and are harmful for mankind, which is totally drama
and story mananaged by the complainant stereotyped.
28. That in view of justice, and looking to the prosecution sotry it be
indicated, that, there is no value in the prosecution story and

same 24 eggs separated by the police as alleged, which are
foisted upon the applicant party just to implicate the applicant
29. That as a usually no such death has been happened of makind by
eating or taking the eggs, but complainant
[6]
being police officer he by his own way by suppressing actual

facts has implicated this innocent person.
30. That offence doesn’t fall within the prohabtory clause of section
497 Cr. PC.
31. That it is settled principle law that if single doubt arises in the

which goes in favour of the applicant accused at bail stage.

malafide intention.
33. That applicant accused is not more required to the police for
further investigation.

APPLICANT/ACCUSED
[6]
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2017.
Shahnawaz son of Muhammad Yaseen Mallah

presently confined in District Jail shaheed
Benazirabad …………………………...….Applicant/accused
VS

Nawabshah
U/S 337-J 269, 270, 273 PPC.
BAIL APPLICATION

-: F A C T S :-
complainant, SIP Khan Muhammad Jamali lodged his FIR at
police station B section Nawabshah, on 27-8-2017, at about
with his staff PC Dur Muhammad, PC Nisar Ahmed, PC
Khalid Parvez, PC Wali Muhammad, with police ammunition,
on police Mobile
[2]
No SPM-218, along with driver PC Muhabat Ali, under entry

No 20, dated 27-8-2017, at about 1630 hours, departed for
patrolling from police station towards City, various places,
when they reached at Ghasita Road Line Par Nawabshah,
where, police party got spy information that, one Shahzor
vehicle No KQ-3833 Sindh, colour white, in which some
persons by taking poisning Eggs are taking away to sale out
the same at different places, which are harmful for the
makinds, and due to eating the same death can be happened,
the complainant after receiving such information, he along
with his staff, departed towards pointed place, where
complainant party started checking of different places, when
at about 1715 hours, they saw one person was coming on one
shahzor vehicle, No KQ 3833, Sindh, from the eastern side
Ghasita Road , in which four persons were seated, the
complainant party asked them to stop, the driver of the
vehicle tried to skip away, but police party very tactfully
encircled the vehicle, due to non availability of the private
Mashirs, PC Dur Muhammad, PC Nisar Ahmed were made
Mashirs, the driver was inquired about his name and address,
who disclosed his name to be Shahnawaz, from his body
search, side pocket of the shirt amount of Rs. 1000/- were
recovered, another disclosed his name to be Wajid son of Haji
Khan Qambrani, from his body search amount of Rs. 500 were
recovered,, Naseer Ahmed son of Sallahuddin Kazi from his
body search Rs. 500/- were recovered, Sardar son of Mubeen
Jamali from his body search police secured amount of Rs.
2000/-, the police party saw in
[3]
the mobile, 50 live Pettties/Parcels were lying there, in which

unuseable eggs were lying, in each Parcel/Patie 350 eggs were
lying, out of which smell was coming, the accused also
disclosed that, they used to sale above unuseable eggs in
diffirent bakkaries in the city, and above amount is of
unuseable eggs, the police party secured the same, and 24
eggs were sealed separately for chemcail analysis, and
complainant party also inquired about Shahzor vehicle and its
documents, on which driver disclosed to be unlicensed,
therefore he has been shown under section 337-J, 269, 270, 273,
PPC, arrested them, the vehicle has been proceeded under
Karvai of 550 Cr PC. such Mashirnama was prepared before
the Mashirs, the arrested accused along with recovered
property brought at police station, and where complainant
party stated that the accused persons are selling the un-
useable eggs at diffirent places, which are harmful for
makinds, and death can be happened on eating the same eggs,
hence this FIR.

-: G R O U N D S :-
malafide intention.
[4]
38. That in fact no such incident whatsoever stated in the has ever
applicant accused and put him behind the bar for ulterior
reasons, the actual facts are that, applicant accused being driver,
by getting order of parcel was going by his own way , on the
same alleged date, police party knowingly and deliberately
encircled him and also after conducting checking, the
complainant party demanded unwarranted Kharcha amount
from the applicant, on which applicant /accused refused,
thereon, complainant party being police official, on the awe of
the weapons snatched each and every thing and amount from
the applicant party, and also by arraning 24 eggs from diffirent
places, which he sealed separately to send the chemical analysis,
otherwise, without any measurement of checking the eggs and
without any knowledge how it can be possible that eggs were
un-use-able or not but looking to the malafide part of the
complainant it be indicated that, each and every thing has been
managed by the complainant and his sweet obligor witnesses.
39. That further malafide part of the complainant is that, eggs are
being kept in flexible place while they may not became

unuseable, so if they will be kept in open sky or at any
unsheltered place, then they can be un-use-able, so complainant
by taking advantage and by using sharp mind has implicated the
applicant accused and others in this false case.
[5]
40. That malafide part of the complainant is that, if the all eggs were
un-useable then he would have to send the same for chemical

analaysis but, complainant failed to perform his duty and also by
managing this false story has implicated the applicant accused in
this false case.
42. That place of incident is very thickly populated area and same is
business point and area, but police did not associate any private
mashir, and knowingly deliberatly by showing false incident has
violated of section 103 Cr, PC
43. That malafide part of the complainant is that, without any harm,
injury, losses or damages to the mankinds, how it can be

possible, that complainant came to know that, same eggs are un-
userable and are harmful for mankind, which is totally drama
and story mananaged by the complainant stereotyped.
44. That in view of justice, and looking to the prosecution sotry it be
indicated, that, there is no value in the prosecution story and

same 24 eggs separated by the police as alleged, which are
foisted upon the applicant party just to implicate the applicant
45. That as a usually no such death has been happened of makind by
eating or taking the eggs, but complainant
[6]
being police officer he by his own way by suppressing actual

facts has implicated this innocent person.
497 Cr. PC.


malafide intention.

APPLICANT/ACCUSED
[6]
CERTIFICATE


Allah Dad son of Ghulam Mustafa Wassan

shaheed Benazirabad ….. ………………Applicant/accused
VS
Crime No: 102/2016, P.S, Duar

BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that, Complainant, SIP Abrar

Hussain Rind lodged his FIR at police station Daur, On 13-11-
complainant along with his staff, HC Hazar Khan, PC Rano
Khan, PC Sajjad Hussain, C Ghulam Murtaza, with police
ammunition wearing police dress, on police mobile No SPD
748, along with driver, HC Muhammad Ayoob, under the
entry No. 20,
[2]
dated 13-11-2016, at about 1830 hours, departed for patrolling
within their beat, when at about, 1900 hours, they reached,
near Dargah Mitho Fakeer, where complainant party saw on
the light of the mobile, one person was standing near the
Dargah, who by seeing the police vehicle, tried to run away,
the police party got down from the vehcle and very tactfully
encircled him, and captured him, due to non availality of the
private Mashir, HC Hazar Khan, PC Rano Khan were made
Mashirs, the arrested accused was inquired about his name
and address etc, who disclosed his name to the applicant
accused, the complainant party suspected and conducted
body search, from his fold of shalwar one black shopper was
recovered, same was secured in cutody of the police, which
was opened, in which one large piece of chars and one small
piece of chars detailed bellow were recovered, same was
weighted on spot, which became 1070 grams, the chars was
sealed on spot at once, from his body search, police recovered
Rs. 150 detailed bellow, which were secured by the police, the
police party also inquired about the amount and chars, on
which he disclosed that, above chars is his, and same amount
is earned from the above sold out chars, he is already
involved in crime No. 100/2016, under section 401, 398, PPC
of PS Daur, so applicant accused kept chars in his possession
illegally, he has been arrested under section 9/C, CNSA,
thereafter, such Mashirnama was prepared before the
lodged.
[3]
After after registration of FIR, the applicant accused was
confined in judicial custody hence this bail application on the
following grounds .
-: G R O U N D S :-

ulterior reasons.


79.That place of incident is managed one and same has been

alleged offence.
80.That there is voilatin of section 103 Cr, PC.
[4]
81.That as per provision of section 9/C CNSA and according to
quantity of the chars/Narcotics substance the case of the
applicant accused is no border line of 9/B and 9/C CNSA.
82.That applicant acused is rotting jail since 10 months, without

indefinite period.
83.That as per ingredient of section 9/C CNSA, which is

case.
84.That the recovery of chars, amount etc, which has been foisted
upon the applicant /accused just to implicate the applicant

one.

him.

88.That complainant has been hired by ruling party just to

implicate the applicant accused in this false case.
[5]

stage.


reasons.



[6]

APPLICANT/ACCUSED
CERTIFICATE


Muhammad Jameel son of Roshan Ali

shaheed Benazirabad . ….. ………………Applicant/accused
VS
Crime No: 76/2017, P.S, Daulatpur

BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant, SIP Akhtar
Hussain solangi lodged his FIR at police station Daulatpur, on
20-07-2017 at about 750 hours, alleging therein that, today
complainant along with his staff, each HC Ghulam Nabi
Korai, PC Qurban Ali Dahri, C Khan Muhammad, with police
ammunition, on police mobile No SPD 750, along with C Ali
Asghar Awan, under the entry No 19 dated 20-7-2017 at about
1615 hours departed for patrolling within their beat towards
[2]
NHW, various places, when they reached at, Sanghra Mori,

whre complainant party got spy information, that one person
is awaiting for convenience, at NHW road, near AMeen Shah
stop to sale out the chars at somewhere place , after getting
such information the complainant along with his staff,
reached at pointed place, when at about 700 hours,
complainant party reached at NHW near Ameen Shah stop,
where, police party saw one person from the westen side of
the road, containing one black colour shopper was standing
there, who by seeing the police party near him, he tried to run
away, the complainant party stopped their vehicle, he along
with his staff got down and very tactfully encircled and
captured the person along with shopper, due to non
availability of the private Mashirs, the HC Ghulam Nabi and
PC Qurban Ali, were made Mashirs, the arrested person was
inquired about his name and address, who disclosed his name
to be Muhammad Jameel son of Roshan Ali Leelgar Bhatti,
resident of Mariyam Road Nawabshah, from his body search,
tow notes of 50/50 and two notes of 100/100, total Rs. 300/-
were recovered, the secured shopper was opened and
checked, which was of plastic shopper, in which 20 large
pieces of chars were lying, same was weighted on spot, which
became 10,000 Grams chars, same was sealed before mashirs
with their signatures, for sample purpose, the arrested
accused was inquired about chars, who disclosed that, same
chars is mine and which, he used to sale the same on money,
the police
[3]
arrested him due to keeping chars in his possession and also

shown under section 9/C CNSA, such Mashirnama was
prepared before Mashirs with their signatures, thereafter,
complainant party took the above property and applicant
accused brought at police station and lodged present FIR,
hence this FIR.
After after registration of FIR, the applicant accused was

arrested, whho has been shown in the above false case, and is
confined in judicial custody hence this bail application on the
following grounds .
-: G R O U N D S :-

ulterior reasons.

applicant, so that he come in his illegal terms otherwise
applicant/accused is innocent he has no concerned with the
alleged offence actual facts are that, On 17-07-2017 at about
11:00 police took the applicant accused along with his wife
and other family members was available, on the same time, he
was called outside of the house and detained him at police
station
[4]
B section for about two days and thereafter, On 19-07-2017,

police of PS B section reffered the custody of the applicant
accused towards police station Daualtpur, and On 20-07-2017,
this false FIR has been lodged against the applicant accused,
with malfide intention for ulterior reason, otherwise applicant
accused has no committed offence as alleged and whole
things have been made dramatically against the applicant
accused.
99.That thereafter wife of the applicant accused also moved

applications to SSP District shaheed Benazirabad and DIG
Shaheed Benazirabad Division, but no fruitful result
enlightened, thereafter, wife of the applicant accused moved
applications to higher authorities, by narrating whole
genguine facts that, applicant accused has been called by from
his house and after his arrest, he has been shown, in this false
cases with malafide intention for ulterior reason.
100. That further genguine facts are that applicant accused is

labour type, he is doing business of Kabari, and he has Kabari
shop at Mariyam Road Nawabshah, where other businessman
and adjacent shopkeeper, who in support of the applicant
accused have sworn their affidavits, and narrated actual facts
that , they are knowing the applicant accused since long, he is
innocent and is doing his business of Kabari respectively and
subsequently is not involved into such cirmianl activities and
no such type information has already been received by any
person, but police by managing things and choosing this false
story has
[5]
implicated the applicant accused in this false case so that

applicant may oblige them for ulterior reasons.
101. That place of incident is managed one and same has

been shown knowingly and deleberatly just to make this false
case otherwise applicant accused has no concerned with the
alleged offence.
102. That as per ingredient of section 9/C CNSA, which is

case.
103. That the recovery of chars, amount etc, which has been
foisted upon the applicant /accused.
104. That there is violation of section 103 Cr PC , and case is

made sterriotyped on the basis of false assetions.
105. That prosecution story is uncoroborative, unsupported

and without any substantiation and same is false and
fabricated one.
106. That the applicant/accused has possessed good

reputation in his vicinity present case is nothing but
complainant has no left lack to show his efficiency, just to
107. That case has been challaned, applicant accused is no
more required for further investigation.
108. That nothing has been committed by the

applicant/accused but this whole drama has been staged by
the complainant.
[6]
109. That it is settled principle law that if the single benefit of

stage.
110. That complainant has not shown size, shape and further
111. That no purchaser or further location has been discribed

by the complainant party but there is only foistation of the
chars upon the applicant/accused with malafide intention for
ultior reasons.
112. That there is no previous such type record and applicant

is not involved into such activities but due to reason
mentioned above and due to high influence of police, this FIR
has been lodged on false and fabricated assertions.
113. That from the contents of the FIR it be indicated that,

114. That there is no apprehension of absconsions of the

[7]
115. That other ground will be urged at the time of hearing

when the entire papers will be available.

APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF SESSSIONS JUDGE SHAHEED
BENAZIRABAD
B. A. No OF 2017.
Syed Wali son of Gul Nabi wrongly shown Syed Nabi

Benazirabad ..………………………..……Applicant/Accused
VS
Crime No. 15/2017 PS Gupchani

U/S 14 Foriegner Act
BAIL APPLICATION
grounds:
-: F A C T S :-

SIP/SHO Parvez Ali shah lodged his FIR at police station
Gupchani, on 28-02-2017, at about 1430 hours, alleging therein
that, today complainant along with PC Jawaid Ali, PC Zaheer
Ali, with police ammunition, on police mobile No. SPD -823,
along with driver HC Muhammad Moosa, under entry No 07,
dated
[2]
28-02-2017, at about 11:45 hours departed for patrolling

various palces, when about 1300 hours, they reached at road
which leads from Gupcahni to shahdadpur Link Road, near
Khatyan, where they saw one person was standing at road,
who by seeing the police party tried to run away, the
complainant party suspected and stopped their vehicle, got
down from the vehicle, tactfully encircled him, the
complainant party tried to arrange private Mashir, but not
found, so, PC Jawaid Ali, PC Zaheer Ali were made Mashirs,
the arrested accused was inquired about his name and
address, who disclosed his name to be applicant accused,
from his body search, police secured amount of Rs. 300/-,
further police party inquired about, visa, passort, permenant
address etc, on which he disclosed that he has no permenant
address, CNIC etc of Pakistan, therefore accused has been
arrested in the above case crime, such Mashirnama was
prepared before Mashirs, the police party brought the accused
and property came at police station where present FIR was
lodged hence this FIR.
After registering the FIR, police arrested the

applicant/accused who is in judicial custody, hence this fresh
bail application with fresh grounds .
-: G R O U N D S :-
implicated by the complainant with the malafide intention.
[3]
2. That in fact no such incident whatsoever, stated in the FIR has
ever taken place, but complainant by showing false incident has

implicated the applicant accused, actual facts are that, the police
of PS Gupchani subsequently have lodged series of the case on
some Pathan and by showing false incident, false story, false
things even so by same way, on the day of lodging of the FIR,
applicant was going by his own way to do labouring work, the
police party encircled him and also tried to santch amount and
other things, from the applicant accused, on which is protested
and resisted them, on his resistence, the police party took him
and brought at police station, where this false FIR has been
registered against the applicant accused with malafide intention
otherwise nothing has been committed but this whole drama has
been staged by the complainant and his sweet obligor witnesses
just to put pressure upon the applicant accused and collect
unwarranted amount otherwise applicant accused has no
concerned with the alleged offence.
3. That further factual condition is that, applicant accused is
resident of Pakistan and he is Pakistani and is not Afghani, in

which malafide part of the complainant is that, he has shown
name of father of the applicant accused Syed Nabi in place of Gul
Nabi just to show his false implication, moreover, applicant’s
father namely Gul Nabi son of Muhammad Nabi is resident of
Muhalla Sadiqabad Rawalpindi, so how it can be possible that,
applicant is forienger, the complainant failed to perform his
duty, contrary he by narrating false assertions has implicated
and innocent person/applicant accused with malafide intention
just to put him under pressure, with intention to collect illegal
and unwarranted amount.
[4]
4. That at the time of arrest to the applicant accused, the
complainant and his PWs firstly snatched amount from the

applicant accused and other things, paperes then they by
showing above false story implicated him in this false case.
5. That if the verification will be made for identity of the applicant
accused, which will be same of Pakistan as he and his family has

no cocnenred with Afghanistan and they are not forienger.
6. That applicant accused and his other male member used to sell
cloths at different places, but police without verifying name

address and without getting further detail has lodged this FIR
with malafide intention .
7. That applicant accused is peace loving Pakistani and he is not
foreinger.
8. That nothing has been committed by the applicant accused and
he is not involved into bad activities but he is peace loving

pakstiani.
9. That section 14 foriegner act has been misapplied by the
complainant.
as all the PWs are interested witnesses of the complainant
[5]
11. That there is no apprehendsion of the tampering with the
evidence as applicant/accused is ready to furnish solvent surety

to the satisfaction of this Honourable Court.

APPLICANT/ACCUSED
CERTIFICATE

behalf of the applicant/accused before this honourable court
prior to this no bail is filed by the applicant accused .

MAGISTRATE –II KAZI AHMED
B. A. No: OF 2017.
Qurban son of Dhignao Tanwari
Ghotaki………………………………...….Applicant/accused
VS
Crime No: 142/2017, P.S, Kazi

Ahmed
U/S 392 PPC
BAIL APPLICATION

-: F A C T S :-

complainant, Zulfiqar Ali son of Muhammad Sulleman Lakho
lodged his FIR, On 22-03-2017 , at about 1000 hours, alleging
therein that, he has his own CD-70 motorcycle, applied for
2017, which is registered in the
[2]
name of uncle of the complainant namely Ibrahim, which

complainant himself used to run, On 08-02-2017, complainant
along with his brother Yousif Lakho and relative Arz
Muhammad son of Gullan Lakho in gathering on their
motorcycle, came at Kazi Ahmed town for their personal
work, after getting free, the complainant party were coming
towards their house, the motorcycle was being driven by the
complainant, when at about 4:30 hours, at evening time, they
reached at Sehwan Road, at village Chatto Khoso, where they
saw and identified, four persons, on the raod having weapons
were standing there, who aimed their weapons and stopped
the complainant party, due to fear of the weapons, the
complainant party stopped their vehicle, saw each Qurban
son of Dhignao Tanwari, resident of village Pir Jhando,
Taluka sakrand, having pistol in his hand, Wzeer son of
Ghulam Hussain Bhanojo, resident village Nabi Bux Bhanojo,
having pistol in his hand, Yaseen son of Ranjho Mari resident
of Fateh Ali Mari having pistol in his hand, one unknown
accused having pistol in his hand, who all coming, the
Qurban Tanwari snatched key of motorcycle from the
complainant and other accused persons got downt the
complainant party from their motorcycle, meantime accused
snatched amount of Rs. 1500/- from the pocket of the
complainant, and from the pocket of the Yousif Lakho Rs.
500/- were snatched, from the pocket of Arz Muhammad
amount Rs. 1000/- were snatched by the accused, thereafter,
accused threatened that if the complainant party complian
[3]
against them, then it will not be better for them, thereafter, all
accused by boarding their vehicle run away towards village
Fatoohal Zardari, thereafter, complainant party went and
narrated whole facts with their elders, thereafter, complainant
along with his witneses, who all in gathering went and met
with Wazeer Bhanojo, and reqeusted him to return the
motorcycle and robbed amount, on which, he kept the
cmplianant party on false hopes, ultimately refused, hence
this FIR.

arrested, who is in judicial custody hence this bail application
-: G R O U N D S :-
malafide intention.
54. That there is delay in lodging the FIR for about 1 month, 14 days,
which is inordinate delay and is not explained at all.
staged by the complainant with malafide intention for ulterior

reason, whereas, applicant accused and other accused had
friendly and cordial relations with complainant , so they
grappled on very pitty matters, therefore, complainant by
managing this false story has
[4]
implicated the applicant accused and others in this false case

otherwise applicant accused has no concerned with the alleged
offence.
56. That malafide part of the complainant is that, it is imposible that,
how it can be possible that, complainant has shown residences of

the applicant accused and other co accused of different villages
and different places, so in what manner he is knowing them and
subsequently he has not shown that, they are involved into such
criminal activities or nor but, complainant by making this false
story dramatically has implicated the applicant accused and
other accused in this false case with malafide intention for
ulterior reason just to put them under pressure for his ill-
designed means.
57. That malafide part of the complainant is that, they have shown
place of incident Sehwan Road near village Chutto Khoso, so it

be clarified that, same road is busy 24 hours and village Chutto
Khoso which is populated and bigg village and surrounded the
same area there is no such place to commit offence and skip
away easily, but complainant by managing things and choosing
this false story has implicated the applicant accused and others
in this false case.
58. That malafide part of the complainant is that, he has stated that
accused robbed the amount and motorcycle from the

complainant and besides he has stated that, accused only by
santching amount skip away , so it be verified that nothing has
been robbed and no robbery has been committed of the
motorcycle but this whole drama
[5]
has been staged by the complainant with consent of his sweet

obligor witnesses, otherwise applicant accused has no concerned
497 Cr PC.


malafide intention.

APPLICANT/ACCUSED
[6]
CERTIFICATE


MAGISTRATE –III NAWABSHAH
B. A. No: OF 2017.
Salman Khan son of Muhammad Liyar Rahu

presently confined in Central prison
Sukkur ……………………………...….Applicant/accused
VS
Crime No: 232 of 2017 P.S, A section

Nawabshah
U/S 392 PPC
BAIL APPLICATION

release him on bail in the above case/crime on the
-: F A C T S :-

complainant, Khan Bahadur Malak lodged his FIR at police
station A section Nawabshah on 26-7-2017 at about 1800
hours, alleging therein that, complainant runs his ice factory
in the name and style of Al Madina ice Factory situated in
Bucheri Road Nawabshah, on 9-7-2017, the complainant along
with his employee Nisar
[2]
Jatt, were sitting in front of their ice factory on cot, electric

bulbs were alighted, whena t about 11:00 Night one 125
motorcycle fo the black colour came on which three persons
were boarded, who after stopping the motorcycle, took out
their pistols from their fold fo shalwar, threatened the
complainant to kept quiet, due to fear, compliannt part
remained silent, out of three accused persons complainant
party identified two persons which to be Ali Gohar son of
Hassan brohi and Abdul kareem son of Rustam Gopang,
unknown accused was seen clearly and would be identified if
seen again. The accused Ali gohar on gun point snatched cash
amount of Rs. 42000/- from the front pocket of the
complainant and one Mobile Phone, while accused Abdul
kareme snatched one Mobile Phone set from Nisar, and then
all the accused persons by issuing threats went away on their
motorcycle, due to harassment complainant could not see the
number of the motorcycle, the complainant tried to contact
with the accused persons but could not be succeeded and
ultimately lodged present FIR.
After usual investigation, the police of PS A section

Nawabshah malafidly by showing the applicant accused as
one of the unknown accused and challaned him, the applicant
is in judicial custody, hence this bail application on the
following grounds .
-: G R O U N D S :-
malafide intention.
[3]
67. That neither the name of applicant accused transpired in the FIR
nor his feature descriptions has been given in the FIR, nor any
identification prayed has ever taken place in Jail to substantiate
the claim of the complainant and as such under such
circumstances very involvement of the applicant accused has
became doubtful and as such, case registered against the
applicant accused requires further inquiry.
68. That the place of occurance shown in the FIR is situated Bucheri
Road Taj Colony Nawabshah which is thickly populated

residential area, as wel as commecrical area where round the
clock, peoples, passerby are present, besides this, the alleged Ice
Factory is situated on Bucheri road which is leading to
Nawabshah to Sukkur, which is busy road and round the clock
traffic is playing but is strage that none from locality was
attracted at the time of alleged incident, which itself creates
doubt in prosecution story.
69. That FIR is delayed for about 17 days without any plausible
explanantion which goes to show that the same has been lodged
after deliberation and consultation as such false implication of
the applicant accused can not be ruled out.
70. That no specific role, part, overt act has been assigned against the
applicant accused, as such case against the applicant accused

requires further iqnruiy.
71. That all the PWs cited in the Fir are setup persons of the
[4]
72. That nothing incriminating has been secured from the applicant
accused which prima facie connected the applicant accused with

commission of the offence.
73. That except the solitary words of the complainant and his setup
persons nothing is in place of record except the further stamtent

fo the complainant which too not supported by any substances in
connection of the involvement of the accused being one of the
culprit involved in the commission of the offence.
497 Cr PC.
as all the PWs are sweet obligor of the complainant.

APPLICANT/ACCUSED
[5]
CERTIFICATE

MAGISTRATE –II NAWABSHAH
B. A. No: OF 2017.
Salman Khan son of Muhammad Liyar Rahu

presently confined in Central prison
Sukkur ……………………………...….Applicant/accused
VS
Crime No: 29 of 2017 P.S, Balu Ja

Kuba
U/S 392 PPC
BAIL APPLICATION

-: F A C T S :-

complainant, Muhammad Irfan Malak lodged his FIR at
police station Balu Ja Quba On 26-7-2017 at about 1500 hours,
alleging therein that, he runs his Pedhi shop, near Benazir
Public School Kazi Ahmed, On 10-7-2017, at about 230 PM,
the complainant along with his employee, Sharafat Ali Malak,
and his friend , and Gul Muhammad were sitting at his Pedhi
shop, when one
[2]
125 Motorycle of the Black Colour came there on which three

persons were boarded immediately on arrival, all the three
persons unboarded from their motorcycle, and they all
entered into Pedhi shop, and they all took out their pistols
from their fold of shalwar, aimed the same on the
complainant party and asked them, to keep quite, and asked
whatever having with the applicant party including the cash
amount, same should be handed over them, due to fear
complainant remained silent, the complainant party
identified, them to be the Ali Gohar son of Hassan Brohi,
Abdul Kareem son of Rustam Gopang, both resident of Taj
Colony Nawabshah, out of them Ali Gohar Brohi Rs. 7000/-
cash from the counter and Abdul Kareem Gopang snatched
mobile phone from the complainant and after snatching they
issued threats, and by closing the outer door of the pedhi
went away on their motorcycle, the complainant party have
seen identified accused clearly and would be identified, if
seen again, due to harassment complainant could not seen the
number of the motorcycle, the complainant party then kept on
searching, but could not succeeded complainant went and
lodged present FIR.
After usual investigation, the police of PS Balu Ja Kuba

malafidly by showing the applicant accused as one of the
unknown accused and chalalned him, the applicant is in
judicial custody hence this bail application on the following
grounds .
[3]
-: G R O U N D S :-

alleged offence, but he has been implicated in this false case
with malafide intention.
84.That neither the name of applicant accused transpired in the
FIR nor his feature descriptions has been given in the FIR, nor
any identification prayed has ever taken place in Jail to
substattiate the claim of the applicant and as such under such
circmsutances very involvement of the applicant accused has
became doubtful and as such, case registered against the
applicant accused requires further inquiry.
85.That it is strange, that the place of incident is commercial area,

where round the clock peoples, customers , passerby are
running and doing their their business, roud the clock and the
time of incident has been shown 2:30 PM, which is
unbelviable and itself creates doubt in the prosecution story.
86.That FIR is delayed for about 16 days without any plausible

explanantion which goes to show that the same has been
lodged after deliberation and consultation as such false
implication of the applicant accused can not be ruled out.
87.That no specific role, part, overt act has been assigned against
the applicant accused, as such case against the applicant
accused requires further iqnruiy.
[4]
88.That all the PWs cited in the Fir are setup persons of the
89.That nothing incriminating has been secured from the

applicant accused which prima facie connected the applicant
accused with commission of the offence.
90.That except the solitary words of the complainant and his
setup persons nothing is in place of record except the further
stamtent fo the complainant which too not supported by any
substances in connection of the involvement of the accused
being one of the culprit involved in the commission of the
offence.
91.That offence doesn’t fall within the prohabtory clause of

section 497 Cr PC.
92.That applicant accused is not more required to the police for


94.That applicant accused is ready to furnish solvent surety to


APPLICANT/ACCUSED
[5]
CERTIFICATE


Liaquat Ali alias Liaqoo son of Sarang Ali Khaskheli

presently confined in District
Jail shaheed Benazirabad ………………Applicant/accused
VS
Crime No: 21 /2017, P.S,Airport
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant, SIP Ghulam

Mustafa Abbasi lodged his FIR at police statin Airport, on 6-2-
2017, at about 1830 hours, alleging therein that, today
complainant along with his staff each, ASI Shahzad Khan
Memon, HC Muhammad Ashraf Rind, PC Hafizullah
Khaskheli, PC Kehar Nazeer Chandio, with police
ammunition, on the police mobile No 826, along with driver
PC Inayat Hussain Zardari, left police station under entry No.
17 dated 06-02-2017
[2]
at about 1520 hours, to arrest the Pos, during the patrolling

various places, by patrolling from Manuabad, Gharibabad,
Issarpur, Bhangwar Colony, during the patrolling when at
about 1720 hours, they reached at Shikarpur house, where
they received information that one person namely Liaquat Ali
alias Laiqoo khaskheli is coming from Lakha chowk towards
city Nawabshah containing the chars, to sale out the same, the
complainant party after receipt of such information, they
proceeded towards pointed place, when at about 1730 hours,
when they reached at Lakha Chowk, where they saw, the
above said person containing one black colour shopper in his
right side hand, was coming foot path, who by seeing the
police tried to skip away towareds easten side, but police very
tactfully aprehnded him on the distance of 5 steps , the police
tried to arrange private Mashir but not found so, ASI Shahzad
Khan Memon and HC Muhamamd Ashraf Rind were made
Mashirs, the arrested pesons was inquired about his name,
address and parentage, who disclosed his name to be Liaquat
Ali Alias Liaqoo, son of Sarang Ali Khaskheli, resident of
Jamal Khan Khasheli, Deh Nai Abad, Taluka Mehrabpur,
District N-Feroze, from his body seach, the police recovered
two notes of 500/500, and five notes of Rs. 100/100, total
amount of Rs. 15,00/- and one small knife was recovered from
the accused, the police also opened the shopper in the same
shopper there two other shoppers were lying, containing the
chars, viz five large pieces were in first shoper and in 2 nd
shoper 4 small pieces of chars were lying, total was weighted
which became 7000 grams, the entire
[3]
chars was sealed for chemical analysis, meantime, amount

and knife was sealed separately, the accused person was
inquired about chars, he disclosed that , he used to sale the
same on money at different places, thereafter, complainant
also arrested him in the above case/crime, such Mashirnama
was prepared before the Mashirs with their signatures, the
accused and recovered property was brought at police station
where present FIR was lodged .
After usual investigation, the challan was submitted

before competent court of law, accused was brought in
judicial custody, hence the applicant accused got filed present
bail application before this Honourable Court with following
ground.
-: G R O U N D S :-
116. That the applicant /accused is innocent and had not

ulterior reasons.
117. That in fact no such incident, whatsoever stated in the

FIR has ever taken place, but complainant by managing things
just to show false implication of the applicant in present case
has foisted such quantity of narcotics substance upon the
alleged offence actual facts are that, prior to lodging of this
FIR, the applicant accused was attending dates of hearing in
crime No
[4]
94/2016 of PS Hallani, before the Honourable Additinal

session judge Kandiaro, so On 1-2-2017 applicant was
arrested from the court premises of Kandiaro by the police viz
ASI Asghar Ali Ujjan, and other police officials, on the next
date viz 02-02-2017, the brother fo the applicant namely
Dhingano filed direct complainant against the police personal,
before concerned court of law and same was also transferred
to the Honourable session judge N-Feroze, which was
transferred to 1st Assistant session judge Kandiaro same was
came on record, on 4-07-2017 and order passed in favour of
applicant party, so complainant of above case, just to save his
skin and save the skin of above police officials shown in direct
complaint also shown the applicant accused in this false case
by managing things with police of PS airport and also
challaned the case within the jurisdiction of this Honoourable
court, with malafide intention for utlrior reason.
118. That there is delay in sending the so called chars for

chemical analysis for about 16 days, which is inordinate delay
and same is not explained at all.
120. That malafide on the part of the complainant can be

verified from the facts that such place cited in the FIR is
thickly populated and it is imposible to commit offence
[5]
or sale the chars easily or openely, but complainant by

showing wrong place of incident has made this false story
very technically.
121. That there is violation of section 103 Cr PC having the

superior population area as Shikarpur House, which is
situated in midd heart city of Nawabshah so it is imposible to
sale out the chars openly at the same place, so it be verified
that, complainant by managing things has implicated the
applicant accused in this false case .

complainant has no left lack to show his efficiency just to


the complainant.

stage.
description of chars, but only shown chars in
[6]
the contents of the FIR, which creating highly doubt in

prosecution story.
127. That no purchaser or further location has been discribed

chars upon the applicant/accused with malafide intention for
ultior reasons.

mentioned above and due to high influence of police, this FIR
has been lodged on false and fabricated assertions.



APPLICANT/ACCUSED
[7]
CERTIFICATE


MAGISTRATE –I NAWABSHAH.
B. A. No: OF 2017.
in Cr, Case No of 2017
Amjad Ali son of Sher Muhammad Rind

Benazirabad ………………..…………….Applicant/accused
VS
Crime No. 66/2017, P.S Taluka

Nawabshah U/S 3/4 , PEHO.
BAIL APPLICATION

-: F A C T S :-

complainant, SIP Manzoor Ali Bhangwar lodged his FIR at
police station, Taluka Nawabshah, on 15-06-2017, at about
with his staff, HC Rano Khan, PC Abdul Qudoos, PC Izzat Ali
with police ammunition, on police mobile No. SPD-002 along
with driver Habibullah, departed from police station, when at
about 1530
[2]
hours, they were patrolling within their beat, various places,

when they reached at Landhi Stop Sakrand road Nawabshah,
where complainant party got spy information that, accused
Amjad, near his house at Sim nala Mori, where he is insisted a
bathi of Katcha wine and selling the same, after receipt of
such information, the complainant along with his staff,
departed towards pointed place, when at about 1630 hours,
the complainant party reached at pointed place, where they
saw, one person in the bushes of Devis was sitting, who by
seeing the police party wearing the dress, tried to run away by
taking one white colour gallon in his hands, the complainant
party got down from the mobile, and apprehended the run
away person containing the gallon, the complainant tried to
act for private Mashir but not found, so HC Rano Khan, PC
Abdul Qudoos were made mashirs, from the arrested
accused, te police party secured one gallon in their possession,
inquired about his name and address, parentages, who
disclosed his name to be Amjad Ali son of Sher Muhamamd
Rind, R/o own houses, Deh 40 Dad, Taluka Nawabshah,
District shaheed Benazirabad, from his body search, four
notes of 50/50 total amount of Rs. 200/- were recovered from
his side pocket of shirt, the gallon of white colour and shopper
was opened by the police which was contained 20 Litters
Katcha wine, from the above Kacha wine, one Bottle was
sealed seprated for chemical analysis, and other Katcha wine
was sealed in white colour gallon separately as a police
property, from the trees of the devis one Iron Drum was
recovered, in which unprepared, Kathca wine was lying ,
which was secured by the police, the accused has been
arrested
[3]
due to prepareing the and selling the katcha wine, such

Mashirnama was prepared before Mashirs thereafter, accused
along with recovered property brought at police station,
where present FIR was lodged, hence this FIR.

arrested, who is confined in jducial custody hence this bail
-: G R O U N D S :-

complainant with the malafide intention for the ulterior
reasons.
97.That the case property and currency notes have been foisted
upon the applicant/accused.
98.That nothing was recovered from the exclusive possession of

the applicant accused and alleged property has been clearly
foisted upon the applicant accused.
99.That the place of incident has been shown by the police,

100. That according to content sof the FIR, police party has
not shown that, applicant was preparing the Katcha wine or
not and they have not recovered any manufacturing
[4]
articles from the place of incident, even otherwise no any

dummy or purchaser person was seen or mentioned in the FIR
by the police that who were purchasing the Katcha wine from
the applicant, therefore the section 3 and 4 are not attracting to
the present case and same are misapplied by the police.
101. That actual facts are that, complainant has been hired
by the a local Wadera who is belonging with ruling party so
complainant just to oblige him has lodged this false story
otherwise nothing has been committed but this whole drama
has been staged by the complainant and his staff.
102. That there is violation of sec tion 103 Cr PC.

103. That alleged recovered Katcha wine has been shown as
recovered and its quantity has been shown 20 litters without
measuring by measuring articles , which creating highly
doubt in prosecution story, even otherwise, the quantity for
sample has not been shown , the actual measurement that
how much Katcah wine was sealed separeatly for chemical
analysis, so it be indicated that things have been managed by
the complainant and his staff with malafide intention for
utlrior reasons just to favouring the person of ruling party.
104. That case has been challaned, and applicant accused is

not more required for further investigation by the police and
he has been arrested on 15-6-2017 since applicant accused is
behind the bar and facing trial.
[5]
105. That there is no previously record of such type against

the applicant accused, so as per contents of the FIR it be
indicated that, each and every thing has been cooked up.
106. That section applied in the FIR doesn’t fall within the
107. That it is a settled law that bail should not be treated a

108. That applicant/accused is ready to furnish solvent

109. That other ground will be urged at the time of

arguments.
APPLICANT/ACCUSED
CERTIFICATE

applicant accused.

MAGISTRATE –II KAZI AHMED
B. A. No: OF 2017.
Fayaz Hussain son of Ghulam Muhammad Jatoi

presently confined in Distrit Jail shaheed
Benazirabad ……………………….…….Applicant/accused
VS
Crime No: 14/2017, P.S, Lakhat

U/S 3/6 Sindh Sound System
Regulation Act 2013
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Moula Bux Chandio lodged his FIR at police
station Lakhat, on 18-8-2017, at about 1115 hours hours,
alleging therein that, today complainant along with his staff,
PC Imamuddin, PC Mehboob Ali, with police ammunition, on
police Mobile No. SP 171, along with driver PC Abdul Malik,
under entry no 5,
[2]
dated 18-08-2017 at about 0905 hours, departed for patrolling

from PS, various places, when at about 1030 hours, they
reached they reached link road Lakhat, leading to the Duar,
where complainant party saw, from the Link Road side of
Lakhat, one Chingchi Motocycle, thereon one person seated
and driving seat, who was listening the sound by tape record
soundly, the complainant party stopped the Chingchi and got
in one side, tried to found private Mashir but not found, so PC
Imamuddin and PC Mehboob Ali were made Mashirs, the
accused was inquired about his name which to be applicant,
from his side pocket one note of Rs. 50 was recovered, and
complainant party secured Loud spkeaer, and also inquired
about the license of the Chingchi, but person could not
produce the same, thereafter, complainant party, was secured
in custody of the police, the accused was arrested in the above
case, crime , the accused and recovered property brought at
police station where FIR was lodged hence this FIR.
After registration of the FIR, the police of PS Lakhat

arrested the pplicant accused, he is in judicial confined, hence
this bail application on the following grounds.
-: G R O U N D S :-
110. That the applicant/accused is innocent and had

committed no alleged offence, but he has been falsely
implicated by the complainant with the malafide intention for
the ulterior reasons.
[3]
111. That in fact no such incident whatsoever stated in the

FIR has ever taken place but this whole drama has been
112. That prior to lodging of this FIR, the complainant also

knowingly and deleberatly had stopped to the applicant
accused and also demanded Kharcha amount, on refusal of
the applicant, the complainant also warned the applicant
accused that now he will face consequences, result fo which
he has been implicated in this false case.
113. That Tape record has been foisted upon the applicant
accused, while when complainant party brought the applicant
accused and Chingchi at police station without making any
inquiry, the complainant firstly lodged this false FIR and then
shown false assertions and things just to rope the applicant in
this false case.
114. That section applied in the FIR which doesn’t fall within
the prohibitory clause of section 497 Cr PC.
115. That place of incident is thckly populated area but

police failed to associate private Mashir and violated of
section 103 Cr, PC.
116. That in fact as per contents of the FIR it be indicated that

staged by stereotyped.
117. That prior to this applicant is not involved in any case as
per instruction.
[4]
118. That applicant accused possessed good reputation and

he is poor simple type person but he has been implicated in
this false case with malafide intention for ulterior reasons.
119. That according to section 3/6 of Sindh Sound System

regulation , which is misapplied and not attractable.

121. That applicant accused is ready to furnish solvent surety

122. That other grounds will be urged at the time of

arguments.

APPLICANT/ACCUSED
CERTIFICATE


MAGISTRATE –II NAWABSHAH
B. A. No: OF 2017.
1. Ali Gulab son of Rasool Bux Soomro

2. Manzoor Hussain son of Gul Muhammad Soomro
both confined in police custody at PS railway
Nawabshah, District shaheed
Benazirabad ……..……………….….Applicants/accused
VS
Crime No: 24/2017, P.S, Railway

Police Nawabshah
U/S 379, 34 PPC
BAIL APPLICATION

applicants/accused, that this Honorable Court may be to
release them on bail in the above case/crime on the
-: F A C T S :-

complainant, Imam Dino lodged his FIR at police station
Railway police Nawabshah, on 10-8-2017 at about02:50 hours,
alleging therein that, today complainant along with SHO
Shahzado Khan, PC Muhamamd Javed, PC Muhammad
Ashraf, arrested the applicants accused Ali
[2]
Gulab, Manzoor Hussain, resident Khairpur Mirs, and

recovered amount of Rs. 157940/- and one CNIC Cpy one
brown Baig which is cutt of from upper side, in the Baig there
was lying One Key, one Ticket of railway Jounrney, such
arrest made before rehmatullah Soomro, they came at police
station, the complainant himself also stated that, he is
resident of Halla he further stated that he along with his
cousin Rehmatullah in gathering, departed On 9-8-2017, to
purchase Jahez articles for marriage of his sister, from
Karachi, and seated from Khairpur city in sukkuer express to
go at Karachi , and also booked seat with birth No 31/6, 35/6.
the complainant was contained with amount of Rs. 157940 /-
after departure, out of which complainant kept amount of Rs.
100,000/- in purse separately and an other amount Rs. 57940,
were kept by the complainant along with Photostat copy of
CNIC in his bag in seprate purse of the baig, and also locked
the same, and key of the baig kept with himself, while relative
of the complainant Ali Gulab and Manzoor Hussain who saw
the complainant at the time of keeping the above amount in
baig, in the Baig there was lying three suits, Shalwar, Kameez,
one Paint Shirt, from the Khair Station, Ali Gulab and
Manzoor Hussain slept on the another birth, today on 10-08-
2017, at about 1:35, hours, complainant felt that, anyone is
taking things from his head side, the complainant awoken and
saw, Manzoor was taking baig from the head side of the
complainant, and Ali Gulab was also standing nearby
Manzoor, who by taking bag of the complainant got down
from the train , the complainant
[3]
became astonish, who by leaving the complainant at

Khairpur station went away, and they are arrived within
jurisdiction of District shaheed Benazirabad, the complainant
got awoken to his companion Rehmatullah and train beggan
to start, the complainant within soon manner also narrated
whole facts him, and they both got down at plat form from
the running train, where complainant party made cries, where
police party came, and complainant party narrated them
whole facts, and they came to know that above police station
is of Nawabshah, the complainant party narrated whole facts
with police party, the complainant party along with c police
started searching the accused, the complainant party saw the
lightly shining from Jangli Jhariyan from the ending side of
Mall Gowdown , the complainant party also encircled there,
and saw the above both accused were there, and Ali Gulab
was having Mobile Phone and torch was burning, the police
party also saw on the light of torches that, baig of the
complainant which was cutt from upper side, and one blade
and peieces of the papers wre lying there, the above both
accused tried there to run away, but they were arrested with
help of police party, from the shalwar of Manzoor Hussain in
Pink Colour shopper where found notes of 5000/5000 total
five notes, and 75 notes of 1000/1000 and from the shalwar of
Ali Gulab, police recovered from blue colour shopper total 57
notes of 1000/1000/- and 9 notes of 100 rupees and two note
of 20/20 and CNIC copy of the complainant and other thigns
have been identified by the complainant, during police
proceeding, both accused were arrested, the baig was cutt by
the
[4]
accused by blade and all thigns were lying seprate from baig
and trig blade and its paper was lying there, which
complainant handed over to the police and same were
secured, the complainant also put signature upon such
proceeding/Karvai, Ali Gulab and Manzoor Hussain who by
making conspiracy have stolen above thigns of the
complainant hence this FIR.
After registration of the FIR, the police of PS Railway

arrested the applicants accused, who are in police lock at
Railway police Nawabshah hence this bail on the following
grounds .
-: G R O U N D S :-

committed no alleged offence, but they have bene implicated
in this false case with malafide intention.

staged by the complainant with malafide intention for the
utlrior reasons, actual facts are that, the complainant and
applicants accused are cousins they in gathering were going
to Karachi to purchase th dower and gold ornaments from
Karachi, whereas when applicants accused and complainant
seated in sukkuer express, and reached within juridisction of
Nawabshah, where police party also during checking came
and checked the baig of the complainant and also took the
same, thereon complainant protested, on his protested police
by putting evil eyes over the amount also took the baig and
went away, the complainant and applicant accused with
purpose to get
[5]
release the baig and other articles went behind the police party,
when they reached at railway police station where police party
demanded them huge kharcha amount, on which complainant
refused, on his refusal, applicants accused have been shown in
the above false FIR.
125. That nothing has been committed while complainant is

ready to swearing his affidavit that, above incident is false
one and nothing has been committed but this whole drama
has been staged by the police just to get unwarranted and
illegal amount so on refusal of the complainant and applicant
party they have been booked in the above FIR otherwise
thing made in the FIR are false and fabricated one.
126. That applicants accused are innocent and they have

committed no offence but have been implicated by police of
PS railway.
127. That contents of the FIR are false and fabricated while
complainant is ready to give his no objection in favour of the
applicants accused that no plausibly offence has been made
out but things have been managed by the police.
128. That applicants accused have no concerned with the

alleged offence.
129. That thigns have been made stereotyped.
[6]
131. That it is settle principle law that if any single doubt

arose in prosseuction story, then each and every benefit of the
doubt should goes in favour of the applicant/ accused at bail
stage.



arguments.

APPLICANT/ACCUSED
[5]
CERTIFICATE


MAGISTRATE –III NAWABSHAH
B. A. No: OF 2017.
Muhammad Saleem son of Khair Muhammad Malak

presently confined in District Jail Shaheed
Benazirabad ……………………….…….Applicant/accused
VS
Crime No: 220/2017, P.S, A section

Nawabshah
U/S 427, 506/2 PPC .
BAIL APPLICATION

-: F A C T S :-

complainant, Mst Razia lodged her FIR at police station A
section Nawabshah, on 18-7-2017, at about 16:00 hours,
alleging therein that, her marriage consummated with
Muhammad Saleem son of Khair Muhammad Malak, actual
resident Khadro, presently Manuabad Nawabshah, to whom
she gave birth to three sons and
[2]
four daughters, due to matrimonial affairs, On 19-09-2016, the

marriage of complainant and accused was dissolved through
Honourable court, and Honourable court directed to
Muhammad Saleem to give amount of Rs. 15,000/- per
month to minors, Muhammad Saleem was not paying the
expenses to the minors, the complainant filed case in family
court on which Muhammad saleem was annoyed, On 09-12-
2016, she along with her daughter Muhammad Zeeshan and
brother Ali Hassan and other children were available at their
house, when at about 11:00 hours, day time Muhammad
Saleem, and Khair Muhammad Malak came at house in
intoxicant condition, having danger in their hands, who was
extending murderous threats that if the complainant did not
withdraw from the case, then she would be killed and caused
damages, T.V, Fridge and Almirah, the son of the complainant
Muhammad Zeeshan and brother Ali Hassan intervened and
gave name of Almighty Allah and rescued the complainant
party thereafter, he by giving threats of dire consequences run
away, thereafter, complainant moved an application before
honourable session judge for registration of FIR, which was
transferred to 1st Additional session judge for hearing, who
heard and gave order for registration of FIR hence this FIR.
After registration of the FIR, the police of PS A section

Nawabshah arrested the applicant accused, he is in judicial
confined, hence this bail application on the following
grounds.
[3]
-: G R O U N D S :-

the ulterior reasons, actual facts are that, there is family
dispute in between the both parties, due to such family
affairs, the complainant by managing this false story has
lodged this false FIR, otherwise applicant accused has
committed no offence.
136. That there is much delay and inordinate delay for about
7 months and 9 days in lodging the FIR, so such delay is not
coverable and same is not explained at all.
137. That further malafide part of the complainant is that,

incident has been shown dated 18-7-2016 and order got from
Honourable court of 1st Additional session Judge On 19-6-
2017 and matter has been reported on 18-7-2017, so it be
indicated that delay and delay has been occurred to lodging
the FIR so looking to the facts of the FIR it be indicated that
nothing has been committed but this whole dram has been
staged by the complainant with malafide intention.
138. That nothing has been caused damages of the

complainant, while applicant accused was not aware about
such incident but after lodging of the FIR, when police
arrested him he came to know that, this false FIR has been
lodged against him.
[4]
139. That applicant accused is government servant and at the

time of lodging the FIR applicant accused was on his duty.
140. That no specific role, part, injury or overt act assigned

to the applicant accused but this whole drama has been made
malafidly.
141. That prior to this applicant is not involved in any case as

per instruction.
142. That applicant accused possessed good reputation and

he is poor simple type person but he has been implicated in
this false case with malafide intention for ulterior reasons.
143. That complainant is greedy type free minded lady she

by showing false incident and choosing false story succeeded
to lodge this false FIR against the applicant accused.

stage.

[5]


arguments.

APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF SESSION JUDGE SHAHEED
BENAZIRABAD
B. A. No: OF 2017.
1. Amir Hussain son of Zanhwar Muhammad Qasim

2. Faraz Hussain son of Noor Hussain Jamali
both confined in police lockup at Bandhi
Taluka Daur, District shaheed
Benazirabad ……….…… ….…......Applicants/accused
VS
The State …………………………………..………………Opponent
Crime No: 67/2017, P.S Bandhi

U/S 337-L (ii), F(i), A (ii),, 324, 504,
147, 148 PPC .
BAIL APPLICATION
UNDER SECTION 497 CR.P.C.
It is prayed on behalf of the applicants/accused , that

this Honorable Court may be pleased to release them , on bail in
the above case/crime, on the consideration of the following facts
and grounds:-
-: F A C T S :-
Briefy facts leading to present case are that, Complianant Haji

Muhammad Ismail lodged his FIR at .police station Bandhi on 27-7-
2017, at about 14:30 hours alleging therein that, he is residing at
above mentioned address, in front of his house, he has a Kiryana
Mirchant shop, which he himself used to run, in front of his shop,
there is a open plot, at evening time, boys of the complainant party
and other nieghbourers, they used to play Wali Ball
[2]
game, yesterday son of the complainant Ghulam Abbas and

nephew Ali Nawaz were plying Wali Ball, where namely Faraz
Hussain son of Noor Hussain Jamali, R/O Village Ghulam Rasool
Jamali, deh 64 Nusrat, during the play of Wolly Ball exchanged hot
words with son and nephew of the complainant, the complainant
was available at shop at about 7:00 Pm , where complainant party
saw namely Wahid Bux having pistol in his hand, Fayaz Hussain
having repeater, Faraz Ali having pistol, Ameer having DBBL Gun,
Noor Hussain having hatchet in his hand, Faizal, Sattar, Nazeer,
Anwar, Zaheer, having lathies in their hands and other 9 unknown
persons having lathies in their hands, who have been seen clearly,
would be identified if seen again, who all by rioting came at shop of
the complainant, meantime Wahid Bux jamali aimed his pistol and
made straight fire upon the complainant, the complainant himself
saved, and fire was missed, meantime son of the complainant
Ghulam Abbas and nephew Ali Nawaz on the firearm report came
out, thereon, Noor Hussain gave hatchet blows to both, Faizal,
Sattar, Naveed, Anwar and Zaheer, gave lathies blows to the son
and his nephew which hit on their head, arms and other part of
body, they both fell down, the complainant cries for save save, on
the cries of the complainant his son Mohram, and nephew Sobho
son of Nooral Jamali rushed there, duiring that period persons
having lathies gave lathies blows to the son of the complainant and
his nephew, thereafter, complainant, Mohram, and sobho gave
name of Quran to the accused persons and rescued the Ghulam
Abbas and Ali Nawaz, thereafter Fayaz Hussain, Faraz Hussain and
Ameer Ali, just to create harass upon the complainant made aerial
firing of pistols and DBBL gun, they went away towards their
houses, thereafter complainant saw son of the complainant
[3]
sustain injuries on his little figure of right side hand, on thumb of

the left side hand, and on the compaws hatchet blows were
sustained, was bleeding, and on his other bodies blows were hit, the
nephew of the complainant Ali Nawaz sustained hatchet blows on
his head and back and blood was ooazing and on the other part of
body, injuries were available, thereafter complainant took his sons
Mohram Ali, nephew sobho, Ghulam Abbas and Ali Nawaz, for
urgent treatment at RHC Bandhi, thereafter complainant came at
.police station Bandhi for medical letter to get treatment of the
injured and afte getting treatment he came and lodged present FIR .
After registering of the FIR, police of PS Bandhi arrested the

applicants/accused in the above case/crime, who are in police lock
up, hence this bail application on the following grounds .
-: G R O U N D S :-
1. That the case against the applicants/accused is false and

fabricated one, they have committed no offence, but they have
been implicated with malafide intention for the ulterior reasons .
2. That there is delay of one days in lodging FIR without furnishing

pualsible explanantion.

ever taken place but this whole, drama has been staged by the
complainant with malafide intention for the utlior reasons, actual
facts are that, on the day of incident co- accused Zaheer was not
available at place of incident
[4]
who was on shirine of the Lahoot and co-accused Naveed was at
Punjab with visiting purpose, and co-accused Wahid was at
Karachi, so complainant suppressing actual facts has lodged the
FIR on innocent persons even they were not available at the place
of incident on the day of incident as alleged by the complainant
and other applicants/accused and co accused have been
implicated knowingly, deliberately , by the complainant party
they are politicians persons and having high approach to the
police of District shaheed benazirabad, so complainant by
managing things with concerned SHO of PS Bandhi got lodged
FIR with malfide intention for the ulterior reaons otherwise
applicants accused have no concerned with alleged offence.
4. That co accused Noor Hussain, Abdul Sattar, Fayaz Hussain and

Anwar, Wahid Hussain, Faizal alias Faiz Muhammad and
Zaheer alias Zaheer Abbas are admitted on interim pre arrest
bail application by the Honourable court of 1 st Addj, session
judge SBA.
5. That in fact there is no injury on the person of the complainant,

or other injured namely Ghulam Abbas, Ali Nawaz, or others,
but complainant is in league and who is intending to maange
certificate and things with police and duty doctor of RHC
concerned, will get false managed certificate wit malafide
intention just to put pressure upon the applicants accused.
6. That malafide part of the complainant is that, he has shown

applicant co-accused Noor Hussain caused hatchet blows to the
son and nephew of the complainant as alleged
[5]
but, in fact Noor Hussain is unware about such incident, while
house of the complainant and applicants accused are on the
distance about two KM, but how, so which is impossible that,
complainant only shown persons, that above persons came and
Noor Hussian gave hatchet blows to son of the complainant and
nephew on their person, besides complainant did not show that
at what vehicle or in what way they came there and moreover
there is no injury on the person of the sonof the complainant and
nephew, but whole things have been managed by the
complainant.
7. That malafide part of the complainant is that, he has shown

persons about 19/18, having pistols, DBBL and other deadly
weapons but no firearm injury sustained by the complainant
party and only some common blows have been shown by the
complainant, so it be verified that, nothing has bene committed
8. That malafide part of the complainant is that he has shown that

co-accused Wahid Bux made straight fire upon the complainant
but he saved himself, thus for actual facts are that co accused
Wahid Bux is not Wahid Bux but he is Wahid Hussain, so
accused Wahid Hussain is in Karachi city and at the time of
incident he was not available there, but, this false story, has been
regsiteed with malafide intentions just to implicate the applicants
accused and others with malafide intention for utlrior reasons.
[6]
9. That further malafide part of the complainant is that, he has

shown co-accused namely Zaheer Hussain, and other co
accused, Faizal, Sattar, Naveed and Anwar, having lathies in
their hands and gave lathies blows to his son Ghulam Abbas and
nephew Ali Nawaz, but actual facts are that, before the incident
co-accused Zaheer Hussain at the time of incident as alleged, he
was at shrine of Lahoot Noorani Noor, in Balochistan province
with his Murshad, and co accused Naveed was at Punjab and
they were not available at the place of incident, on the same day,
but complainant very tactfully by managing things with
malafide intention has implicated the applicants accused, just to
show false implication of the applicants/accused.
10.That in fact nothing has been committed but this whole drama
has been staged by the complainant.
11.That applicants/ accused are not hardened criminal nor

desperate nor previous convict as per instruction.
12. That applicants/ accused possessed good reputation in their

vicinity.
13.That no injury is on the part of the complainant, co-accused

Noor Hussain has been shown with direct role with malafide
intention, so it is verified from the contents of the FIR, that, there
is no specific role, part injury on the other applicants/accused
and co accused persons, while there are general allegation upon
the applicants accused.
[7]
14.That there is ineffective firing, which is not attributable upont the

applicants/accused.
15.That it is well settled principle of law that if a single doubt arose
in prosecution story, then each and every benefit should go in
favour of the accused party at bail stage.
16.That there is no apprehension of the absconsion of the

applicants/ accused as all the PWs are sweet obligor of the
complainant.
17.That there is no aprehension of the tampering with the evidence

as applicants/ accused are ready to furnish solvent surety to
satisfaction of this Honourable court

APPLICANTS/ACCUSED
CERTIFICATE
This is certify, that this is first bail application on behalf

of the applicants/accused, in above case and crime, prior to this
bail no any other bail moved on behalf of the applicants/accused
before this Honourable Court or any other competent court of law
in respect of the above case/crime as per instructions.
ADVOCATE FOR THE

APPLICANTS/ACCUSED
IN THE COURT OF SPECIAL JUDGE ANTI TERRORISM
COURT SHAHEED BENAZIRABAD
B. A. No: OF 2017.
1. Janib son of Raza Muhammad Zardari

2. Khair Muhammad son of Khuda Bux Gupchani
both confined in District Jail shaheed
Benazirabad …………………….…… Applicants/accused
VS
The State ……………….………………………………Opponent
Crime No: 129/2017 , PS Kazi

Ahmed
OFFENCE U/S 365-A 6/7 ATA .
BAIL APPLICATION
UNDER SECTION 21-D of ATA 1997, R/W S-497, Cr.P.C.
It is prayed on behalf of the applicants/accused
named above , that this Honorable Court may be pleased to release
them on bail in the above case/crime on the consideration of the
-: F A C T S :-
Briefly facts leading to present case are that, coplianant Abdul

Malik lodged his FIR at police station Kazi Ahmed On 18-7-2017 at
about 22:00 hours, alleging therein that, complainant has his owned
zamindari, On 12-6-2017, he along with his friends each Fazal Ul
Rehman, and Hafiz Saifullah, all in gathering were gone to Sehwan
Sharif for Ziyarat purpose, whereafter after performing the Ziyarat,
they
[2]
laid down from Van vehicle, at at Kazi Ahmed bypass, at about 5:00
Pm evening time, they saw one white carry Suzuki , came and
stopped in front of the complainant party, out of which, 6 persons
having weapons dismounted from it, they all aimed their
weapons/pistols upon the complainant, and asked to sit in their
vehicle otherwise they will kill him, due to fear, the complainant
set in their vehicle, and accused also asked to friends of the
complainant that, they are kidnapping away him with purpose of
collect illegal ransom, so they may arrange amount of Rs.
200,0000/-, thereafter, accused persons tied the eyes of the
complainant and went away, and also brought at unknown place,
and all accused persons time and again were staying the
complainant at different places, out of which three persons were
talking on phones who disclosed their names Janib Zardari,
Shoukat Brohi, Mushtaque Lakho, and three persons did not show
their names , and were asking the complainant that that persons of
the complainant have yet not brought the amount of ransom Rs.
20,00,000/- if they not come then they will kill him, today they
detained the complainant in one abdoned Wall/Kot, meanwhile
complainant by taking advatange, succeeded to run away and by
making inquiry, also approached at police station and also narrated
whole above facts, hence this FIR was lodged.
After usual investigation the Police of PS Kazi Ahmed

arrested the applicants/accused named above, who are in judicial
custody hence this bail application on the following grounds .
-: G R O U N D S :-
16.That case against the applicants/ accused is false and fabrcaited

one and they are innocent as accused Janib is
[3]
overment employee serving as Excise Inspector accused Khair

Muhammad is poor man and labourer.
17.That no alleged incident is ever taken place but whole drama has
been staged by the police for ulterior reasons on the instance of
ruling party.
18. That there is inrodiante delay of almost 36 days, in registration

of FIR and such a long delay has not been plausible explained at
all by the complainant, hence false implication of the applicants/
accused can not be ruled out.
19.That there is no any evidence available on record to show that

complainant has actually left from Sehwan Sharif Ziyarat on 12-
6-2017 for Kazi Ahmed by pass, and van or not when he was said
to have been kidnapped on that date from Kazi Ahmed Bypass
as there is neither any FIR by his friends or other relative of the
complainant , or telegram, or in media Kazi Ahmed, about the
missing of complainant which needs consideration, that false
implication of the applicants/ accused can not be ruled out.
20.That there is no evidence collected by the S.I.O about the
kiandpaping of complainant from his friends named above that
he was kidnapped from the Kazi Ahmed bypass or not though
SIO, has not visited place of incident Kazi Ahmed bypass which
also makes the case of the applicants one of further inquiry.
21.That it is strange enough that the FIR doesn’t transpire any of

witness about the confimrantion of the complainant that, by
whom complainant has been kidnapped or not
[4]
and friends of the complainant did not report such facts before
police of PS Kazi Ahmed or parents of the complainant about
this kidnapping of the complainant but this whole drama has
been staged by the complainant at the instance of police has
obligoed.
22.That malafide part of the complainant is that, he or his

witnesses /friends could not note number , or further detail of
vehicle, but only implicated the applicants accused in this false
case and where that wehicle gone to away the direction on road.
23.That how it can be possible that, thereafter complainant has

shown any identity of the applicants accused and even they are
not known to each other, but at once he has been kidnapped by
the applicants accused with purpose to collect ransom amount,
then how it can be possible that, applicants accused were in
advance knowledge that this person is rich or poor and he can
afford such amount or not but complainant by managing this
false story has implicated the applicants/accused with malafide
intention.
24.That complainant failed to show the place wherefrom he
succeeded to run away from clutches of the applicants accused,
and he did not accompanied the police or other person to show
the place, where he reached and inquired about their, went to
police statin for FIR.
25.That place of incident/kidnapping of the applicants accused is

thickly populated area and Bus stop, there is no such place to
kidnap person easily and run away or
[5]
take away, while, police is patrolling round the clock at that
place but complainant by managing this false story has
implicated the applicants accused.
26.That there is dispute over the landed property in between the

Zardari community and relative of the applicant accused Janib,
while police arrested the applicant accused Janib, On 5-6-2017,
however, On 5-7-2017, wife of the applicant accused Janib
namely Mst Sahib Khatoon filed application under section 491 Cr
PC in which raid conducted by Civil Judge & JM-III Nawabshah
for release of the applicant accused besides date of incident is 12-
6-2017, that time applicant accused was in police custody so how
it can be possible that, applicant accused Janib or other would
have been kidnapped to the complainant, while in the lock up PS
Kazi Ahmed in which it was found that accused Janib and three
persons namely Khair Muhammad Gupchani Budhal Chandio
and Shahid Arain, as per statement of the accused Janib Zardari
he was kept at different police station .
27.That section 6/7 ATA as well as 365-A PPC have bene

misapplied by the police as no weapon was fired but to
aggravate the offence, otherwise no such incident whatsoever
has ever taken place.
28.That case against the applicant accused is of such a nature which

can only be established after leading evidence on record hence at
this stage applicants accused are entitled for cocncession of bail.
29.That story narrated in the FIR by the complainant is unbelievable

and unnatural.
[6]
30.That applicants accused is not prevous convict as per

instruction.
31.That case has been challaned and applicants accused are in jail
hence they are no more required for police for further
investigation purpose.
32.That there is no apprehension of absconsion of the applicant

accused or tampering with the evidence
33.That applicants accused are ready to furnish solvent surety to the

satisfication of this Honourable court.
34.That other grounds will be urged at the time of arguments .
DATED__________ ADVOCATE
FOR APPLICANTS/ACCUSED
CERTIFICATE

application of the applicants/accused, before this Honourable
applicants/ accused before this Honourable court.
Advocate for applicants/accused

B. A. No: OF 2017.

VS

BAIL APPLICATION

-: F A C T S :-

police ammunition, on police Mobile No.
[2]
SP 201, along with driver PC Wajid Memon, under the entry

No. 33/21-7-2017, at about 0530 hours, departed within their
beat for patrolling, various places, when at about 0730 hours,
they reached Sakrand Sarhari road near Hashim Rasti, where
they saw, one person was standing there, who by seeing the
police party tried to run away, the complainant party
suspected, and stopped their vehicle, the complainant party
got down with their staff and very tactfully captured to the
persons, the captured persons were inquired about their name
, residence etc, who disclosed his name to be applicant
accused, the complainant tried to make private Mashir but not
found, due to non availability ,of the private Mashirs PC
Ghulam Rasool and PC Mehboob Ali, were made mashirs, the
police conducted body search of arrested accused, from his
right side of shalwar one pistol recovered which secured by
the complainant party, the pistol was unloaded, which was of
30 bore, containing the magazine in running condition
without licenses, the from the Magazine 3 live bullets were
recovered, which were unloaded, the pistol and magazine and
its bullets, were sealed, further body search was conducted of
the arrested accused from his side pocket of shirt one note Rs.
50 recoovered which was secured by the police, the arrested
[3]

grounds.
-: G R O U N D S :-

applicant/accused and applicant has no concerned with
[4]
the alleged weapon, but complainant just to drag the




52. That it is settle principle law that, if any single doubt
[5]

doubt should goes in favour of the applicant/accused at bail
stage.


APPLICANT/ACCUSED
CERTIFICATE

Gohar Ali Son of Sardar jutt

Muslim, Adult presently confined in District
VS
Crime No: 103 /2017, P.S,Airport

BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant, Insp/SHO

Nadeem Ahmed Chanar, lodged his FIR at police station
Airport, On 13-06-2017 at about 2000 hours, alleging that,
today complainant along with his staff each ASI Tasawar
Hussain Memon, HC Muhammad Nawaz Pathan, PC Ihsan
Ali Siyal, PC Ali Gohar, PC Kareem Bux chandio, with police
ammunition, on govermnet vechile No. SP 4267 along with
driver PC Inayat Hussain, under the entry No, 20 dated 13-06-
2017, at about 1800 hours, departed for patrolling, after
patrolling various places, when complainant party reached at
New Nakka they got spy
[2]
information that, one person namely Gohar Ali Jut , who has
kept chars in his possession, and is coming from Khadhar
towards city, after getting such information complainant
party departed at pointed place, when at about 1900 hours
complainant party reached at Chemi Visco Mill Khadar Road,
they saw one person was coming towards Khadhar who by
seeing the police party tried to run away, complaiant party
led down and very tactfully apprehended him, due to non
availability of private Mashire, ASI Tasawar Hussain, HC
Muhammad Nawaz were made Mashir, the complainant
party also inquired about name and address etc of the
accused, who disclosed his name to applicant accused,
thereafter personal search was conducted, in which 2 big and
one small piece of Chars was recovered, from side pocket of
shirt of the accused complainant party reaceived amount of
Rs. 100/- the chars was secured and weighted, which became
1200 grams, complaiant party sealed the same for chemcail
analysis, and accused was inquired about the recovered Chars
the accused disclosed that he used to sale the chars on money,
thereafter such Mashirnama was prepared with signatures of
the Mashirs, thereafter, arrested accused and above property
were brought at police station, further complainant stated
that, accused was selling chars and has committed under 9/C
CNSA, therefore this FIR has been lodged against him.

before competent court of law, accused was
[3]
brought in judicial custody, hence the applicant accused got

filed present bail application before this Honourable Court
with following ground.
-: G R O U N D S :-
ulterior reasons.

FIR has ever taken place, but complainant by showing his
efficiency just to falsely implicate the applicant in present case
alleged offence.
135. That there is bounden duty of the complainant that as

per contents of the FIR, he during the recovery of such
norcotic substance, should have to investigate about the actual
person dealer of the chars or to investigate that wherefrom
such quantity of chars has been possessed by the applicant
accused but complainant failed to do so and also by foisting
such quantity of chars has made false police case against the
applicant accused which creates highly doubt in prosuection
story.
[4]
136. That in fact no such incident whatsoever, stated in the

staged by the complainant, actual facts are that, due to
political influence, the complainant by managing things with
his staff has roped the applicant accused in this false case.
thickly populated and it is imposible to commit offence or sale
the chars easily or openely, but complainant by showing
wrong place of incident has made this false story very
tacnically.

superior population there is Chemico Visco Mill and so many
house is around the area there is no such type of place to
commit offence easily, but the complainant could not perform
his duty honestly to act for independent witness whereas all
the PWs cited in the FIR are pocket person and staff of the
complainant who at any time under the command of the
complainant can do any act legal or illegal and can adduce
fabricate evidence with regard of the above/case, so it be
indicated that, each and every thing ver tactfully managed by
the complainant and his staff just to drag the applicant
accused in this false case with malafide intention for ulterior
reasons.

[5]

141. That complainant failed to explain, real motives while

he has not shown in what manner, in what condition
applicant accused was coming towards city side, and to
which city he was coming, but complainant party by making
this false story has implicated the applicant accused for the
ulterior reasons.

the complainant.

stage.
145. That no purchaser or further location has been decribed

chars upon the applicant accused with malafide intention for
ultior reasons.

is not involved into such activities but due to
[6]
reason mentioned above and due to high influence of

political person, who hired the complainant and got lodged
this present FIR on false and fabricated assertions.



APPLICANT/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2017.
Ghulam Abbas son of Muhammad Hanif Arain

Muslim Adult presently confined in Distrit
VS

Ahmed
BAIL APPLICATION

-: F A C T S :-

complainant, SIP Hussain Ali lodged his FIR at police station
Kazi Ahmed, On 7-7-2017 at about 0030 hours, alleging
therein that, accused shown in crime No 119/2017 under
section 324, 353, 364, 511, 395, 436, 427, 341, 147, 148,, PPC
337-A (ii), H(ii) Q PS Kazi Ahmed, in the same case
Mashirnama was prepared of
[2]
recovery and arrest of the accused namely Ghulam Abbas son

of Muhammad Hanif Arain, resident Mashakh, Taluka
sakrand, who has kept unlicensed pistol , containing
magazine of 30 bore in running condition in his possession,
has committed offence in the above case/crime, hence this FIR
has been lodged

grounds.
-: G R O U N D S :-

56. That in fact no such incident whatsoever stated in the FIR was
ever took place but the whole drama has been staged by the
complainant, just to show his efficiency otherwise, otherwise
applicant/ accused have no concerned with the alleged offence.
[3]
58. That applicant accused is granted bail in the main case while this
case is connected with main case.
59. That place of incident shown in the main case is thickly
populated area such place is not like to commit offence easily

which is populated area even nothing has been committed but
this whole drama has bene staged by the complainant and his
staff with malafide intention for utlrior reasons..
60. That there are general allegation just to bow down the applicant
otherwise alleged story is made out on false assertions.
61. That it be verified from the facts of this and main case that
nothing has been committed by the accused and it be indicated

that story narrated in the FIR which is made on false assertins
same is stereotyped and concocted one.

[4]
67. That it is settle principle law that if any single doubt arose in

should goes in favour of the applicant accused at bail stage.


APPLICANT/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2017.
Junaid Ali son of Muhammad Bashir Arain

Muslim Adult presently confined in Distrit
VS

Ahmed
BAIL APPLICATION

-: F A C T S :-

complainant, SIP Hussain Ali lodged his FIR at police station
Kazi Ahmed, On 7-7-2017 at about 0015 hours, alleging
therein that, accused shown in crime No 119/2017 under
section 324, 353, 364, 511, 395, 519,
[2]
436, 427, 341, 147, 148 , PPC 337-A (ii), H(ii) Q PS Kazi Ahmed,
in the same case Mashirnama was prepared of recovery and
arrest of the accused namely Junaid Ali son of Muhammad
Bashir Arain resident Mashakh, Taluka sakrand, who has kept
unlicensed pistol , containing magazine of 30 bore in running
condition in his possession, has committed offence in the
above case/crime, hence this FIR has been lodged
grounds.
-: G R O U N D S :-


FIR was ever took place but the whole drama has been staged
by the complainant, just to show his efficiency otherwise,
otherwise applicant/ accused have no concerned with the
alleged offence.
[3]

152. That applicant accused is granted bail in the main case

while this case is connected with main case.
153. That place of incident shown in the main case is thickly

populated area such place is not like to commit offence easily
which is populated area even nothing has been committed
but this whole drama has bene staged by the complainant and
his staff with malafide intention for utlrior reasons..
154. That there are general allegation just to bow down the
applicant otherwise alleged story is made out on false
assertions.
155. That it be verified from the facts of this and main case
that nothing has been committed by the accused and it be
indicated that story narrated in the FIR which is made on
false assertins same is stereotyped and concocted one.
157. That case property as alleged have been foisted upont

he applicant accused, by the complainant just to make this
false case with malafide intention for ulterior reasons.
158. That all the PWs are police officials and are sub ordinate
of the complainant hence they are interested witnesses.
[4]
159. That applicant accused possessed good reputation in the

vicinity and he is not involved into such acitivities but he has
been roped by the police with malafide itnention

doubt should goes in favour of the applicant accused at bail
stage.


arguments.

APPLICANT/ACCUSED
CERTIFICATE


MAGISTRATE –I SAKRAND
B. A. No: OF 2017.
Sikandar son of Gulsher Mangsi

Shaheed Benazirabad …………….…….Applicant/accused
VS

U/S 506/2, 148, 149, 435 PPC .
BAIL APPLICATION

applicant/accused , that this Honorable Court may be to
-: F A C T S :-

complainant, Mst Aziz Bano lodged her FIR at police station
Sakrand, On 4-7-2017 at about 1200 hours, alleging therein
that, there is dispute in between the complainant and
Shahnawaz party on the landed property , who time and
again were threatening that, complainant party are not
hadning over them lands, so they will nto spare to the
complainant and his son Muhammad Aslam, On 29-6-2017,
complainant along with his son Muhammad Aslam Magsi,
Mst Hayat
[2]
Khatoon, wife of late Ali Nawaz Magsi were available at their

house, when at about 2300 hours, at noon time complainant
party saw, outside of the house of the complainant there leafs
of the Banana crop are lying and some are spreaded on the
way of outging, wherefrom flames seemed to the complainant
party the complainant party came out from their house and
saw, Shahnawaz son of Mir Hassan, Gulsher son of Haji
Sahib, Ramzan son of Ghulam Qadir, Sikandar son of Gulsher
Mangsi, and 5/6 unknonw accused persons were standing in
gathering,unknown accused persons have been seen clearly ,
would be identified if seen again, who by setting fire on the
garbeg of Banana crop of the complainant were standing
there, the fire extended to the house and boundary of hedge,
which surrounded to the hedge enricled to the house of the
complainant, on which complainant party inquired from the
accused that what are you doing so thereon on all accused
persons asked the complainant party to vacate the lands
otherwise, complainant party will be killed by them ,
meantime, accused Shahnawaz Mangsi and Gulsher Mangsi
who took out their pistols from their fold of shalwar aimed
upon the complainant and stated that, if the complainant will
not give share from the land, then complainant and his son
will be killed by them, on which complainant party made
cries, on the cries of the complainant party various persons
came out from their houses, thereafter all accused persons by
giving threats of dire consequences run away, thereafter
complainant with help of his villages extinguished the fire,
and narrated whole facts with their gentlemen of the
community, who advised to not proceed any matter,
[3]
and gave assurance to get return the Faisla but today they
refused to give the Fiasla, thereafter gentleman advised to go
and report the matter , hence this FIR has been lodged.
After registration of the FIR, the police of PS Sakrand arrested

the applicant accused, he is in judicial confined, hence this bail
application on the following grounds.
-: G R O U N D S :-

the ulterior reasons, actual facts are that, there is dispute in
between the parties over the landed property, while, civil
litigation is pending before Honourable comptent court of
law, and from the civil comptent court of law also passed
order by bounding the both parties to get partition of the
land, such matter is pending before concerned Mukhtiarkar
for make partition of the land, but complainant being person
of greed type and showing his influence, by adopting illegal
methods, and taking advantage of this false story succeeded
to lodge the FIR against the applicant/ accused and co
accused, just to put pressure upon the applicant/ accused, so
that he and others come in his illegal terms with malafide
intention for the ulterior reasons.
165. That all other applicants accused are admitted on pre

arrest bail by Honourable Assisstant Sesssion judge shaheed
benazirabad therefore applicant is entitled for the same sort
of relief.
[4]

by the complainant, just to rope the applicant/ accused in this
false case .
167. That there is delay in lodging the FIR for about 5 days
168. That no fire has been set on the banana crop and none
from the complainant party seen by seting the fire on the
banana leafs or crop, but complainant just to take undue
advatange has filed this false case with malafide intention.
169. That complainant is supported by influential persons,

therefore he intead adopting due course of law, he by taking
undue advantage has filed this false case against the
applicant/ accused just to humiliate them.
170. That no specific role, part, ovet act assigned to the

applicant accused mere there are general allegation against
the applicant/ accused.
171. That malafide part of the complainant is that, he has no
shown that how much damage cause to the complainant and
which things brunt in that fire, but he by showing false story
cursory succeeded to lodge the FIR against the applicant/
accuse.
172. That there is no eye witess or independent witness of

scene of occurrence but allegation only have bene leveled
against the applicant accused by the complainant by
managing things with his sweet obligor witnesses.
[5]
173. That applicant/accused possessed good reputation in
the vicinity.
174. That there is no mention by the complainant in his alse

story that by whom fire was sat at leafs, or crop or an other
place, so section 435 PPC is not attracting to the present case,
mere there are general allegation .
175. That applicant/ accused is not convicted previously.

stage.

178. That applicant accused is ready to furnish solvent

arguments.

APPLICANT/ACCUSED
CERTIFICATE

application of the applicant/ accused, before this Honourable
applicant/accused before this Honourable court.

Abdul Majeed son of Tahir Bughio

Muslim, Adult presently confined in District
VS
Crime No: 21 /2017, P.S, Ali Abad

BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant, Ali Nawaz

Waghro lodged his FIR at police station Ali Abad on 24-6-2017
at about 1045 hours, alleging therein that, today complainant
along with his staff, C Jamauluddin , C Shamasuddin, C
Muhammad Iqbal, with police ammunition, on private vehicle
departed for patrolling, various places, under entry No. 21, by
patrolling, when they reached at Kareem Abad stop where
complainant got spy information that, one person
[2]
is selling chars at graveyard of Pir Lashkari, the complainant

along with his staff departed towards pointed place, when at
about 0930 hours, complainant party reached at Link Road
Qabool Rahu, Lashkari graveyard, where they saw one person
was standing near tree of Khabar at road side, who by seeing
the police party tried to skip away, the complainant part at
once got down and on the some distance, the police party by
giving hackles, captured him, the complainant party also
inquired about name and address etc from the captured
person, who disclosed his name to applicant accused, due to
non avaialblity o,f the private Mashir, C Jamaluddin, C
Shamasuddin were made Mashirs, the shopper was recovered
from the accused person, and opened the same and checked
the smell in which detailed bellow chars was lying, the chars
was secured and weighted, which became 1050 grams,
thereafter complainant party sealed the same chars for
chemical analysis, the accused was inquired about the
recovered chars, who disclosed that above chars is mine and
accused further disclosed that, he has purchased the same
chars from Khana Badosh used to sale on the money,
thereafter due to recovery of the chars, the above captured
person was arrested in the above case crime, body search was
conducted of the captured accused, from his front side pocket
Rs. 150/- detailed bellow were recovered, thereafter such
Mashirnama was prepared with signatures of the Mashirs,
thereafter, arrested accused and above property were brought
at police station, further complainant stated that, accused was
selling chars and has committed under 9/C CNSA, therefore
this FIR has been lodged against him.
[3]

ground.
-: G R O U N D S :-

ulterior reasons.

alleged offence.
153. That in fact no such incident whatsoever, stated in the
staged by the complainant, actual facts are that, one person
namely Abdul Haq son of Muhammad Bughio who is serving
in Revenue department and is tout of some higher officers,
and is person of define nature and greedy type, he had
collected amount of Rs. 12,00,000/- from the applicant
accused to appoint to give a job in
[4]
revenue department within four months, but after receiving

the amount he could not get appoint to the person of the
applicant accused on job, and also committed fraud, cheat,
and mischieves, with applicant accused ( such PS copy of
agreement is attached herewith), thereafter when the aplicnat
accused reqeusted the Abdul Haq Bughio for retunring his
amount, on which he firstly kept the applicant accused on
false hopes, and then thereafter he by managing things with
present complainant lodged this false FIR against the
applicant accused, otherwise, applicant accused has no
concerned with the alleged offence and whole things have
been made on false assertions just to put pressure upon the
applicant accused and usurp his huge amount with malafide
intention.

the chars easily or openely, but complainant by showing
tacnically.
superior population there are villagers in huge numbers, but
the complainant could not perform his duty honestly to act for
independent witness whereas all the PWs cited in the FIR are
pocket person and staff of the complainant who at any time
under the command of the complainant can do any act legal
or illegal and can adduce fabricate evidence with regard of the
above case
[5]
so it be indicated that, each and every thing ver tactfully

managed by the complainant and his staff just to drag the
applicant accused in this false case with malafide intention for
ulterior reasons.
156. That chars if any as alleged has been sent for chemical
analysis which is delayed.



he has not shown any other person or location of the place or
purchaser, but by making this false story has implicated the
applicant accused for the ulterior reasons.
the complainant.

stage.
162. That complainant has not shown size, shape and
[6]
further description of chars, but only shown chars in the

contents of the FIR, which creating highly doubt in
prosecution story.

mentioned above and due to high influence of Abdul Haq
Bughio who hired the complainant and got lodged this
present FIR on false and fabricated assertions.



APPLICANT/ACCUSED
CERTIFICATE

IN THE COURT OF 2nd ADDITIONAL SESSSIONS

JUDGE SHAHEED BENAZIRABAD
B. A. No: OF 2017.
Shahdad alias Shahzad Khoso ………… Applicant/accused
VS

U/S 302, 114, 148, 149 PPC .
AFFIDAVIT
I, Mst Heer widow of Deceasesd Ali Asgher, Muslim

Adult R/O Village Punhal Khan Chandio, Taluka sakrand,
District shaheed Benazirabad, d,o hereby state on oath as
under:-
1. That I widow of deceased Asgher Ali and one of legal hier

of deceased Asghar Ali in the above case hence fully
conversant with the facts f,o the present case.
2. That I am widow of deceased Ali Asghar I have

categorically stated that deceased Asgher Ali was my
Husbend, and complaiant Ali Akbar, Nasarullah, and
Manzoor Ali are my brothers in law ,and after registration
case No 6 of 2012, against them , at police station Ali Abad,
they fled away towards the unknown place and now I
have no knowledge whereabouts of them, thereafter
brothery faisla was held in between us and applicants
acused, in which present applicants accused persons were
found innocent and their names have been given in the FIR
by police, as applicants accused Shahnawaz Khoso,
Khadim Chandio, Ghulam Rasool alias Takkar KHoso are
innocent and they are not our culprits, therefore I have no
objection if this Honourable court may grant them bail.
3. That I have no grievances, grudge against the applicants

accused who are not our culprits.
4. That I am swearing this affidavit without any pressure and

inducement.
Whatever, stated above is true and correct to the best of

I know the deponent Deponent
Advocate
B. A. No: OF 2017.
Shahdad alias Shahzad Khoso ………… Applicant/accused
VS

U/S 302, 114, 148, 149 PPC .
AFFIDAVIT
I, Murada’n wife of Sulleman Muslim Adult R/O

Village Punhal Khan Chandio, Taluka sakrand, District
shaheed Benazirabad, d,o hereby state on oath as under:-
1. That I am mother of the complainant Akbar Ali and

deceased Asghar Ali and one of legal hier of deceased
Asghar Ali in the above case hence fully conversant with
the facts f,o the present case.
2. That I am wife of Sulleman Khoso that deceased Ali

Asghar was my son and complainant Akabar Ali,
Nasarullah and Manzoor are also my sons, and after
registration case No 6 of 2012, against them , at police
station Ali Abad, they fled away towards the unknown
place and now I have no knowledge whereabouts of them,
thereafter brothery faisla was held in between us and
applicants acused, in which present applicants accused
persons were found innocent and their names have been
given in the FIR by police, as applicants accused
Shahnawaz Khoso, Khadim Chandio, Ghulam Rasool alias
Takkar KHoso are innocent and they are not our culprits,
therefore I have no objection if this Honourable court may
grant them bail.
3. That I have no grievances, grudge against the applicants

accused who are not our culprits.
4. That I am swearing this affidavit without any pressure and

inducement.

Advocate

B. A. No: OF 2017.
Shahdad alias Shahzad Khoso

shaheed Benazirabad …. ……………… Applicant/accused
VS

U/S 302, 114, 148, 149 PPC .
BAIL APPLICATION

-: F A C T S :-

complainant, Akbar Ali son of Muhammad Sulleman lodged
his FIR at police station Sakrand, On 5-11-2011, at about 2030
hours, alleging therein that, there is murderous enmity in
between the complainant and Ghulam Rasool alias Takar son
of Muhammad Saleh
[2]
Khoso, resident of near Dhalo Mori, who time and again were
exending threats that they by taking advantage will kill
brother of the complainant namely Asghar, the complainant
the complainant party have their catles, some time back, the
complainant also purchased the cotton plats and shifted there
near village Mithal sheikh where they were feeding their
cattles, o the day of incident at about 1230 hours, he his
brother Asghar Ali, Nasarullah and Manzoor Ali were sitting
in front of their house when accused came there by three
motorcycles, applicant accused Ghulam Rasool and Ali
Nawaz Khoso were armed with DB Guns and Shah Nawaz
Khoso, Shahzado Khoso and Khadim Chandio were armed
with country made pistols and Deedar was armed with
repeater and that applicant accused Ghulam Rasool told other
accused that they had to take revenge from Asghar Ali so he
will be murdered and no body should come near them and
saying so that, he fired with DB gun at Asghar Ali who raised
cries and fell down and then shahdad, Shah Nawaz and other
accused also fired upon him whereupon they raised cries and
beseeched accused in the name of God, accused then saw that
Asghar Ali had died and they boarded their motorcycles
along with their weapons and went away, then he and his
brothers saw that Asghar Ali had firearm injuries on his chest
and arms and shoulders and had blead and expired, they had
then brought his dead body to Taluka Hopsital sakrand and
after getting the postmortem performed had left the dead
body at their house and had came to lodge the FIR.
After registration of the FIR, co accused Shahnawaz

Khoso, Khadim Chandio and Ghulam Rasool
[3]
alias Takkar Khoso were arrest ed and after usual

investigation, I.O submitted the charge sheet before the
Honourable court having jurisdiction, thereafter, this case was
sent up before Honourable court shaheed Benazirabad and
then transferred to this Honourable court for trail purpose,
thereafter, this Honourable court framged the charge against
the accused persons and issued notices, summons, warrants,
and even publications against the complainant party for their
appearance for their evidence purpose, but complainant party
could not appear before this Honourable court in spite of
many efforts, consequently this Honourable court kept the
case of the applicants accused in dormant file and acquitted
the above named applicant accused Shahnawaz and Khadim
till the appearance of the complainant party, thereafter,
applicant accused namely Shahdad was arrested and after
usual investigation his supplementary challan was submitted
before this Honourable court hence this bail application on the
follwing grounds.
-: G R O U N D S :-

implicated by the complainant due to enmity .
181. That there is inordinate delay in lodging the FIR for

about 8 hours and such delay has not been explained at all
admittedly there is murderous enmity in between the
applicants and complainant party.
[4]
182. That Mst Murada wife of Sulleman Khaso filed affidavit,

which is attached with this bail application in which she has
categorically stated that, deceased Ali Asghar was her son
and complainant Akbar, Nasarullah, and Manzoor are her
sons and after registration of the case No 6 of 2012 against
them, at police station Ali Abad, they fled away towards the
unknown place and now, she has no knowledge whereabouts
of them, thereafter brothery Faisla was held in between the
applicant accused and complainant party, Lrs in which
present applicant accused Shahdad was found innocent and
their names have been given in FIR by police as applicant
accused namely Shahdad Khoso is innocent and he is not
their culpits and he is not culprits therefore she has no
objection if this Honourable court will grant bail to the
applicant accused.
183. That mst Heer wife of the deceased Ali Asghar has also
filed the affidavit which is attached in this bail application in
which she has categorically stated that, deceased Ali Asghar
was her husband and complainant Ali Akbar, Nasarullah and
Manzoor Ali are brother in law of Mst Heer, after registration
of case No. 6 2012 against them at police station Ali Abad
they fled away towards the unknown place and now, she has
no knowledge whereabouts of them, thereafter brothery
Faisla was held in between the applicant accused and
complainant party, Lrs in which present applicant accused
Shahdad was found innocent and their names have been
given in FIR by police as applicant accused namely Shahdad
Khoso is innocent and he is not their culpits and he is not
culprits therefore she has no objection if this Honourable
court will grant bail to the applicant accused.
[5]
184. That complainant Akbar along with PWs Nasarullah,

Manzoor ali and their other brothers committed murder of
Mst Ajeeba, wife of co accused Shahnawaz and injured his
daughter Mst Soni, on 9-4-2012, and such FIR N0. 6/2012 was
registered by Moula Bux son of Shahnawaz at police station
Ali Abad, and complainant party absconded and are not
likely to appear for evidence in this case, which is pending
adjudication from 30-11-2012, and applicant accused is in jail
since his arrest.
185. That allegedly all accused fired from their respective
weapons but police recovered any tow empities of 12 bores
during investigation from the place of incident.
186. That applicant accused is in jail without any progress in

the case.
187. That this Honourable court has granted bail Shahnawaz,

Khadim Ghulam Rasool, therefore applicant accused is
entitled for the same sort of relief on the rule of consistency.
188. That nothing has been recovered during the

investigation.
189. That as this stage the case is required for further inquiry.

evidence as applicant/accused is ready to furnish solvent
[6]

arguments.

APPLICANT/ACCUSED
CERTIFICATE

BENAZIRABAD
A. B. A. No: OF 2017.
1. Shahnawaz son of Mir Hassan Magsi

2. Gulsher son of Haji Sahib Magsi
3. Ramzan son of Ghulam Qadir Magsi
4. Waqar son of Ghulam Qadir Mangsi
all R/O Village Darri Magsi, Taluka Sakrand
District shaheed Benazirabad ……….Applicants/accused
VS

U/S 506/2, 148, 149, 435 PPC .
ANTICIPATORY BAIL APPLICATION


pleased to admit them on pre arrest bail in the above
grounds:-
-: F A C T S :-

complainant, Mst Aziz Bano lodged her FIR at police station
Sakrand, On 4-7-2017 at about 1200 hours, alleging therein
that, there is dispute in between the complainant and
Shahnawaz party on the landed
[2]
property , who time and again were threatening that,

complainant party are not hadning over them lands, so they
will nto spare to the complainant and his son Muhammad
Aslam, On 29-6-2017, complainant along with his son
Muhammad Aslam Magsi, Mst Hayat Khatoon, wife of late
Ali Nawaz Magsi were available at their house, when at about
2300 hours, at noon time complainant party saw, outside of
the house of the complainant there leafs of the Banana crop
are lying and some are spreaded on the way of outging,
wherefrom flames seemed to the complainant party the
complainant party came out from their house and saw,
Shahnawaz son of Mir Hassan, Gulsher son of Haji Sahib,
Ramzan son of Ghulam Qadir, Sikandar son of Gulsher
Mangsi, and 5/6 unknonw accused persons were standing in
gathering,unknown accused persons have been seen clearly ,
would be identified if seen again, who by setting fire on the
garbeg of Banana crop of the complainant were standing
there, the fire extended to the house and boundary of hedge,
which surrounded to the hedge enricled to the house of the
complainant, on which complainant party inquired from the
accused that what are you doing so thereon on all accused
persons asked the complainant party to vacate the lands
otherwise, complainant party will be killed by them ,
meantime, accused Shahnawaz Mangsi and Gulsher Mangsi
who took out their pistols from their fold of shalwar aimed
upon the complainant and stated that, if the complainant will
not give share from the land, then complainant and his son
will be killed by them, on which complainant party made
cries, on the cries of the complainant party various persons
came out
[3]
from their houses, thereafter all accused persons by giving

threats of dire consequences run away, thereafter complainant
with help of his villages extinguished the fire, and narrated
whole facts with their gentlemen of the community, who
advised to not proceed any matter, and gave assurance to get
return the Faisla but today they refused to give the Fiasla,
thereafter gentleman advised to go and report the matter ,
hence this FIR has been lodged.
after registration of the FIR, the police of PS Sakrand started

hunting for the applicants/accused, finding them not there have left
the threats to come again to arrest the applicants accused, hence this
pre arrest bail application on the following grounds.
-: G R O U N D S :-
192. That the applicants/accused are innocent and had

committed no alleged offence, but they have been falsely
the ulterior reasons, actual facts are that, there is dispute in
between the parties over the landed property, while, civil
litigation is pending before Honourable comptent court of
law, and from the civil comptent court of law also passed
order by bounding the both parties to get partition of the
land, such matter is pending before concerned Mukhtiarkar
for make partition of the land, but complainant being person
of greed type and showing his influence, by adopting illegal
methods, and taking advantage of this false story succeeded
to lodge the FIR
[4]
against the applicants accused and co accused, just to put

pressure upon the applicants accused so that they may come in
his illegal terms with malafide intention for the ulterior reasons.

by the complainant, just to rope the applicants accused in this
false case .
194. That there is delay in lodging the FIR for about 5 days
195. That no fire has been set on the banana crop and none
from the complainant party seen by seting the fire on the
banana leafs or crop, but complainant just to take undue
advatange has filed this false case with malafide intention.
196. That complainant is supported by influential persons,

therefore he intead adopting due course of law, he by taking
undue advantage has filed this false case against the
applicants accused just to humiliate them.
197. That no specific role, part, ovet act assigned to the

the applicants accused.
198. That malafide part of the complainant is that, he has no

shown that how much damage cause to the complainant and
which things brunt in that fire, but he by showing false story
cursory succeeded to lodge the FIR against the applicants
accused.
[5]
199. That police is hunting for the applicants accused finding

them not there have left the threats to come again to arrest the
applicants, hence this pre arrest bail application.
200. That there is no eye witess or independent witness of
scene of occurrence but allegation only have bene leveled by
the complainant by managing things with his sweet obligor
witnesses.
201. That applicants/accused possessed good reputation in

the vicinity.
202. That there is no mention by the complainant in his alse

story that by whom fire was sat at leafs, or crop or an other
place, so section 435 PPC is not attracting to the present case,
mere there are general allegation .
203. That applicants/ accused is not convicted previously.

doubt should goes in favour of the applicants accused at bail
stage.

evidence as all the PWs are sweet obligor fo the complainant.
[6]
206. That there is no apprehension of the absconsion of the

applicant accused as they are ready to furnish solvent surety

arguments.
APPLICANTS/ACCUSED
CERTIFICATE
This is to certify that this is first pre arrest bail

application of the applicants/ accused, before this
Honourable court, prior to this no pre arrest is pending on
behalf of the applicants/accused before this Honourable
court.
Advocate for applicants/accused

BENAZIRABAD
A. B. A. No: OF 2017.
Shahnawaz and others …….. …………….Applicants/accused
VS

U/S 506/2, 148, 149, 435 PPC .
.
AFFIDAVIT.
I, Shahnawaz son of Mir Hassan Magsi R/O Dari Magsi

Taluka Sakrand, District shaheed Benazirabad, do hereby
state on oath as under:-
1] That I am the applicant/accused in the above case hence fully

conversant with the facts of the case.
2] That the accompanying application has been drafted under

our instruction the contents of the same are true and correct.
3] That I have committed no offence I have been falsely

implicated by the complainant with malafide intention for the
ulterior reasons otherwise I am innocent.
4] That Police of PS Sakrand is behind me and have raided my


Advocate

BENAZIRABAD
A. B. A. No: OF 2017.
VS

U/S 506/2, 148, 149, 435 PPC .
.
AFFIDAVIT.
I, Waqar son of Ghulam Qadir Mangsi R/O Dari Magsi






Advocate
BENAZIRABAD
A. B. A. No: OF 2017.
VS

U/S 506/2, 148, 149, 435 PPC .
.
AFFIDAVIT.
I, Ramzan son of Ghulam Qadir Magsi R/O Dari Magsi






Advocate
BENAZIRABAD
A. B. A. No: OF 2017.
VS

U/S 506/2, 148, 149, 435 PPC .
.
AFFIDAVIT.
I, Gulsher son of Haji Sahib Magsi R/O Dari Magsi Taluka

Sakrand, District shaheed Benazirabad, do hereby state on
oath as under:-





Advocate
5.
BENAZIRABAD
B. A. No: OF 2017.
Kareem Bux son of Ranjho Khan

by caste Dongh, presently confined in Distrit
VS
Crime No: 12/2017, P.S, Daulatpur

BAIL APPLICATION

-: F A C T S :-

complainant, ASI Mir Muhammad lodged his FIR at police
station Daulatpur, On 24-2-2017, at about 1600 hours, alleging
therein, today complainant along with his staff, HC Altaf
Hussian Memon, C Massat Ali , with police ammunition on
government Mobile No 750 along
[2]
with driver C- Ali Asghar Awan, under the entry No. 10/24-
2-2017 at about 1440 hours, departed for patrolling within
their beat, when complainant party by leading from the
Bahadur Patrol Pump, when at about 1500 hours, they
reached at Village Raza Muhammad Dahri Link Road at
Bachau Band, where complainant party saw one person was
coming from front side, who by seeing the complainant party
in police uniform tried to run away, police suspected and
stopped their vehicle, the complainant along with his staff
very tactfully apprehended the accused persons, the
complainant tried to arrange private Mashir but not found,
the HC Altaf Hussain Memon, PC Massat Ali were made
Mashirs, the accused was inquired about his name and
address, who disclosed his name to be applicant accused,
from his body search, from his left side of shalwar, one pistol
containing the Magazine was recovered, the magazine was
unloaded by the police and same was checked which was 30
bore of the detailed bellow, and in magazine 3 live bullets of
30 bore were recovered, such pistol was in running condition,
the same was secured in the police custody from his further
body search, from his left side pocket of shirt amount Rs.
300/- were recovered, the accused was inquired about pistol
and its license, who disclosed to be unlicensed, the pistol
along with bullets was sealed before the Mashirs with their
signatures, the complainant conducted inquiry against the
accused persons of his criminal record through wireless,
which complainant came to know that, arrested accused is
involved in the case of PS Mithiyani, District N-feroze
[3]
under crime No 60/- 2007 under section 337-F (i), L(ii) PPC,
crime No 75 of 2007 U/S 324, Q , crime No 11/2008 U/S 427,
382, PPC , Crime No. 38/2011 U/S 492, 365 PPC of PS
Mithiyani, in which he is proclaimer and Pos accused, who
has been arrested due to keeping the unlicensed pistol and its
bullets, thereafter Mashirnama was prepared with signature
of the accused persons, thereafter accused alogn with
secured property was brought at police station where present
FIR was lodged.

grounds.
-: G R O U N D S :-


otherwise applicant/ accused have no concerned with the
alleged offence.
210. That the pistol in-question and amount have been

foisted upon the applicant/accused and applicant has no
[4]
concerned with the alleged weapon, but complainant just to drag

the applicant/accused before the competent court of law has
lodged present FIR by leveling allegations otherwise there is no
any substance and substantial record which connect with the
applicant/accused
211. That except the solitary words of the complainant and

his subordinate staffs there is no substances on the record
which connect the applicant/accused with the alleged offence
merely there are general allegation just to bow down the
applicant otherwise alleged story is made out and is
implausibly .
212. That place of incident is thickly populated area near

Bachau Band Link Road, which is thickl populated area there
is huge population and persons are passing from the same
place and huge in number there are villages but complainant
by managing this false story has implicated the applicant
accused.
214. That case property as alleged have been foisted upont

he applicant accused, by the complainant just to make this
false case with malafide intention for ulterior reasons.
216. That applicant accused possessed good reputation in the

vicinity.
[5]
218. That case has been challaned and same is not requires
for the further invesgiation.
219. That previous FIRs shown in the FIR which have been
regstiered against the applicant accused by hiring the
different complainant on the instance of the ruling party and
some influential persons, which are nothing but same have
been registered against the applicant accused just to put
pressure upon the applicant accused.

doubt should goes in favour of the applicant accused at bail
stage.

evidence as all the PWs are police officials.


arguments.

APPLICANT/ACCUSED
[6]
CERTIFICATE

MAGISTRATE –II I D NAWABSHAH
B. A. No: OF 2017.
Rao Muhammad Majeed son of Naimat Ali Rajput Sikandar Ali son
of Muhammad Luqman, Wagan
Muslim, Adult R/O Ward No. 3 Shahi Bazar Duar ,
District shaheed Benazirabad ……......Applicant/accused
VS
Crime No: 55/2017, P.S Daur

U/S 489-F. 504, PPC.
BAIL APPLICATION

applicant/accused , named above, That this Honourable court
grounds:-
-: F A C T S :-

complainant, Waseem Hassan Gorchani is land lord On
dated 18-6-2014, complainant along with Muhammad Afzal
sonof Muhamamd Moosa, brohi and my cousin Khalil Ahmed
son of Barkat Ali were present on his Otaq, then at about 11:00
Am Dr. Sikandar Ali son of Muhammad Luqman Wagan R/O
Ward No 3,
[2]
Shahi Bazar Daur came at Otaq and his Car XLI No 061 ASY,
Model 2009 purcahsed in sum of Rs. 13,50,000/- and given to
complainant, cash amount Rs. 5,50,000/- and took the custody
and of car and documents etc and for remaining amount Rs.
8,00,000/- from his account No 0565496551000691 issued two
cheques each of rs. 400,000/- of MCB branch Daur, vide
cheque No 1505292718, dated 15-2-2016, and second cheque
No,1505292718 respectively, on the mentioned date
complainant approached to the concerned bank for
encashment of the cheque where bank authority has told to
the complainant that, there is no money in the account of
Sikandar, that on 6-4-2016, the complainant again went to the
said bank for said purpose but bank issued memo with the
reason that there is no money in the said account, thereafter,
complainant party approached to the Dr, Sikandar Ali Wagan
and they asked for some time which complainant has given
him and complainant time and again approach for money but
Dr. Sikandar kept him on false hopes and promises, on 10-4-
2017 used harsh words with complainant and bluntly refused
to return his amount, on that complainant has filed applicant
before the session court SBA, and obtained order vide order
No 2955 dated 21-4-2017 and lodged this FIR.
After registration of the FIR, police arrested the

applicant accused, A bail application was filed by the
applicant accused through his council which was dimsised on
merit, hence compromise is made in between the applicant
accused and complainant hence this 2nd bail application the
baiss of compromise on the following grounds .
[3]
-: G R O U N D S :-

225. That there is delay in lodging the FIR more then 1 year
226. That applicant accused has fulfilled his words and paid
whole remaining amount Rs. 800,000/- to the complianant in
year of 2015, in presence of the witnesses namely Muhammad
Khan and Dr. Jawaid Khan and there is no any outstanding
amount against the applicant accused.
227. That compromise has been made in between the

applicant accused and complainant of this case, now
complainant has resolved his grievances, while things have
been settled by the complainant and applicant accused out
side of the court, since grudge and hindrance of the
complainant have been resolved with the applicant accused,
and they have no more altercation therefore, com,plianant is
ready to swear his no objection affdaivit before this
Honourable court.
228. That nothing has been committed as alleged.
229. That section 489 PPC is not fallen within the prohibitory
caluse of section 504 PPC is bailable.
[4]
230. That applicant accused is respectable person and he has
possessed good reputation in his vicinity.
231. That the applicant accused is ready to furnish solvent

surety to satisfication of this Honourable court.

arguments.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is 2 nd bail application

on behalf of the applicant/accused, first was dismissed on
merit, prior to this no any bail or other case has been filed by
the applicant accused before this Honourable Court or other
competent court of law .
ZULFIQAR ALI DAHRI

BENAZIRABAD
B. A. No: OF 2017.
1. Ali Sher Rind son of Muhammad Khan

2. Dildar son of Ali Sher Rind
shaheed Benazirabad ……….………….Applicants/accused
VS
Crime No. 203/2017 , PS A section

Nawabshah U/S 365-B , 363, 506/2 PPC.
BAIL APPLICATION

-: F A C T S :-

complainant, Abdul Ghafar lodged his FIR at police station A
section Nawabshah, On 21-6-2015, at about 1500 hours,
alleging therein that, he along with his family and sisters is
residing at above mentioned address, namely Mst uzman
aged about 17/18 years, is in five number sister of the
complainant, On 17-6-2017, complainant along with his
brother Abdul Jabbar Magsi and cousin Ghulam Akbar son of
Ali Bux Magsi were available at their house, when at about
3:30Am, door of the house knocked, the complainant went
and opened the door, he saw, 4 persons, out of which, three
have been identified by the complainant each to be,
Muhammad Ali, Dildar, Ali Sher, R/O Fakeer Muhammad
Garden, near Sugar Mill Nawabshah, and one unknown
accused person was available with them, who have been seen
clearly and would be identified if seen again, Muhammad Ali,
took out his pistol from his folder of shalwar and asked to
remain silent, the complainant party remain silent due to fear
of the weapons, thereafter, all accused persons took his sister
namely Uzma, and neice namely Salma daughter of Abdul
Jabbar Magsi aged about 3 years, and by boarding them in
one silver Colour 2-D Car went away towards society side,
due to harassment, complainant could not note number of the
car, thereafter, Muhammad Ali was threatening the
complainant that, he will consummate marriage with uzma
and complainant party may not chase behind them, else, they
will give harm to the child Salama, thereafter, complainant
remain under depression and now he came and complained
that, accused Muhammad Ali Rind along with his brother and
with one unknown accused came and abduct away niece and
sister of the complainant with intention to consummate
marriage with sister of the complainant forcibly , hence this
FIR.
After registration of the FIR, the applicants/accused was

arrested, who are in judicial custody hence this bail
application on the following grounds
-: G R O U N D S :-

committed no alleged offence, but they have been falsely
234. That On 19-6-2017, Mst uzma shown as abductee, she

with her free will and wishes has consummated marriage
with co accused Muhammad Ali, by leaving house of her
parents in three plain cloths, so due to that marriage,
complainant, just to take put pressure upon the applicants
and co accused started threatening the applicants and co
accused, that, applicants and co accused will be implicated in
false cases, so complainant by showing incident On 17-6-2017,
succeeded to lodge the FIR against the applicans accused and
co accused, otherwise nothing has been committed but this
whole drama has been staged by the complainant.
235. That Mst Uzma in her statement of free will affidavit

clearly stated that, neither she has been abducted away nor
enticed, nor induced, nor secreatly confined, nor coeccired or
pressurized and harassed by any body, but she
consummated marriage with co accused Muhammad ali with
her free will, wishes being youn grown up lady she by
keeping thought of good and evil surprisingly by keeping her
fundamental right has consummated marriage with co
accused Muhamamd Ali, which is legal and valid marriage as
per injunction of Islam, so it be indicated and verified that,
nothing has been committed but whole drama has been
engineered by the complainant just to destroy life of the
applicants/accused and co accused Muhammad Ali and his
wife.
236. That thereafter due to danger, apprehension and cruel

attitude of the complainant and his other supporters, the
Muhammad Ali and Mst Uzma also filed constitution petition
No. S.1090 of 2017 before Honourable High Court Sindh
CIrucit Bench Hyderabad, for legal protection against the
highhandedness of the complainant, thereon such order
passed on 23-6-2017 for legal protection to the applicants
against the high handedness of the complainant party, so it
be verified that, nothing has been committed but this whole
drama has been staged by the complainant and his PWs.
237. That there is delay in lodging the FIR for about 4 days,
238. That place of incident is thickly populated area but none

from adjacent person have been shown or acted to be mashir
of the case and none from adjacent persons have been seen
such occurrence so it be indicated that nothing has been
committed but complainant very tactfully has managed this
story.
239. That
240. due to pressure, harass, of the applicant accused

Muhammad Ali the case property and currency notes have
been foisted upon the applicant/accused.
241. That nothing was recovered from the exclusive

possession of the applicant accused and alleged property has
been clearly foisted upon the applicant accused.
242. That as per the facts of the FIR police got the spy
information about manufacturing the raw liquid in the house
but no any single material of preparing the raw Katcha wine
has been recovered by the police from the house, but
complainant being police officer and for the ulterior motives
by engineering false story has implicated the applicant
accused, otherwise, applicant is not involved into such
activities.
[4]
243. That malafide part of the complainant is that, police has

not given any plausible explanantion and failed to associate
private Mushir and could not corroborate version of the FIR,
even place of the incident as alleged is very populated area
where huge number of the houses and villages are situated,
and there is no such place to prepare the Katcha wine and
sale easily, but complainant by managing this false story has
implicated the aplicant accused in this false case with
malafide intention.
244. That there is voialtion of section 103 Cr, PC.
245. That as per order of the learned judged it be verified

that, case is like the stereotyped as per story narrated in the
FIR it be verified that, prosecution side could not prove their
case and by the prosuection side there is no cogent version or
testimony, substantiation, leading evidence, proof, or
substance against the applicant accused but, due to quotation
of another incident the right of the granting the bail to the
applicant accused can nto be prejudiced, so as per settled
priniciple law it be verified that, if the single doubt arising or
arose in the prosecution story, then each benefit of doubt
which should goes in favour of the applicant accused at bail
stage.
246. That malafide part of the complainant is that, he has

stated that, applicant accused was preparing Katcha wine in
his house, but no such type of material of preparing the
Katcha wine has been recovered, besides no any other person
in helping of the applicant accused has been seen and nothing
has been described plausibily by the complainant or his PWs,
but complainant being police
[5]
official who by showing his effeiciny very tactfully and sharply

succeeded to make a false story and implicated this innocent
person by foisting the Katcha wine.
247. That how it can be possible that, this Honourable court

should apply judicial mind that, except Litters of Katcha wine
nothing else has been recovered or described plausibly and
no purchaser, buyer or other person has been seen or shown,
by the complainant, this far it be verified that, complainant is
master mind of preparing false stories and also implicated the
applicant accused just to put pressure upon him with
malafide intention for the ulterior reasons.

249. That definition of article 3 PEHO, which was applied in

the FIR is in respect of transporation and selling of intoxcants
in which there must be buyer and seller and currency notes, it
is admitted in the FIR that neither at the time of incident any
buyer was present nor any such sale and prucase dealt of
intoxication nor seen by the police, as mentioned in the FIR,
which doesn’t cover the main ingredient of article 3 more
over neither any manufacturing material was recovered at the
pointed place neither police stated in the FIR that there is any
Bathi they saw, so how it can be possible that, such quinitty of
the Katcha wine has been recovered as alleged, so nothing
has been recovered but complainant by showing false
incident implicated the aplciant accused, moreover,
[6]
article 4 which comes within the ambit of bailable caluse

therefore the applicant accused is entitled for the concession of
the bail.
251. That the witnesses of the FIR are setup and subordinates
to the complainant, as such their evidence requires, scrutiny,
because whole investigation is conducted by person who
himself a complainant in the above case thereore the veracity
of the investigation is also created doubt, which can be
determined at the time of trail and at this stage the case of the
applicant accused required further inquiry.
252. That police did not specified in the FIR, that how many
litters of raw liquid were recovered from the
applicant/accused.
253. That chemical report is still awaited.
254. That police arrested him under the article 38 of Qanoon-

e- Shahdat confession to police is not admissible.

256. That ultimate convection and incarceration of guilty a
person can repair the wrong cause by a mistaken relief of
interim bail granted to him.
[7]
257. That basic idea to enable that accused to answer the

criminal prosecution against him, Rather that to rot him
behind tha bar , accused is also entitled to expenditures access
to justice which included a right to fair and expenditures trail.


arguments.

APPLICANT/ACCUSED
CERTIFICATE

applicant accused.

IN THE COURT OF CIVIL JUDGE AND JUDICAL
MAGISTRATE –I DAUR
B. A. No: OF 2017.
Hakim Son of Sahib Dino

Mughal, presently confined in P.S Daur
District Shaheed Benazirabad……………….Applicant/accused
VS
Crime No. 70/2017, P.S Daur U/S

3/4 , PEHO 1979..
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Pir Bux lodged his FIR at police station
Duar, On 17-6-2017, alleging therein that, he along with his
Subordinate staff, police ammunition, under the entry No. 11
at about 1400 hours departed for patrolling, during patrolling,
complainant party reached at Amir Ji River got a spy
information that a person Hakim son of Sahib Dino Machi
R/O Pharsi
[2]
Taluka Daur, Making a Raw Liquid on Bathi, on such

information, complainant party reached at the pointed place,
at about 1530 hours, and found that a person being stood in
his house and he saw the complainant party endeavor to
decamp from over there, complainant party tactfully encircled
the applicant accused and arrested him, due to non
availability of the private Mashir, made as Mashir PC Ghulam
Hyder and PC Abdul Jabar and inquired about the name of
the accused, who disclosed his name to be applicant/accused,
R/O Pharsi Goth and on searching the house complainant
party found a blue colour Plastic Box of 60th Litters 2.15th
Litters plastic box 3, white colour plastic Box of the ten Litters,
on open it, it is found that, there is a Desi Sharab in it, and
after taking the sample from each box in a litter plastic box
sealed, and sent them for the purpose of chemical
examination and other was sealed at the spot and from his
body search, complainant party recovered Rs. 250/- and also a
motor bike was available beside him, which is also kept in
custody, under section 51 and 550 (description of the bike
mentioned in the FIR) and about that applicant/accused
disclosed that such raw Liquid manufactured by him and
same was sold and he has no any documents of the bike, after
that sealed the recovered property and also made a
Mashirnama of recovery in the presence of the above
mentioned Mashir and after that brought the case property
and applicant at police station and lodged the present FIR,
hence this bail application on the following grounds.
[3]

arrested, A bail application was filed before Civil Judge &
Judicial Magistrate-I Daur which was dismissed On 23-6-2017,
due to reason showing that an incident occurred in Tando
Muhammad Khan town where more then 80 persons have lost
their livs while using Katcha wine, so on this stage, bail
application of the applicant accused dismissed hence this
fresh bail application on following grounds.
-: G R O U N D S :-

261. That the case property and currency notes have been

activities.
[4]

malafide intention.

stage.

[5]




[6]

the bail.
applicant/accused.


[7]



arguments.

APPLICANT/ACCUSED
CERTIFICATE

applicant accused.

BENAZIRABAD
B. A. No: OF 2017.
Hakim Son of Sahib Dino

Mughal, presently confined in P.S Daur
District Shaheed Benazirabad……………….Applicant/accused
VS
Crime No. 70/2017, P.S Daur U/S

3/4 , PEHO 1979..
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Pir Bux lodged his FIR at police station
Duar, On 17-6-2017, alleging therein that, he along with his
Subordinate staff, police ammunition, under the entry No. 11
at about 1400 hours departed for patrolling, during patrolling,
complainant party reached at Amir Ji River got a spy
information that a person Hakim son of Sahib Dino Machi
R/O Pharsi
[2]
Taluka Daur, Making a Raw Liquid on Bathi, on such

information, complainant party reached at the pointed place,
at about 1530 hours, and found that a person being stood in
his house and he saw the complainant party endeavor to
decamp from over there, complainant party tactfully encircled
the applicant accused and arrested him, due to non
availability of the private Mashir, made as Mashir PC Ghulam
Hyder and PC Abdul Jabar and inquired about the name of
the accused, who disclosed his name to be applicant/accused,
R/O Pharsi Goth and on searching the house complainant
party found a blue colour Plastic Box of 60th Litters 2.15th
Litters plastic box 3, white colour plastic Box of the ten Litters,
on open it, it is found that, there is a Desi Sharab in it, and
after taking the sample from each box in a litter plastic box
sealed, and sent them for the purpose of chemical
examination and other was sealed at the spot and from his
body search, complainant party recovered Rs. 250/- and also a
motor bike was available beside him, which is also kept in
custody, under section 51 and 550 (description of the bike
mentioned in the FIR) and about that applicant/accused
disclosed that such raw Liquid manufactured by him and
same was sold and he has no any documents of the bike, after
that sealed the recovered property and also made a
Mashirnama of recovery in the presence of the above
mentioned Mashir and after that brought the case property
and applicant at police station and lodged the present FIR,
[3]

arrested, A bail application was filed before Civil Judge &
Judicial Magistrate-I Daur which was dismissed On 23-6-2017,
due to reason showing that an incident occurred in Tando
Muhammad Khan town where more then 80 persons have lost
their livs while using Katcha wine, so on this stage, bail
application of the applicant accused dismissed hence this
fresh bail application on following grounds.
-: G R O U N D S :-

282. That the case property and currency notes have been

activities.
[4]

malafide intention.

stage.

[5]




[6]

the bail.
applicant/accused.


[7]



arguments.

APPLICANT/ACCUSED
CERTIFICATE

applicant accused.

IN THE COURT OF CIVIL JUDGE AND JM-I
NAWABSHAH
B. A. No: OF 2017.
Muhammad Aslam son of Shuhabuddin

Mughal, presently confined in Police Lock up
at 60th Mile Taluka Daur, Ddistrict
Ahaheed Benazirabad ……………………….Applicant/accused
VS
Crime No. 55/2017, P.S 60th Mile U/S

3/4 , PEHO .
BAIL APPLICATION

-: F A C T S :-

complainant, SIP Rafique Ahmed Rind lodged his FIR at
police station 60th Mile, On 24-6-2017, at about 1630 hours,
alleging therein that, he along with his staff, Each Noor
Ahmed, PC Raheel Ahmed, with polie ammunition on police
mobile No. 173, along with driver PC Muhammad Rajper,
under the entry No. 10 departed
[2]
for patrolling, during patrolling, complainant party came to

know, that, one person on the Link raod Nawabshah near Sim
Nala at the Musafur Khana, where selliong the Katcha wine
on the money, the complainant after getting such information
departed towards pointed place when at about 1540 hours,
they reached at pointed place, where complainant party saw
one perso was standing there, containing one black coloured
Plastic shopper, detailed bellow, who by seeing the police
party in uniform, tried to skip away, the police party at once
stopped their vehicle, dismounted from it, encircled and very
tactfully apprehended him along with shopper,, the police
inquired about his name, who disclosed his name to be
applicant accused, resident village Syed Gul shah, Deh 45
Dad, Taluka Daur,, the complainant tried to make private
Mashir but not found, so PC Noor Ahmed and Roheel Ahmed
were made Mashirs, the complainant party opened the Plastic
shopper and saw in which 4 shoppers of Katcha wine were
recovered,, the police inquired about the Katcha wine, on
which he disclosed that, he used to sale on the money, the
police arrested him,and conducted body search, and
recovered amount of Rs. 500/- detailed bellow, the police
party separated one shopper of Katcha wine for chemical
analysis and 3 shoppers were sealed separately as a police
property, the Mashirnama was prepared before mashirs, the
recovered property and accused brought at police station and
where accused was shown under section 3,/4 Munshiyat,
hence this FIR was lodged.
arrested, hence this bail
[3]
application was filed by the applicant accused on the

following grounds.
-: G R O U N D S :-

303. That the case property has been foisted upon the
applicant/accused.
304. that alleged Katcha wine and amount etc have been
foisted upon the applicant accused, otherwise he has no
concerned with the alleged incident.
305. That place of incident has been shown Nawabshah link

raod near Sim Nala at Musafar Khana, which is highly and
thickly populated area and surrounding the same area there
is highly persons and villages, so it is impossible to commit
offence easily or selling the katcha easily and accused was
standing there, but complainant by managing this false story
implicated the applicant accused and besides failed to
associate private Mashir and by making consultation with his
sweet obligor witnesses has implicated the applicant accused
in this false case .
306. That section 3 is bailable and section 4 is not applicable

to the present case which is not attracting to the present case.
[4]
307. That complainant has been hired by ruling party to

implicate the applicant accused in this false ccase.
308. That Katcha wine etc has been clearly foisted upont eh
applicant accused just to make this false case.
309. That malafide part of the complainant is that, he has not

shown weight, and further detail of the Katcha wine but only
by showing four shoppers has implicated the applicant
310. That applicant accused is innocent and he is not indulge

into such activities but complainant by showing this false
incident has implicated the applicant accused with malafide
311. That nothing has been recovered from the applicant

accused, but all alleged recovery shown by the complainant
which has been foisted upon him with malafide intention for
ulterior reasons.
312. That complainant by making stereotyped story has

implicated the applicant accused, otherwise complainant or
his staff has not shown any purchaser or further location but
by foisting Katcha wine has implicated the applicant accused .
313. That the applicant not hardened nor criminal nor

convict previously.
prohibitory clause of section 497, Cr, PC.
[5]
315. That case registered against the applicant accused is

unbelievable and implausible which is false and stereotyped.


arguments.

APPLICANT/ACCUSED
CERTIFICATE

other case has been filed by the applicant accused before this
Honourable Court or other competent court of law .

IN THE COURT OF CIVIL JUDGE AND JM-III
NAWABSHAH
B. A. No: OF 2017.
Ghulam Nabi son of Noor Muhammad

Malak, presently confined in district
Jail shaheed Benazirabad ………………….Applicant/accused
VS

Crime No. 206/2017, P.S A section
Nawabshah
OFFENCE U/S 3/4 , PEHO .
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Niaz Muhamamd lodged his FIR at police
station A section Nawabshah On 22-6-2017 at about 1345
hours, alleging therein that today complainant along with PC
Souz Ali, PC Anwar Ali departed with police ammunition on
police Mobile No 2, along with driver PC Shoukat Ali , under
entry No 10 /22-6-2017, at about 1045 hours, within their beat,
[2]
various places, when at about 12:30 hours, they reached Musli

Phatak railway line, they saw one person was standing in his
front, two white colour gallon were lying, of 12 /12 litters,
who by seeing the police tried to run away, by taking gallon,
the complainant party got down from mobile, very tactfully
apprehended them, including the gallons, the private Mashir
could not found, so PC Souz Ali, PC Anwar Ali made Mashirs
of the case, the arrested accused was inquired about his name
and address, who disclosed his name to be applicant accused,
from secured gallons, which were opened same were filled
with Katcha wine out of which 1/1 litters each has been
seprated for sample purpose and other 11/11/ litters from
both gallons were sealed separately, from his body search,
amount Rs. 90 detailed bellow were secured by police, about
the Katcha wine, accused disclosed that he used to sale on
money, therefore he has been arrested in the above case crime,
the accused and property brought at police station where
present FIR was lodged hence this FIR.
After registration of the FIR, the applicant accused was

arrested, hence this bail application was filed by the applicant
accused on the following grounds.
-: G R O U N D S :-

[3]
applicant/accused.
320. that alleged Katcha wine and amount etc have been
foisted upon the applicant accused, otherwise he has no
concerned with the alleged incident.
321. That place of incident is Musli Phatak Line Par

Nawabshah , which is highly and thickly populated area and
surrounding the same area there is highly persons and city is
encircled, and which is near the PS B section Nawabshah, it is
impossible to commit offence easily or selling the katcha
easily and accused was standing there, but by managing this
false story implicated the applicant accused and besides failed
to associate private Mashir and by making consultation with
his sweet obligor witnesses has implicated the applicant
accused in this false case .



intention.
[4]

ulterior reasons.
327. That complainant on hearsay implicated the applicant

accused, otherwise complainant or his staff has not shown
any purchaser or further location but by foisting Katcha wine
has implicated the applicant accused .

convict previously.



arguments.

APPLICANT/ACCUSED
[5]
CERTIFICATE


B. A. No: OF 2017.
Sikandar Ali ……………………. ……......Applicant/accused
VS

U/S 489-F. 504, PPC.
NO OBJECTION AFFIDAVIT
I, Waseem Hassan son of Muhammad Hussain Gorchani

Muslim, Adult R/O Village Haji Allah Dito Gorchani Taluka
Daur , District shaheed benazirabad, do hereb state on oath as
under:-
1. That I am complainant in the above case, hence fully

2. That after registration of FIR, now I have resolved my

greviences with the applicant accused named above on the
intervention of the our neckmard of the locality on Holy
Quran, our compromise has been made, so I have no more
grudge hindrance against the accused.
3. That since I have no more grudge hindrance against the

accused.
4. That I have obtained my remaining amount from the

aplciant accused and compromise is made.
5. That i have no objection if this Honourable court will

release or acquit applicant accused in the above case
/crime.
6. That I am swearing this affidavit without any pressure
inducement.
Whatever stated above is true and correct to the best of my

knowledge nad belief .
Advocate
2nd bail application

B. A. No: OF 2017.
Sikandar Ali son of Muhammad Luqman, Wagan
Muslim, Adult R/O Ward No. 3 Shahi Bazar Duar ,
District shaheed Benazirabad ……......Applicant/accused
VS

U/S 489-F. 504, PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

complainant, Waseem Hassan Gorchani is land lord On
dated 18-6-2014, complainant along with Muhammad Afzal
sonof Muhamamd Moosa, brohi and my cousin Khalil Ahmed
son of Barkat Ali were present on his Otaq, then at about 11:00
Am Dr. Sikandar Ali son of Muhammad Luqman Wagan R/O
Ward No 3,
[2]
Shahi Bazar Daur came at Otaq and his Car XLI No 061 ASY,
Model 2009 purcahsed in sum of Rs. 13,50,000/- and given to
complainant, cash amount Rs. 5,50,000/- and took the custody
and of car and documents etc and for remaining amount Rs.
8,00,000/- from his account No 0565496551000691 issued two
cheques each of rs. 400,000/- of MCB branch Daur, vide
cheque No 1505292718, dated 15-2-2016, and second cheque
No,1505292718 respectively, on the mentioned date
complainant approached to the concerned bank for
encashment of the cheque where bank authority has told to
the complainant that, there is no money in the account of
Sikandar, that on 6-4-2016, the complainant again went to the
said bank for said purpose but bank issued memo with the
reason that there is no money in the said account, thereafter,
complainant party approached to the Dr, Sikandar Ali Wagan
and they asked for some time which complainant has given
him and complainant time and again approach for money but
Dr. Sikandar kept him on false hopes and promises, on 10-4-
2017 used harsh words with complainant and bluntly refused
to return his amount, on that complainant has filed applicant
before the session court SBA, and obtained order vide order
No 2955 dated 21-4-2017 and lodged this FIR.
After registration of the FIR, police arrested the

applicant accused, A bail application was filed by the
applicant accused through his council which was dimsised on
merit, hence compromise is made in between the applicant
accused and complainant hence this 2nd bail application the
baiss of compromise on the following grounds .
[3]
-: G R O U N D S :-

334. That there is delay in lodging the FIR more then 1 year
335. That applicant accused has fulfilled his words and paid
whole remaining amount Rs. 800,000/- to the complianant in
year of 2015, in presence of the witnesses namely Muhammad
Khan and Dr. Jawaid Khan and there is no any outstanding
amount against the applicant accused.
336. That compromise has been made in between the

applicant accused and complainant of this case, now
complainant has resolved his grievances, while things have
been settled by the complainant and applicant accused out
side of the court, since grudge and hindrance of the
complainant have been resolved with the applicant accused,
and they have no more altercation therefore, com,plianant is
ready to swear his no objection affdaivit before this
Honourable court.
337. That nothing has been committed as alleged.
338. That section 489 PPC is not fallen within the prohibitory
caluse of section 504 PPC is bailable.
[4]
339. That applicant accused is respectable person and he has

possessed good reputation in his vicinity.


arguments.
APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is 2 nd bail application

on behalf of the applicant/accused, first was dismissed on
merit, prior to this no any bail or other case has been filed by
the applicant accused before this Honourable Court or other
competent court of law .
ZULFIQAR ALI DAHRI

IN THE COURT OF 3RD ADDITIONAL SESSSION JUDGE
SHAHEED BENAZIRABAD
B. A. No: OF 2017.
Nazir son of Faiz Muhammad Brohi

R/O Line Par Nawabshah, district
shaheed Benazirabad
confined in District Jail shaheed
Benazirabad ………. .. ….…………....Applicant/accused
VS
Crime No: 203/2011, P.S A section

Nawabshah
U/S 393, 353, 399 427 , 402, 324, 148,
149 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-

complainant, Raja Naveed lodged his FIR at police station A
sectiomn Nawabshah On 6-11-2011 at about 2200 hours,
alleging therein that, today he along with his staff, ASI
Muhammad Azam Bhangwar, PC
[2]
Muhammad Khalid, PC Ali Akbar with police ammunition,

on poklice mobile No SP 6305 along with driver HC Abdul
Rashreed, departed under entry No 28 dated 6-11-2011, at
about 2000 hours, within their beat various places, when they
reached at society new Nakka, by patrolling there, when at
about 21 hours, they reached at govemrent gowdown, where
complainant party saw on the light of the vehicle, the five
persons with intention to commit robbery were standing at
road having pistols in their hands, who by sending private
vehicle to the mobile of the complianant gave signal to rob
them, the police party stopped their vehicle and identified
each to be Nazeer, Karam alias Kami, Ghulam Rasool,
Kaleemullah and one unknown accused person, who has been
seen on the light of the mobile and would be identified if
seena gain one motorcycle was parking in their side, the
complainant party got down from their vehicle, tried to arrest
them by informing them about police, the accused persons
who dettered the complainant party and with intention to
commit their murder made straight firing, the complainant
took shelter and fires hit to the police mobile the complainant
party in their defense made firing in air, thereafter, all accused
by making fires and taking advantage of darkness run away
towards the jungle side the motorcycle was parked there,
which was without number, engine No 33357591 cahssis No
350923 Model 2009 , black Colony of Unique company, which
was suspected and proceed under Karvai of 550 Cr PC, the
complainant party saw the police mobile, three whole were
hit on body of the police mobile, the
[3]
complainant party made such Mashirnama on the light of the

police mobile, ASI Azam Bhangwar, C Muhammad Khalid
such information was given to the higher officers thereafter
recovered property was brought at police station and this FIR
was lodged againt the accused persons.
After registration of the FIR, the police started hunting

for the applicant accused therefore, A pre arrest bail
application was filed by the applicant accused but honourable
3rd Additional session judge put the applicant under custody,
hence this fresh bail application on the following grounds .
-: G R O U N D S :-


accused and applicant accused has no concerned with the
alleged story but complainant by managing things has lodged
the above FIR just to put pressure upon the applicant
accused.
344. That all the co accused are acquitted from the above case
crime by Honourable court of 3rd Additional session judge
shaheed Benazirabad, therefore applicant is entitle for the
same sort of relief.
[4]
345. That in fact applicant was unaware about such

lodgment of FIR but when police started hunting him then he
came to know about such lodgment of FIR.
346. That nothing ahs been recovered from the applicant

accused and there are general allegation against the applicant
accused .
347. That ineffective firing has been shown by the

complainant which is not attributable with the applicant
accused.
348. That no specific role, part injury or overt act assigned to

the applicant accused mere there are general allegation
against the applicant accused just to show false implication of
the applicant accused so that he may come in their terms.
349. That section 324 PPC is not attracting to the present

case.
350. That place of incident has been shown Sarkari gowdown

which is populated area there is no such place to commit
offence after committing run away easily but police very
tactfully made above story just to implicate the applicant
accused.
352. That nothing has been committed but this whole drama
has been staged by the complainant with malafide intention.
[5]
353. That applicant accused is not previously hardened or

criminal he is not desperate as per instruction.
354. That all the story narrated in the FIR is unbleiveable and
implausible, which is based on false assertions but
complainant by showing his malafide part has implicated the
applicant accused in this false case.
355. That as per contents of the FIR it be indicated that eah

and every thing has bene managed by the complainant.
356. That there is no apprehension of tampering with the

evidence, the applicant accused is ready to furnish solvent

arguments.

APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF 3RD ADDITIONAL SESSSION JUDGE
SHAHEED BENAZIRABAD
B. A. in S C No: 513 OF 2014.
The State
VS
Noor Din and others
Crime No. 09/2014, P.S Gupchani

OFFENCE U/S 324, 353, 399, 402, PPC
BAIL APPLICATION

applicant/accused , Abbas alias Ghulam Abbas son of
Ghulam Ali confined in District Jail shaheed Benazirabad,
That this Honourable court may be pleased to release him, on
bail in the above case/crime on the consideration of the
-: F A C T S :-

complainant, ASI Fakeer Muhammad Khokhar lodged his FIR
at police station Gupchani, On 25-2-2014, at about 06-30 hours,
alleging therein that, today complainant along with his staff,
each C Madad Ali Brohi, C Riaz Ali Brohi, C Ghulam Rasool
Brohi, PC Ashique Hussain Khaskheli, PC Zafar Ali Khokhar,
with
[2]
police ammunition, on govemrent vehicle SP 7446, along with

driver PC Shahid Hussain Khokhar, under the entry No.
27/25-2-2014 at about, 0215 hours, departed from police
within their beat, various places, when they reached at Ali
Abad Stop, where they got spy information that, in crime No.
5 of 2013, under section 392 PPC, of PS Gupchani, absconding
accused Abdul Malak son of Pir Bux and another were
standing at Gupchani Road leads to shahdadpur near
Khatiyani with intention to commt robbery, the complainant
party after getting such information he along with his staff
departed towards pointed place, when at about 5:30 hours,
they reached at pointed place, where, complainant party saw
on the light ,of the mobile and identified each Abdul Malik
son of Pir Bux having pistol in his hand, Abdul Aziz alias
Mulla having pistol in his hand, Noor Din having revolver,
Ghulam Nabi alias Porho having pistol in his hand, Imdad Ali
having Desi Pistol, Ghulam Abbas having repeater, Hassan
Having revolver, they were standing at road with intention to
commit offence, who sensed the private vehicle to the vehicle
of the .police mobile, and gave signal to stop the same, the
police party stopped the same, complainant along with his
staff dismounted from it and enricled the accused by
informing him about police, who by hearing the police, made
straight fire upon the police with intention to commit murder,
the police in their defense made firing, such firing continued
for about 9 minutes, thereafter, all accused persons by taking
advantage of darkness run away towards the jungle side,
there was not path to cross the police mobile, the police party
could not went behind them, thereafter police party
[3]
returned back at police station, and stated that Abdul Malik
Siyal, Noor Din, Ghulam Nabi alias Porho, Imdad Ali,
Ghulam Abbas, Abdul Aziz alias Mulla, Hassan, who with
intention to commit offence were standing at road, made
straight firing upon the police and dettered them from
performing their duty hence this FIR lodged, the complainant
made fire of 20 bullets from his SMG, and other staff will give
their detail in their stamtent hence this FIR.

was filed by the applicant accused on the following grounds.
-: G R O U N D S :-


staged by the complainant with malafide intention , actual
facts are that, complainant has been hired by the ruling party
and then, this false story has been engineered by the
complainant just to implicate the applicant accused and
others in this case.
360. That malafide part of the complainant is that accused

persons are residing at different places, then it is
[4]
thoroughly imposible that, how complainant was in knowledge
about name, parentages, address fo the acused persons, so it be
indicated that complainant who with preplanning has lodged
this false FIR against the accused persons with consultation of his
staff.
361. That malafide part of the complainant is that, there is no

single mark on the person of either side or vehicle fo the
complainant.
362. That malafide part of the complainant is that he stated

that firing continued for about 9 minutes but no empty was
recovered and no single mark shown of hitting the fires but
complainant by managing this false story has implicated the
applicant accused.
363. That applicant accused is behind the bar for the

indefinite period.
364. That no specific role, part, injury, overt act assigned to

the applicant accused but this whole drama has been made by
the complainant.
365. That there is ineffective firing has been shown by the

complainant , as per contents of the FIR section 324 PPC is nto
attracting to the present case.
366. That nothing has been committed but this whole drama
has been staged by the complainan.
367. That there is violation of sec tion 103 PPC.
[5]
convict previously.



arguments.

APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF CIVIL JUDGE AND JM-I KAZI
AHMED
B. A. No: OF 2017.
The State
VS
Abdullah Dharejo and another

BAIL APPLICATION

-: F A C T S :-

complainant, HC Kareem BUx Lakho lodged his FIR at police
station Kazi Ahmed, on 20-6-2017, at about 1700 hours,
alleging therein that, today complainant alogn with PC
Imamuddin, PC Ghulam Nabi, PC Muhamamd Ashraf, with
police ammunition, on police mobile No. 305, along with
driver PC Pyaro Khan, under the entry
[2]
No 12/ 20-6-2017 at about 1430 hours, they departed within

their beat, for patrolling, various places, when they lead Jamal
shah Link Road towards Pir Form and where, complainant
party got spy information that, namely Abdullah Dharejo, is
selling the Katcha wine at Lundi Shakh Ji Mori, openly, the
complainant after getting such information, he along with his
staff departed towards the pointed place, when at about 1545
hours, they saw, two persons, by keeping the Gallon of the
Katcha wine were standing there, who have been identified,
which to be Abdullah son of Haji Jam Dharejo, and Khuda
Bux son of Gulsher Mahar, they by seeing the police party
tried to run away, the police party at once stopped their
vehicle, complainant with help of his staff, tried to capture
him, but accused Khuda Bux Mahar by leaving Katcha wine
run away and accused Abdullah Dharjeo was arrested along
with Gallon of Katcha wine due to non availability of the
private Mashirs, PC Ghulam Ali, PC Muhammad Ashraf were
made Mashirs, the arrested accused was inquired about his
name, address etc, who disclosed his name Abdullah son of
Haji Jam Dharejo, resident Ghatti Goth, his body search was
conducted but nothing was found, recovered plastic bag was
searched, out of which 10 Litter Desi wine was lying, out of
which one bottle was sealed separately, and other wine was
sealed separately, the arrested accused disclosed for the run
away accuse, that who was namely Khuda Bux son of Gulsher
Mahar, R/O own houses, taluka Kazi Ahmed, and further
disclosed that they in gathering, used to sale the Katcha wine,
the Gallon of run away accused was checked, out of which 10
litters were lying, in
[3]
which one bottle was sealed separeately and other Katcha
wine sealed separately, the run away accused Khuda Bux
Mahar and arrested accused Abdullah Dharejo, who by
keeping Katcha wine in their possession have committed
offence of 3,/4 Munshiyat, Hudood, such Mashirnama was
prepared and accused along with recovered property were
brought at police station hence this FIR.

arrested, hence this bail application was filed by the applicant
accused on the following grounds.
-: G R O U N D S :-

applicant/accused.
374. that alleged Katcha wine has been foisted upon the
applicant accused, otherwise he has no concerned with the
alleged incident.
375. That place of incident is Jamal Shah Link Road at Shakh

Ji Mori, which is highly and thickly populated area and
surrounding the same area there is highly village population,
it is impossible to commit offence easily or selling the chars
easily and accused was standing there,
[4]
but by managing this false story implicated the applicant
accused and besides failed to associate private Mashir and by
making consultation with his sweet obligor witnesses has
implicated the applicant accused in this false case .



intention.

ulterior reasons.
381. That complainant on hearsay implicated the applicant

accused, otherwise complainant or his staff has not shown
any purchaser or further location but by foisting Katcha wine
has implicated the applicant accused .

convict previously.
[5]



arguments.

APPLICANT/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No OF 2017.
Arif son of Gul Nabi Pathan

VS
Crime No. 50/2017 PS A section

Nawabshah
U/S 14 foriegner Act
BAIL APPLICATION

grounds:
-: F A C T S :-

ASI Abdul Sattar Kamboh lodged his FIR at police station A
section Nawabshah On 25-2-2017 at about 1015 hours, alleging
therein that, today he along with his staff, PC Muhammad
Hashim, PC Zahid Ali, PC Muhammad Saleem, with police
ammunition, on the police mobile No. 2, along with driver PC
Habibullah, under entry No 03/25-2-2017, at about 8:15 hours,
departed within their beat, for patrolling various places,
[2]
when at about 09-00 hours, they reached at Bypass Road

Ghulam Hyder shah Colony Nawabshah, where complainant
party saw tow persons were standing, who were seems
Afghani type, they by seeing the complainant and his staff in
police uniform tried to run away, the police party at once got
down, captured the the persons, at once due to non
availability of the private Mashirs, PC Muhammad hashim,
PC Zahid Ali were made Mashirs, from their names and
address were inquired, who disclosed their names, which to
be Arif son of Gul Nabi Pathan, from their body search , from
his body search amount of Rs. 200/- were recovered, detailed
bellow, which were kept in custody of the police, second
person disclosed his name to be Jahangir son of Gulab Khan
Pathan, from his body search, from his shirt, amount Rs. 300/-
detailed bellow were recovered, which secured in custody of
the police, both arrested accused were inquired abouted Visa,
Passport, etc, on which they disclosed that, they without visa
and passport, entered into Pakistan, illegally by crossing
border, thereafter, they were arrested under 14 foreigner act,
such mashirnama was prepared before Mashirs, the accused
was brought at police station, hence this FIR was lodged.

applicant/accused who is in judicial custody, applicant which
was rejected due to mistake father’s name of the applicant,
hence this fresh bail application with fresh grounds .
[3]
-: G R O U N D S :-

implicated the applicant accused.
15. That applicant accused is Pakistani and his father’s and and
other relatives identity card is prepared of paksitan , so it be

indicated that his paternity is of paksitan and he is not belonging
with forienger country or he is not Afghani.
accused, which will be same of Pakistan as he and his family has

no cocnenred with Afghanistan and they are not forienger.
17. That applicant accused and his other family used to sell cloths at
different places, but police without verifying name address and

without getting further detail has lodged this FIR with malafide
intention .
foreinger.

pakstiani.
[4]
complainant.


APPLICANT/ACCUSED
CERTIFICATE

behalf of the applicant/accused before this honourable court
prior to this no bail is filed by the applicant accused .

BENAZIRABAD
B. A. No OF 2017.
Parvez son of Gulab Khan alias Gul Allam

VS
Crime No. 22/2017, PS B section

Nawabshah
BAIL APPLICATION

grounds:-
-: F A C T S :-

SIP/ SHO Khan Muhamamd Jamali lodged his FIR at police
station B section Nawabshah, On 25-2-2017 at about 1730
hours, alleging therein that, complainant along with his staff,
each PC Ghulam Mustafa, PC Wali Muhammad, with police
ammunition, on police Mobile No 212, along with driver Ali
Khan departed for patrolling under entry No 18 dated 25-2-
2017 at about 1530 hours, within the beat of city,
[2]
various places, when at about 1630, hours, complainant party
reached at 60th Mile Nakka in Deh 86 Nusrat, where they saw
one person was standing from the eastern side of road, who
by seeing the police and police party tried to skip away, police
suspected him and on the distance of 10 steps, the
complainant stopped their mobile, dismounted from it, very
tactfully apprehended him, the police party tried to made
private mashir but not found, PC Gulam Mustafa and PC
Wali Muhammad made mashirs, the arrested person was
iqnuried about his name and address,, who disclosed his
name to be the applicant accused, resident of Afghani, the
police inquired about Visa, Passport, and further detail of
entering in the Pakistan country, but he disclosed that same
are not available and he along with his brother Jahangir and
his relatives Arif son of Gul Nabi Pathan and Ibrahim son of
Ghulam Nabi Pathan are entered into Pakistan in gathering,
and their whereabouts are not known, thereafter complainant
party arrested him under 14 foriegner act, from his body
search nothing found, such mashirnama was prepared before
Mashirs, the accused was brought at police station, hence this
FIR was lodged.

applicant/accused who is in judicial custody, applicant which
was rejected due to mistake father’s name of the applicant,
hence this fresh bail application with fresh grounds .
[3]
-: G R O U N D S :-

17. That applicant accused is Pakistani and his card is prepared of
Pakistan .
18. That identity Card, father and mother of the applicant accused is
prepared of paksitan , but complainant by showing false incident

has implicated the applicant accused.
accused, which will be same of Pakistan as they have no

cocnenred with Afghanistan and they are not forienger.
20. That applicant accused and his other family used to sell cloths at
different places, but police without verifying name address and

without getting further detail has lodged this FIR with malafide
intention .
foreinger.
[4]

pakstiani.
complainant.


APPLICANT/ACCUSED
CERTIFICATE

on behalf of the applicant/accused before this honourable
court prior to this no bail is filed by the applicant accused .

IN THE COURT OF CIVIL JUDGE AND JM-I
B. A. No: OF 2014.
The State
VS
Abdul Razzak
Crime No: 70/2014, P.S, B Section

Nawabshah
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Mian Bux Mari lodged his FIR . on 21=-5-
2014 at about 13:30 hours, he alleged therein that he along
with his subordinate staff, each one PC Dur Muhammad PC
Muhammad Bux, officials arms and ammunition on
government vehivle NO SP 7575 with driver PC Ali Khan,
vide entry No 16 dated 21-5-2014. at about 11:15 hours, left the
PS for patrolling in his beat after patrolling deferent places ,
when police party reached near Mehmood Ali Shah turn, at
60th Mile Road there they received spy information that one
persons openly selling a chars on 60th Mile road after receiving
such information the complainant along with above staff,
moved towards the pointed place, when at about 12:30 hours
the complainant party reached there , at 60th Mile Phatic in
Deh 86 Nusrat, Taluka Nawabshah and saw one persons
having black shopper in his right side hand who seeing the
police party and government vehicle, tried to run away, then
complainant party stopped their mobile deboarded the same
and made a circle with tactfully and
[2]
apprehended the accused due to non availability of the

private masher each one PC Dur Muhammad Bhangwar PC
Muhammad Bux appointed act as mashirs, and inquired
about the apprehended persons and then the phatic shopper
which was in right handed same was possessed the police,
thereafter inquired about name and caste and residence of the
accused who disclosed his name to be applicant accused
Abdul Razzak thereafter complainant party opened the black
shopper and found one big piece of charas, lying in and
weight of the same to be 240 grams, out of which little piece of
chars 40 grams Weight of the same separately sealed and
remaining Charas of 200 Grams sealed in back shopper,
further body search found Rs 70/o from right side of shirt,
detail of the same is below from home further inquired, about
the charas and cash amount who disclosed that charas is my
own same is being sale for passing life and amount of the
same is a selling of the charas, then complainant party
arrested the accused persons under section 3/4 PEHO, such
mashirnama was prepared with signature of the mashers,
thereafter arrested accused recovered property and cash
amount brought at PS under the custody of the complainant
party therefore arrested the accused keeping the possession
illegal charas for purpose of selling has committed and
offence u/s 3/4 Manshiyat due to that on behalf of the state
the present case has been registered.
DETAIL OF RECOVERED CHARAS AND CASH

AMOUNT
1. One big Piece of Chars weight 240 Grams out of which one
little piece of charas weight 40 grams sealed the same for
chemical examination and remaining chars 200 separately
sealed in black plastic.
2. Cash amount of one Currency Note of Rs 50 and tow
currency note of 10 Rupees total Rs 70/- hence the present
application on following grounds.
-: G R O U N D S :-

applicant/accused.
389. that on 21-5-2014 the accused was coming from his

village to Nawabshah for labouring as he is mason at that
time he has a cash
[3]
amount Rs 4000/- which were taken by the police party then it

was are foisted upon the accused demanded back due to that
motive in order to usurp the cash amount of Rs 4000/- of the
accused due to that false case has been registered against the
accused.
390. That the section/ offence mentioned in the FIR do not

fall within the prohibitory clause of section 497 Cr PC .
391. That the section 4 is bailable while section 3 which too

doesn’t fall within the prohibitory clause, it is yet to be
determined at the time of evidence whether the alleged
property recovered are foisted upon the applicant/accused ,
hence false implication can not be ruled out.
392. That the witnesses are police officials and subordinate of

the complainant and they are interested hence there is no
apprehension of the tampering with the evidence.
393. That the case makes the one of further inquiry.

394. That the applicant accused previous not convicted ( as
per instruction)

arguments.

APPLICANT/ACCUSED
CERTIFICATE

BAHADUR ALI MAHESAR

Advocate for the applicant/accused
B. A. No OF 2017.
Baqar Ali son of Abdul Hakeem Bhoot

Police Lock up at PS B section
Nawabshah ………….. ……………………Applicant/Accused
VS

Nawabshah
U/S 489-F PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

Raza Muhammad lodged his FIR at police station B section
Nawabshah, on 12-6-2017, at about 1330 hours, alleging
therein that, complainant has a Pasticide Pedhi situated at
Muhammad Ali Shah 60th Mile Road, Deh 86 Nusrat, Taluka
Nawabshah, with name and style Al Madina Pasticide Pedhi,
where complainant is doing business of the various pesticides,
[2]
namely Baqar Ali son of Abdul Hakeem Bhoot, resident

village Muhammad Siddique Bhoot, Taluka Tando, District
Badin is already known from the complainant, about some 3
months back at noon time, complainant along with his
witnesses Muahmmad Ishaque son of Dad Muhammad,
Zulfiqar Ali son of Hakim Ali Khaskheli both resident 60th
Mile Road Deh 86 Nusrat Taluka Nawabshah, who were
sitting there, where, Baqar Ali came, and purchased 100 bags
weighting about 10 each bag, total balance amount worth of
Rs. 120,000/- became against the Baqar, in lieu of that amount,
the Baqar Ali issued a cheque No. 24228753 dated 5-5-2017,
from his account No. 0112072502102467 drawn at UBL Bank
Branch Khoski District Badin and taken away the rice crops,
thereafter, complainant went to encash the cheque but same
could not pass, the manager of the Bank drawn Memo by
stating that amount in insufficient in that account, thereafter,
complainant approached to the Baqar Ali Bhoot and narrated
whole facts, so he may return the amount, on which he kept
the complainant on false hopes, today he refused to pay the
amount, thereafter, complainant moved an application under
section 22-A 6 (i) Cr, PC to Honourable sessions judge,
thereon complainant got order of 1st Additional session judge
to registering the FIR, hence this FIR was lodged.
After registration of the FIR, the applicant /accused has

been arrested by the police, who is in jail custody, hence this
bail application on the following grounds.
[3]
-: G R O U N D S :-
28. That there is delay in lodging the FIR for about 3 months and 5
days, which is inordinate delay and unexplained at all.
29. Thatin fact nothing has been committed but this whole drama
has been staged by the complainant, actual facts are that,

applicant/accused is doing work in pesticide company at Khoski
Badin, and besides, applicant accused has no concerned or
contacts with the complainant but complainant with malafide
intention, who has misused the above cheque by showing above
false story, otherwise applicant accused has not purchased the
rices bags or other thing etc, from the complainant.
30. That applicant accused and one Ganhwar Mallah are doing the
pesticide work in one and same company, while some cheques of

the applicant accused were lying to the Ganhwar Mallah with
relation of business, same have been misplaced, thereafter ,
applicant accused kept searching for the same cheques to the
Ganhwar Mallah and other place but after registration of this
FIR, applicant accused came to know that, above false story has
been made out against the applicant accused and his cheque has
been misused by the complainant for the ulterior reasons.
[4]
31. That applicant/accused have nothing with the complainant but,
complainant being person of greedy type and being influence

person has misused the cheque just to put pressure upon the
applicant accused so that he may oblige the complainant party
with ill designs and means.
32. That applicant accused is gentle man he can not think into such
acitivites but complainant very tactfully and by applying his

sharp mind has implicated the applicant accused in this false
case.
33. That section 489-F, PPC is not attracting to the present case,
which has been misapplied by the complainant with malafide

intention for the ultior reasons.
34. That complainant is dol of some other persons who has been
hired to get register this false FIR , otherwise applicant accused

has no cocnenred with the alleged things which have been
managed, and engineered by the complainant, otherwise, story
narrated in the FIR is stereotyped, implausible, and untenable.
35. That applicant accused is not hardened criminal nor desperate
nor previous convicted.
36. That section applied in the FIR doenst come under prohibitory
clause of section 497 Cr, PC.
evidence, as all the PWs cited in the FIR are pocket person of the
complainant .
[5]
38. That applicant/accused is ready to furnish solvent surety to the

APPLICANT/ACCUSED
CERTIFICATE

on behalf of the applicant/accused prior to this no any bail or

Muhammad Sharif son of Allah Warayo Solangi

Benazirabad ………….………………………Applicant/accused
VS

BAIL APPLICATION
grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant SIP Nazeer

Hussain Rind loldged his FIR at police station Jam Dattar on
24-4-2017, at about, 13:10 hours, alleging therein that, today
complainant along with his staff each, PC Ihsan Ali Brohi, PC
Liaquat Ali Brohi, with police ammunition, on police mobile
No. SPD-771, along with driver Muhammad Ali Solangi
departed under entry No. 7/24-4-2017 at about 1200 hours,
departed for patrolling, various places, when they
[2]
reached at Shahpur Chakar Chowk in Jam Sahib, where

complainant party got spy information that one person is
selling chars on money openely near Railway Station Jam
Dattar, after getting such information, the complainant party
departed towards pointed place, when at about 12:30 hours,
complainant party arrived near railway station Chowk Deh
109 Nusrat Taluka Daur, they saw one person was standing at
railway station, containing the black colour plastic shopper,
who was suspected, police party stopped their vehicle, got
down from it, who by seeing the police tried to run away, the
complainant party very tacatfully captured, the accused
including the black colour shopper was lying in his hands, he
was inquired about his name and address, who disclosed his
name to be Muhammad sharif, due to non availability of the
private Mashirs, PC Ihsan Ali Brohi, PC Liaquat Ali Brohi
were made Mashirs, the recovered shopper was opened, in
whichfive big pieces and 4 small pieces of chars were
recovered, the chars was weighted at spot which became 2000
grams, from his body search, from his right side of pocket,
one note of Rs. 100 and three notes of Rs. 50 detailed bellow
were recovered, which were secured in custody of the police,
the chars was sealed for sample purpose, the police inquired
about the recovered chars, who disclosed that he used to sale
the chars on money, so he has been arrested in the above
case/crime, such mashirnama was prepared before mashirs,
thereafter recovered property and accused were brought at
police station where present FIR was lodged hence this FIR.
[3]

ground.
-: G R O U N D S :-

ulterior reasons.

alleged offence.

the chars easily or openely but complainant by showing
tacnically.
[4]
superior population the complainant could not perform his

duty honestly to act for independent witness whereas all the
PWs cited in the FIR are hostile towards the applicant as well
as they are well wisher of the complainant and they are sweet
obligor of the complainant.
172. That there is inordinate delay in sending chemical

report of chars, so it is clear crystal that nothing has been
recovered from the applicant/accused but each and every
thing has been mananged and arranged by the complainan
concotedely.




the complainant.
177. That it is settled principle law that if the single

[5]
benefit of doubt arose in prosecution story, then each every

benefit of doubt should go in favour of the applicant/accused
at bail stage.
description of chars, but only shown 6 pieces chars, which
creating highly doubt in prosecution story.
179. That further actual facts are that, Muhammad Sharif

applicant/accused was slept in his house On 19-4-2017, where
police in 7 police mobiles about 25/30 police officals along
with and in league of Imam Din Marfani, came there and
raided at house of the applicant, on coming, the police entered
into house of the applicant and took the applicant and his
cousin Parvez, by stating that they are roped in other cases,
by saying so police took the applicant and his cousin, at police
station Daulatpur, when, elder of the applicant accused
approached at police station and inquired about detention of
the applicant accused, on which SHO Imam Din Marfani
stated that, investigation against the applicant accused is
being conducted and after completion of the investigation
within 5 days they will release the applicant accused and his
cousin, thereafter, applicant came to know that, FIR in above
case/crime Number has been lodged against the applicant
accused and his cousin has been arrested in another case of
narcotics, so it be indicated that, above case is nothing, but
complainant very tactfully with direction of SSP District SBA
has lodged this false FIR by managing things, with malafide
intention for ulterior reasons otherwise applicant accused has
no concerned with the alleged offence.
[6]
180. That there is no such type of record previously against
the applicant accused that he already was selling chars or not
but, complainant being person of greedy type and has been
hired to implicate the applicant accused in this false case, so
result of which is that, he has been falsely implicated in this
false case otherwise, applicant accused has no committed
offence and things narrated in the FIR are implausible .




APPLICANT/ACCUSED
CERTIFICATE


B. A. No OF 2017.
Baqar Ali son of Abdul Hakeem Bhoot

Police Lock up at PS B section
Nawabshah ………….. ……………………Applicant/Accused
VS

Nawabshah
U/S 489-F PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

Raza Muhammad lodged his FIR at police station B section
Nawabshah, on 12-6-2017, at about 1330 hours, alleging
therein that, complainant has a Pasticide Pedhi situated at
Muhammad Ali Shah 60th Mile Road, Deh 86 Nusrat, Taluka
Nawabshah, with name and style Al Madina Pasticide Pedhi,
where complainant is doing business of the various pesticides,
[2]
namely Baqar Ali son of Abdul Hakeem Bhoot, resident

village Muhammad Siddique Bhoot, Taluka Tando, District
Badin is already known from the complainant, about some 3
months back at noon time, complainant along with his
witnesses Muahmmad Ishaque son of Dad Muhammad,
Zulfiqar Ali son of Hakim Ali Khaskheli both resident 60th
Mile Road Deh 86 Nusrat Taluka Nawabshah, who were
sitting there, where, Baqar Ali came, and purchased 100 bags
weighting about 10 each bag, total balance amount worth of
Rs. 120,000/- became against the Baqar, in lieu of that amount,
the Baqar Ali issued a cheque No. 24228753 dated 5-5-2017,
from his account No. 0112072502102467 drawn at UBL Bank
Branch Khoski District Badin and taken away the rice crops,
thereafter, complainant went to encash the cheque but same
could not pass, the manager of the Bank drawn Memo by
stating that amount in insufficient in that account, thereafter,
complainant approached to the Baqar Ali Bhoot and narrated
whole facts, so he may return the amount, on which he kept
the complainant on false hopes, today he refused to pay the
amount, thereafter, complainant moved an application under
section 22-A 6 (i) Cr, PC to Honourable sessions judge,
thereon complainant got order of 1st Additional session judge
to registering the FIR, hence this FIR was lodged.
After registration of the FIR, the applicant /accused has

been arrested by the police, who is in jail custody, hence this
bail application on the following grounds.
[3]
-: G R O U N D S :-
41. That there is delay in lodging the FIR for about 3 months and 5
days, which is inordinate delay and unexplained at all.
has been staged by the complainant, actual facts are that,

applicant/accused is doing work in pesticide company at Khoski
Badin, and besides, applicant accused has no concerned or
contacts with the complainant but complainant with malafide
intention, who has misused the above cheque by showing above
false story, otherwise applicant accused has not purchased the
rices bags or other thing etc, from the complainant.
43. That applicant accused and one Ganhwar Mallah are doing the
pesticide work in one and same company, while some cheques of

the applicant accused were lying to the Ganhwar Mallah with
relation of business, same have been misplaced, thereafter ,
applicant accused kept searching for the same cheques to the
Ganhwar Mallah and other place but after registration of this
FIR, applicant accused came to know that, above false story has
been made out against the applicant accused and his cheque has
been misused by the complainant for the ulterior reasons.
[4]
44. That applicant/accused have nothing with the complainant but,
complainant being person of greedy type and being influence

person has misused the cheque just to put pressure upon the
applicant accused so that he may oblige the complainant party
with ill designs and means.
45. That applicant accused is gentle man he can not think into such
acitivites but complainant very tactfully and by applying his

sharp mind has implicated the applicant accused in this false
case.
46. That section 489-F, PPC is not attracting to the present case,
which has been misapplied by the complainant with malafide

intention for the ultior reasons.
47. That complainant is dol of some other persons who has been
hired to get register this false FIR , otherwise applicant accused

has no cocnenred with the alleged things which have been
managed, and engineered by the complainant, otherwise, story
narrated in the FIR is stereotyped, implausible, and untenable.
48. That applicant accused is not hardened criminal nor desperate
nor previous convicted.
49. That section applied in the FIR doenst come under prohibitory
clause of section 497 Cr, PC.
evidence, as all the PWs cited in the FIR are pocket person of the
complainant .
[5]
51. That applicant/accused is ready to furnish solvent surety to the

APPLICANT/ACCUSED
CERTIFICATE


Ghulam Hussain alias Baghu son of simple Gul

Muhammad alias Gullu, presently
confined in District Jail Shaheed
Benazirabad ………….………………………Applicant/accused
VS
The State…………………..……………………….………….Opponent

Nawabshah
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant SIP Khan

Muhammad Jamali lodged his FIR at police station
Nawabshah, on 8-3-2017 at about 2000 hours, alleging therein
that, today complainant along with his staff, each, PC Dur
Muhammad, PC Nisar Ahmed, PC Khalid Parvez, with police
ammunition on police mobile
[2]
No. 212, along with driver PC Mohabat Ali Zardari, under the
entry No 29/8-3-2017, departed for patrolling within their
beat, various places, when they reached Sanghar Road Quetta
Bus stand, where complainant party got spy information that
one person on Link Road of sugar Mill, at Dirty Pond, where
selling the chars openly , the complainant party after getting
such information, he along with his staff departed towards
pointed place, when at about 1900 hours, compliannt party
arrived at pointed place, and saw one person, was standing
there, containing one black colour shopper, who by seeing the
police in uniform and police vehicle tried to run away, the
police party at once stopped their vehicle, and complainant
with help of his staff captured the person and secured black
colour shopper, complainant tried to associate private mashir
but not found, meantime PC Dur Muhammad and PC Nisar
Ahmed were made Mashirs, the arrested person was inquired
about his name, who disclosed his name to be Ghulam
Hussain alias Baghu son of Gul Muhammad alias Hussain by
caste Machi, resident at kazi ahmed, the compliannat party
opened the black shopper, in which 6 pieces of chars were
lying, which was weighted, same to be 1100 grams, which at
once sealed for chemcail analysis containing the plastic
shopper, from body search of the accused, from his right side
of pocket, complainant party recovered Rs. 250/- detailed
bellow, the complainant party inquired about chars, on which
he disclosed that, amount is of chars, he used to sale on the
money, thereafter compliannt got information that, accused is
already involved in crime No 121/2013, PS B section under
section 399, 402,
[3]
crime No 105/2014, under section 324, 353, 398, crime No.

17/2015, 380, 457, PS Daulatpur, in which accused is required,
such Mashirnama was prepared before Mashirs, the accused
and recovered property were brought at police station, hence
this FIR has been lodged .

ground.
-: G R O U N D S :-

ulterior reasons.

alleged offence.
[4]
the chars easily or openely but complainant by showing
tacnically.

189. That involvement of the applicant accused in the other

case is false and fabricated one, so as per settled principle law
in S.C.M.R 2017 page No 279, “it is reported that relevance list of
different criminal cases registered accused the accused and if any co
accused persons was placed on record by the complainant, Supreme
Court observed that it was only seized of the present bail application
filed by the accused and the effect/impact of the previous crimincal
record against the accused and if any co accused was not relvenat
for disposing of the present bail application or petition, on that
reported law accused has been released”, so it is right of the
applicant accused to be granted bail by this honourable court
without touching the previous criminal cases.
190. That there is inordinate delay in sending chemical

report of chars for about 14 days, so it is clear crystal
[5]
that nothing has been recovered from the applicant/accused

but each and every thing has been mananged and arranged by
the complainan concotedely.



the complainant.

stage.
description of chars, but only shown 6 pieces chars, which
creating highly doubt in prosecution story.
[6]
197. That such quantity of the chars is on border line of

section 9/C and 9/B, so applicant is entitled to get such sort of
relief.



APPLICANT/ACCUSED
CERTIFICATE

B. A. No OF 2017.
Babar son of Muhammad Haroon

VS

Nawabshah
U/S 381-A PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

namely Munwar Hussain lodged his FIR at police station B
section Nawabshah, on 23-6-2015, at about 1630 hours,
alleging therein that, he is reiding at above mentioned
address, he has owned motorcycle, purchased which is
applied for registration, detailed bellow, On 20-6-2015 ,
cmplianant along with his brother Ashfaque Hussain who
parked his motorcycle in front of main gate of house in Nasir
Shah Colony, he by
[2]
leaving the articles in the house, came out and saw the
motorcycle was not available, the nieghbourer came there but
not found the same, thereafter complainant started searching
the motorcycle, thereafter, he came to know that, motorcycle,
has beem stolen away by key theft, namely Ghulam Shabir
sonof Loung Khan Ghangharo, Jahanzaib son of Muhamamd
Yousif, Babar son of Muhamamd Haroom Ghangharo, who by
breaking the lock of the motorcycle stolen away the same,
After registration of the FIR, the co accused have already
been granted bail and also acquitted from the above case, but
applicant accused was no aware about such false implication,
when police by hunting and finding arrested the applicant,
and then he came to know that above FIR in which he is
named, hence this bail application on the following grounds.
-: G R O U N D S :-
54. That there is delay in lodging the FIR for about 3 days, which is
inordinate delay and unexplained at all.
56. That malafide part of the complainant is that complainant has
not stated that, how, and in what manner he has got

[3]
information that, applicant accused and others are his culprits.
57. That case is un-witnessed and there is no eye witness in the
above FIR.
58. That there is no time and further detail that at what time his
motorcycle has been stolen.
59. That, complainant fialed to proved that applicant accused is
accused or innocent but he has roped him in this false case.

60. That there is nothing on record against the applicant accused that
he is key theft, or involved in the other cases.
61. That co accused are already granted bail and they are acquitted
from the above case therefore applicant is entitled for the same
sort of relief.
63. That applicant accused is poor, labour type and by profession
tailer Master and he can not think into such bad activities.
64. That due to ulterior motives applicant accused and others have
been involved in the above case/crime.
65. That case has been challaned and case is likewise to release the
applicant accused by granting bail him and
[4]
acquitting the accused, and case is no more required for the

as case is unwitnessed and belind one like the stereotyped just to

implicate the applicant in this false case for the ulterior motives.


APPLICANT/ACCUSED
CERTIFICATE

B. A. No OF 2017.
Babar son of Muhammad Haroon

VS

Nawabshah
U/S 381-A PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

namely Munwar Hussain lodged his FIR at police station B
section Nawabshah, on 23-6-2015, at about 1630 hours,
alleging therein that, he is reiding at above mentioned
address, he has owned motorcycle, purchased which is
applied for registration, detailed bellow, On 20-6-2015 ,
cmplianant along with his brother Ashfaque Hussain who
parked his motorcycle in front of main gate of house in Nasir
Shah Colony, he by
[2]
leaving the articles in the house, came out and saw the
motorcycle was not available, the nieghbourer came there but
not found the same, thereafter complainant started searching
the motorcycle, thereafter, he came to know that, motorcycle,
has beem stolen away by key theft, namely Ghulam Shabir
sonof Loung Khan Ghangharo, Jahanzaib son of Muhamamd
Yousif, Babar son of Muhamamd Haroom Ghangharo, who by
breaking the lock of the motorcycle stolen away the same,
After registration of the FIR, the co accused have already

been granted bail and also acquitted from the above case, but
applicant accused was no aware about such false implication,
when police by hunting and finding arrested the applicant,
and then he came to know that above FIR in which he is
named, hence this bail application on the following grounds.
-: G R O U N D S :-
72. That malafide part of the complainant is that complainant has
not stated that, how, and in what manner he has got

[3]
information that, applicant accused and others are his culprits.
73. That case is un-witnessed and there is no eye witness in the
above FIR.
74. That there is no time and further detail that at what time his
motorcycle has been stolen.
75. That, complainant fialed to proved that applicant accused is
accused or innocent but he has roped him in this false case.
76. That there is nothing on record against the applicant accused that
he is key theft, or involved in the other cases.
77. That co accused are already granted bail and they are acquitted
from the above case therefore applicant is entitled for the same
sort of relief.
79. That applicant accused is poor, labour type and by profession
tailer Master and he can not think into such bad activities.
80. That due to ulterior motives applicant accused and others have
been involved in the above case/crime.
81. That case has been challaned and case is likewise to release the
applicant accused by granting bail him and
[4]
acquitting the accused, and case is no more required for the

as case is unwitnessed and belind one like the stereotyped just to

implicate the applicant in this false case for the ulterior motives.


APPLICANT/ACCUSED
CERTIFICATE


2nd Bail application
BENAZIRABAD
B. A. No OF 2017.
Lala Khan ……….………………………..……Applicant/Accused
VS
Crime No. 42/2017, PS Airport

AFFIDAVIT
I, Muhamamd Musveer son of Muhamamd Ramzan,

under CNIC No. 54203-6856634-5, Muslim, Adult R/O,
Khali Shah, Mir Pir, Aleezai Doc Khana Meezani Adda,
District Kila Abdullah, do hereby state on aoth as under:-
1. That I am nephew of the applicant accused hence fully

2. That applicant/accused is son of Moosa Jan, whereas

Moosa Jan is my grandfather, he has his owned property
and both viz applicant/accused and Moosa Jan are living
in Pakistan and are peaceful loving Pakistani.
3. That applicant accused is not foreingner or Afghani, and he

is living with his father and also doing work of labouring,
but complainant by showing false story has implicated the
applicant accused for ulterior reasons.
4. That I am hereby verifying on the Oath by sweari on this

affidavit that, Fateh Muhammad is not name of father of
applicant accused but name of father of the applicant
accused is Moosa Jan which is actual and real name.
whatever stated above is true and correct to the best of

my knowledge.

advocate
2nd Bail application
BENAZIRABAD
B. A. No OF 2017.
Lala Khan son of Moosa Khan alias Fateh

Muhammad Pathan Presently confined
in District Jail shaheed
VS
Crime No. 42/2017, PS Airport

BAIL APPLICATION

grounds:-
-: F A C T S :-

ASI Shahdad Khan lodged his FIR at police station Airport,
On 28-2-2017 at about 1900 hours, alleging therein that,
complainant along with his staff each Kehar Nazeer, C
Wazeer Muhammad, with police ammunition, on police
Mobile along with driver Inayat, departed under entry No
17/ 28-2-2017 at about 1730 hours, various places, when at
about 1830 hours, they reached at Lahore Bakkary, Muhalla
[2]
issarpura, Nawabshah, where they saw one person by seeing

the police in police uniform, who was concealing himself, the
police suspected, stpped government vehicle very tactfully
encircled the persons on the distance of 10 steps, the police
party tried to make private Mashir but not found,, PC Kehar
Nazeer and Wazeer Muhammad wre made mashir, the
arrested person was inquired about name, residency, and on
which he disclosed his name to be Lala Khan son of Fateh
Muhamamd Afghani, the police party conducted body search
of the accused from his front pocket of shirt, police recovered
Rs. 100/- thereafter police inquired about passport, visa, and
other documents, on which he disclosed that same are not
available, he has entered into Pakistan illegally, without
passport and visa, and also crossed border from Afghanistan
to paksitan, thereafter, complainant took the accused and
recovered property and brought at police station and lodged
present FIR.

applicant/accused who is in judicial custody . A bail
application was filed by the aplciant accused which was
rejected due to mistake father’s name of the applicant, hence
this fresh bail application with fresh grounds .
-: G R O U N D S :-
[3]

87. That actual name of the applicant accused is Lala Khan son of
Moosa Jan, but complainant by showing false name father of th

applicant accused as Fateh Muhammad has lodged present FIR .
88. That identity Card, father of the applicant accused namely
Moosa Jan is prepared of Pakistan, with number 54203-0166629-

3, but complainant by showing false incident has implicated the
applicant accused.
89. That nephew of the applicant accused namely Muhamamd
Musveer is swearing his affidavit before this Honourable, that,

the father’s name of the applicant accused is Moosa Jan which is
actual and real name of father of the applicant accused but
complainant by showing false incident has shown name of father
fo the applicant accused Fateh Muhamamd has implicated in the
above case.
90. That Resldar Naib Tehsildar Killa Abdullah District Killa Abdull,
also verified by showing verification Certificate in which there is

clear crystal that, name of father of the applicant accused is
Moosa Jan and he is residing at Kila Adbullah.
91. That father of the applicant accused has property under
[4]
Khewat Number 86 and Khtooni Number 94, Khusra No 18,
but complainant by showing him foreinger has lodged this
false FIR against the applicant accused.
92. That documents are being produced at the time of arguments
which are original and verified in favour of the applicant

accused.
foreinger.
94. That the applicant is not hardened criminal or desperate as per
instructions of the applicant/accused.


APPLICANT/ACCUSED
[5]
CERTIFICATE
This is to certify that this 2nd bail application on

behalf of the applicant/accused first was rejected due to
mistake father’s name of the applicant accused .

BENAZIRABAD
B. A. No OF 2017.
Ayaz Ali son of Ghulam Abbas Jamali

Presently confined in District
Jail shaheed Benazirabad ..……………Applicant/Accused
VS
Crime No. 26/2017, PS Pubjo

U/S 302, 337-J, 34 PPC .
BAIL APPLICATION

grounds:-
-: F A C T S :-

Waryam Fakeer lodged his FIR at police station Pubjo, On 21-
5-2017 about 1200 hours, alleging therein that, he is residing at
above mentioned address, Mst Rehmat Bibi aged about 25/26
years, is daughter of complainant, whose marriage was
consummated with one Ayaz Ali Jamali, to whom, she gave
birth two daughters namely Zaibunisa aged about 3 years,
and
[2]
Mehrunisa aged about 1 year, the marriage of the daughter of

Manzoor Hussain namely Mst Husna is solminzed with
Ghulam hussain brother of the complainant, some 6/7
months back, due to matrimonial affairs, the Manzoor Jamali
got returned back her daughter and stayed in his house, on
which Manzoor Hussain Jamali party were annoyed, On 13-5-
2017, complainant was present at the house of deceased Mst
Rehmat Bibi, where Mst Rehmat Bibi also narrated her
sorrows and painful matters with complainant, where other
family members of the house were available, on which
complainant mended ways of his son in law Ayaz Ali, on
which hot word exchange in between them, on the next day
complainant returned back Hyderabad, on 17-5-2017,
complainant’s son in law Ashique Ali son of Allah Dad
Jamali informed to the complainant that his daughter Mst
Rehmat Bibi was cooking meal where due to hitting flames of
the fire she brunt away and died, the complainant along with
his sons came at house of his deceased daughter, where, he
saw his daughter was died, and his son in law Ashique Ali
who informed the police to conduct necessary formilties of the
dead body, the police came and conducted postmortem of the
dead body, thereafter, complainant party after brurial her
were available on condolence, where adjacent persons came
for condolence, where son in law of the complainant and his
nephew namely Masroor Khan son of Rajab Ali stated that,
Ayaz ali and Manzoor Hussain jamali both sons of Ghulam
Hussain Jamali, have administered the toxic Tablets to the
daughter of the complainant and put pretrol on her body and
set fire on her person,
[3]
brunt away, the complainant was available on the same place,
after getting free, he came at police station and lodged present
FIR hence this FIR.

applicant/accused who is in jail custody, hence the present
bail application on the following grounds
-: G R O U N D S :-
100. That there are two versions of the FIR, firstly complainant
stated that her daughter has been brunt away and in the 2 nd
version he stated that he has got information by his son in law
that her daughter has been murdered by giving toxic tablets, and
in intoxication condition petrol was put upon her and she was
brunt away, so as per version of the son in law of complainant
Ashique Ali, he is not eye witness and he has not stated that such
incident has been seen by him or other but he has only put forth
story upon the appplciant accused with malafid intention.
101. That as per postmoretem report 40 percent body of the

deceased has been brunt, and further it is not alleged in the
Postmortem report that, poison was administered or
[4]
not but complainant on the basis of hearsay evidence has lodged
this false FIR with malafide intention just to implicate the
applicant accused.
102. That malafide part of the complainant is that he has stated

that only Ashique has stated that fire was set on body of the
deceased by applicant accused, but no single body from the
family members made to be witness of the case, and non from
any one have been seen that why in what manner she was brunt
so as per postmortem report it is clear crystal that she has been
brunt by her own way and allegation has been leveled against
the applicant accused with malafide intention.
103. That malafide part of the complainant is that, some hot words
already have been exchanged in between the complainant and
applicant accused, so complainant by managing this false story
and taking advantage of her deceased daughter has implicated
the applicant accused in this false case.
104. That incident as alleged in the FIR is silence, calm and quiet,
nothing has been proved against the applicant accused and there
is no substantiation against the applicant accused except hearsay
evidence , so as per settled principle law the hearsay evidence is
week type of evidence and is not value in eye of law and same is
not congent reason to implicate to any innocent person in any
false case thus-far it be indicated that each and every thing has
been managed by the complainant with malafide intention for
ultiror reasons.
[5]
105. That there is no proof on record of the police whereas during

the postmortem report and in the post mortem report it be
verified and indicated that due to shock of fire she has been
brunt and died away but it is not alleged that, due to poison she
has been died, nothing is available on record against the
applicant accused but complainant by managing this false story
has implicated the applicant accused.
106. That from the piece of investigation as per FIR section 302 has
been applied and as per challan section 322 PPC has been
applied on the applicant accused and same has been not proved
against the applicant accused.
107. That co accused has been released on 7-6-2017, under section

497 CR, PC, at the investigation stage due to lack of evidence, so
applicant is too entitle for the same sort of relief.
108. That as per Mashirnama dated 17-5-2017 and as per version of

the FIR, and statement of 161 Cr PC of the PWs there is distinct
and differentiate, versions are not matchable and same are
change.
109. That there is contradiction in story narrated in the FIR, while

applicant accused has no cocnenred with the alleged offence.
110. That at the time of incident applicant accused was not

available in the house, when the cries raised in the house the
applicant/accused who came house and saw his wife was
burning, and he in burning condition tried to rescue
[6]
her by extinguishing the fire from her body, and applicant

accused too became injured in rescuing his wife, so as per
version of the FIR, and facts of the FIR there is high
contradiction and each and every thing has been made and
cooked up very sharply by the complainant and his Pws.
111. That dated 7-6-2017, report of challn sheet has been submitted
under section 322 PPC but, besides police disclosed that offence
has been committed under ambits of 319 Katal-e-Khata, so it is
clear malafide part just to implicate the applicant accused in this
false case, otherwise, applicant accused has no cocnenred with
the alleged offence .
112. That section 302 PPC is not attracting to the present case and
section 337-J which is not ruled out and is misapplied, while
section 34 PPC is already misapplied and is not attracting to the
present case.
113. That in fact nothing has been committed by the applicant

accused, but, complainant by managing this false story with
connivance of his PWs has implicated the applicant accused just
to drag him in this false case and destroy life of the applicant
accused while he may put in behind the bars and rot the jail.
114. That there is very week type evidence on the hearsay basis
against the applicant accused, so as per contents of the FIR it be
verified that, applicant accused is innocent and he has been
roped in this false case.
[7]
115. That the applicant is not hardened criminal or desperate as

per instructions of the applicant/accused.
complainant


APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF 1st ADDITIONAL SESSION JUDGE
SHAHEED BENAZIRABAD
B. A. IN S.C No OF 2010.
1. Muhammad Ali son of Mehrab Jokhio

2. Imam Bux son of Mehrab Jokhio
3. Sain Bux son of Mehrab Jokhio
All confined in judicial custody……Applicants/Accused
VS
The State …………………………..…………………..Opponent

U/S 302, 324, 452, 342, 337-H(ii), 496A ,
494, PPC
Arising out of Direct Complaint Case
BAIL APPLICATION

applicants/accused, named above, that this Honorable Court
may be pleased to release them, on bail in the above
grounds:-
-: F A C T S :-

complainant, Allah Ditto Jokhio filed direct complaint against
applicant accused and 13 others in all 14 accused persons
tating theein that he has six sons and three daughters from
who Mst halima is aged abhout 18-19 and wedded with sain
Bux Jokhio whose Nikkah
[2]
was performed on 19-2-2006 but Rukhsati has nto taken place

and residing with him in his house, accused Sikandar Ali is
his relative and was annoyed due to dispute over money
matter and were not on talking terms with each other it is
further alleged that ON 19-11-2009 while complainant his
brother Luqman Jokhio, Ashraf Jokhio were present in his
house, at 8:00 PM accused Sikandar Jokhio with gun,
Muhammad Ali Jokhio having Pistol, Imam Bux Jokhio
having Lathi, Karim Bux Joikhio, Sain Bux Jokhio having guns
entered in his house and accused Sikanrdar Jokhio caught
hold his daughter Mst Haleema and dragged her, she raised
cries, on which his wife Mst Makhan grappled with Mst
Halima, on which accused Imam Bux Jokhio applicant caused
lathi blows to her on her head, who fell down by raising cry ,
whereas accused Sain Bux Jokhio gired from gun at his wife
which was missed, then accused Mehrab told complainant
that they will marry Mst Halima with sain Bux Johio and
dragging her daughter took her in Doston, she was raising
cries, on commotion and cries his brother Luqman, Ashraf
Jokhio and other nieghbouer were attracted and came on spot,
the complainant saw his wife Mst Makhan was having injury
over head and she was immediateldy taken to RHC Kazi
Ahmed through police letter and then he lodged the FIR,
crime No 286 of 2009, at police station Kazi Ahmed under
section 324, 496 A , 452 PPC, thereafter Mst Makhan was
shifted to PMCH Nawabshah from where she was taken to
Hyderabad for treatment and then brought to PMCH Hospital
where she remained unconcisous and on 16-12-2009 she died.
[3]
It is further stated that in the direct complainant the police did

not arrested the nominated accused in the FIR in the
meanwhile complainant came to know that On 17-12-2009
accused Sain Bux performed Nikkah with Mst Halima which
has been registered, through Mst Haleema was already
married which her Nikkah was performed in year 2006 and all
the accused persons with help of accused Sikandar, provided
shelter to the abductee and nominated accused persons and
police also avoding to challan the accused before court of law,
hence this direct complainant.
After holding the preliminary inquiry the direct complainant

has been brought on filed by the presiding officer, of this
Honou,rable court and N.B.W were ordered to be issued
against the accused thereafter, applicant accused along with
co –accused Muhammad Ali Jokhio has moved application for
pre arrest bail and he was granted interim pre arrest bail but
latter on his interim bail was not confirm by this Honourable
court and he was remanded to jail hence this bail application
on behalf of the applicants accused.
-: G R O U N D S :-
1. That the applicants/accused are innocent and they have been
falsely implicated by the complainant with the malafide

intention.
2. That applicants accused have been roped in this case with

[4]
3. That nothing has been committed by the applicants accused
but complainant by leveling allegation upon the applicants

accused has implicated them in this false case.
4. That according to the complainant her daughter Mst Haleema
was already married with applicant accused Sain Bux and her
Nikkah was performed On 19-12-2006 the copy of the said
Nikkahnama was produced by the complainant in direct
compliant case and during P.E which shows that the same
was regsiteed oOn 12-11-2009 after three years this proves
that the said Nikkahnama is forged and fabricated and
managed one.
5. That according to the complainant injured Mst Makhan was
admitted in hospital at Nawabshah then she was taken to

Hyderabad where she died and then brought to PMCH
Nawabshah where as according to the provisional medical
certificate issued by the MLO shows that the injured was
carried by the relative of patient to a private center Zohaib
Center Nawabshah, where she was operated and died,
whereas according to the death certificate issued by the
medical suprindetdent PMCH Nawabshah the patient was
operated at Hyderabad no name of hospital at Hyderahas is
shown in the said certificate, as there are different views and
versio of the above three medical certificates, which makes
whole case doubtful and benefit of doubt must go in favour of
the accused at the bail stage.
6. That during the investigation of the FIR crime No 286/2009
the police reached at the collusion that the
[5]
case is false it was therefore challan of the same was not

submitted well in time and lateron the complainant party
managed with I.O and not only this but the complainant
lodged the direct compliant with adition, altercation and
exaggeration with ulterior motives and is difference in the
story narrated in the FIR and direct complaint which makes
the entire incident doubtful.
7. That in fact Mst Haleema herself left the house and contracted
marriage Nikkah with applicant accused Sain Bux, due to this

complainant party was annoyed and managed story and
firstly lodged FIR and then this direct complaint.
8. That during investigation of the FIR crime No 286 of 2009 the
police reached at the conclusion that the case is false it was

therefore challn of the same was not yet been sumitted but
lateron the complainant party managed with I.O and not only
this but complainant has filed present direct complaint with
addition, altercation and exaggerations with the ulterior
motives.
9. That even the main eye witnesse namely Luqman and Ashraf
for which complainant stated in FIR as well in the direct

complaint that they were present at the time of alleged
incident has not been examined during P.E which makes the
whole case doubtful.
10. That the applicant accused were granted bail by this
Honourable court and they remained on bail and attending

the court since long but there is murderous entmity the
applicant accused party and Ali Raza
[6]
zardari party, and on such murderous enmity, Imam Ali

brother of the applicants, was murdered by the Ali Raza part
and such cases are pending at adjudication before this
Honourble court.
11. That Ali Raza party also mudered brother of Muhammad Ali
and one maternal nephew Arib murdered by the Ali Raza

Zardari party.
12. That such cases are pending before this Honourable court and
the Ali Raza zardari party again started blood shade, against
the applicants accused, therefore applicants accused
concealed themselves to save their lives and their family and
therefore the applicants accused could nto appear before this
Honourable court on sufficient dates hence this bail has bene
filed by the applicants accused.
13. That this Honoruable court has recorded evidence of the
complainant and that of alleged abdcutree and from the

evidence from the both pws it is clear stated that case has been
cooked and applicants accused have been roped for the utlrior
motives and if this Honoruable court look into evidence of the
witnesses and if this honourable court come just conclusion
that accused are innocent and has been neted by the
complainant party.
14. That applicants accused have possessed good reputation in
their vicinity but complainant by roping them has disgraced

in this false case otherwise, the have no concerned with the
alleged incident.
[6]


APPLICANT/ACCUSED
CERTIFICATE

IN THE COURT OF CIVIL JUDGE AND JUDICIAL

MAGISTRATE-I SAKRAND
B. A. No OF 2017.
Mir Hassan son of Atta Muhammad Rind

VS
Crime No. 147/2017, PS Sakrand

U/S 394, 34 PPC .
BAIL APPLICATION

grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, Raja

lodged his FIR at police station Sakrand, on 16-5-2017, at
about 1600 hours, alleging therein that, he is doing his service
in Nevy department, and he is on leaves for 12 days, and
came at his house, today complainant along with his cousin
nanmely Jameel Mal, and his brother namely Dildar in
gathering
[2]
departed from Saeedabad climbed in Bus to go nawabshah,

when at about 1030 hours, they reached sakrand City
Hyderabad Chowk sakrand, where due to bus breaker on the
road, where suddenly accused Dildar Rind Mir Hassan Rind,
Munwar Rind and one unknown acused person who have
been seen clearly and would be identified if seen again, they
climbed in bus, who all on coming, Dildar, Mir Hassan and
unknown accused persons having iron Rod, Munwar having
pistol, meantime Munwar aimed his pistol upon the
complainant and other accused persons snatched Metrolla
Altra Toch Screen Mobile from the complainant meantime
accused DIldar and Mir Hassan Iron Rod blows to the
complainant which hit him on his left side of arm and also
snatched amount of Rs. 2000/- from the complainant,
meantime other pessangers who rescued the complainant,
thereafter all accused got down from Bus and run away, then
complainant got treated him and went at police station lodged
the FIR.
After registering the FIR, police arrested the applicants

accused who is in jail custody, hence the present bail
-: G R O U N D S :-
120. That the applicant/accused is innocent and he has been

intention.
121. That in fact no such incident as alleged has ever taken
[3]
place, but complainant by managing false story has implicated

the applicant accused and other for the ultior motives.
122. That complainant neither shown prevous enmity nor he has

shown cause of injuries, without showing incident palusibily
has stated that only from the complainant things have been
robed including the amount so this thing is creating highly
doubt, which create malafide part of the complainant story
narrated in the FIR is nothing but same has been managed as
dramatically.
123. That robbed things containing the amount, as alleged have

been foisted upon the applicant accused just to make false case
otherwise applicant accused has no concerned with the alleged
offence.
124. That story narrated in the FIR is unbelieveable and

implausible.
125. That how it can be possible that, accused climbed on bus and
only robbed from the complainant, and then gave Iron rod
blows, so, and besides there is no independent witness except
sweet obligor of the complainant .
126. That malafide part of the complainant is that, how it can be

possible that, he at once identified the accused persons, and only
committed robbery from him, so it is indicating that, there might
have been prevous revenge of the complainant so just to take
revenge he has made this false story.
[4]
127. That complainant further stated that nothing has been robbed
from his cousin or brother but accused only committed robbery
from him so this thing creating highly doubt that present case is
nothing but due to some ulterior motives has been cooked up by
the complainant party.
128. That nothing has been committed but this whole story
narrated in the FIR is settled principle law that if the single doubt
arose in prosecution story then each and every doubt which goes
in favour of the applicant accused at bail stage.
129. That the applicant is not hardened criminal or desperate as

per instructions of the applicant/accused.

complainant


APPLICANT/ACCUSED
[5]
CERTIFICATE


BENAZIRABAD
B. A. No OF 2017.
Sabir son of Sultan Zardari

VS
Crime No: 192/2014, PS A section

Nawabshah
U/S 324, 353, 399, 402, PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, ASI

Jan Muhammad Mashori lodged his FIR at police station A
section Nawabshah, On 12-11-2014, at about 21:15 hours,
alleging therein that, today complainant along with C-
Azizullah, C Waqar Ahmed, C Ahmed Ali, with police
ammunition, on the police
[2]
mobile No. 1 along with driver sikandar Ali, under the entry
No. 28/12-11-2014, at about 1830 hours, complainant party
departed for patrolling various places , when they reached
Buchehri Road Nakka, which leads to Link Road of Sugar
Mill Phatak, when at about 2000 hours, they reached at village
Tarique Arain, where on the light of the vehicle, complainant
party saw 6 pesons with intention to commit offence were
standing at orad, who by making unlawful assembly were
standing there, they have been seen on the light of the mobile,
which to be each Sabir Zardari, Sadam Chandio, Ghulam
Nabi, Asif Ali, Jameel Rind, who by sensing private vehicle to
police mobile tried to rob, police alarmed them and tried to
apprehend them, who deterred the police party to perform
their duty and made straight firing upon police, the police in
their defense by taking position made defensive firing,
thereafter all accused persons by making fires and taking
advantage of darkness went away, all accused persons by
making unlawful assembly with intention to commit offence
were standing there and made firing upon the police, hence
this FIR was lodged.

-: G R O U N D S :-

intention.
[3]

place, but complainant by managing false story has
implicated the applicant accused and other for the ultior
motives.
398. That complainant has been hired by the ruling party to

lodge false FIR and implicate the applicant accusd and others.
399. That malafide part of the complainant is that, there is no
single scratch or mark hit to the police mobile during the
firing and no single mark or scratch is on the person of the
police party, or accused persons so with this regard, it be
indicated that, each and every thing has been made
dramatically and story has been put forth by the complainant
with malafide intention for the ultior reasons.
400. That complainant has not stated that how much fires
has been made by complainant and his PWs but complainant
by making this false story has implicated the applicant
accused and others.

stated in the FIR that, accused skipped away by making firing
but complainant failed to went behind them and arrest them ,
so it be verified that each and every thing has been cooked up
by complainant every sharply and craftly with malafide
intention just to implicate the applicant accused in this false
case.
402. That story narrated in the FIR is stereotyped and
[4]
complainant has malafidly implicated the applicant accused just

to drag him in false case so that he may come in their terms.
403. That there is specific role part injury assigned to the

applicant accused mere there are general allegation.
404. That firing has been shown eniffective, as per contents
of the FIR section 324 PPC has been misapplied and is not
attracting to the present case.
405. That section 324 PPC is not attracting to the present case
and other section applied in the FIR doenst fall within the
prohibitory clause ,of section 497 Cr, PC.
406. That it is settled principle law that if the single doubt

arose in prosecution story then each and every doubt which
goes in favour of the applicant accused at bail stage.
407. That the applicant is not hardened criminal or desperate

as per instructions of the applicant/accused.

complainant

[5]

arguments.

APPLICANT/ACCUSED
CERTIFICATE


NAWABSHAH
B. A. No OF 2015.
1. Saleh son of Loung Khan

2. Rustam son of Qaim Khan
Both by caste Rahejo R/O Deh 17 Dad
Taluka Nawabshah District Shaheed
Benazirabad …………………..……….Applicants/Accused
VS
Crime No: 70/2015, PS Taluka

Nawabshah
U/S 447, 506/2, 114, 504, 147, 148 PPC
.
BAIL APPLICATION

applicants/accused, named above, that this Honorable Court
may be pleased to release them, on bail in the above
grounds:-
-: F A C T S :-

Ghulam Hyder lodged his FIR at PS Taluka Nawabshah, On
1-12-2015 . at about 21:30 hours, alleging therein that , land of
cousin of
[2]
complainant namely Sawali Zardari and brother of
complainant namely Akbar Zardari is adjacent in 17 Dad, they
all in gathering sold out their land S No 8/4, area 3-34 Acres
to Zanwar Niaz Rahejo, in sum of Rs 56,00,000/- on the sale of
land, namely Arbab Rahejo and his relative disagreed with
complainant party, that complainant should sale out thier
land to them otherwise they will not allow to complainant
party to sale out to another party, and standing crop of
sugarcane etc will be restricted and their lande will be
dispossessed, On 30-11-2015 he along with his brother AKbar
Zardari and cousin Sawali son of Mureed Zardari, and
Zanwar Niaz son of Khuda Bux Rahejo were went to take
corp of sugarcane crop, when at about 11:00 AM, complainant
party saw each Haji Arbab with gun , Din Muhammad with
rifle, Rajab with pistol, Rustam with pistol, Saleh with gun,
Eidan with hatchet and some 4/5 unknonw accused with
lathies and hatchet came there, out of them one Haji Arbab
Rahejo said that, they will purchase this land and they will
not allow the complainant party to sale out ther same land to
Zanwar Niaz Rahejo , meantime he instigated to his other
companions to dispossess the land , meantime all accused by
dispoessing the land of complainant seated there, who by
aiming their weapons upon complainant extended
murderious threats to complainant to go away from the land,
otherwise they will be killed, thereafter complainant party
due to fear of weapons remained silent and returned back,
thereafter complainant made consultation with each other and
came at PS and lodged present FIR.
[3]
-: G R O U N D S :-
411. That the applicants/accused are innocent and they have

been falsely implicated by the complainant with the malafide
intention.
412. That there is delay in lodging the FIR for about 1 day in
lodging the FIR which is unexplained.

FIR has ever taken place but compliannat with malafide
intention by showing false story has implicated the applicants
and others in present FIR otherwise applicants/ accused have
no concerned with the alleged offence.
414. That in fact no such incident has taken place but actual
facts are that, the land and residential houses of applicant
party are adjacent land of the complainant party, whereas
complainant are person of shrwed type and they are
belonging to ruling party, therefore they by exerting pressure
upon the applicant have created troubles for applicant party,
to vacate the land, houses premises, while they easily
dispossess the whole property of the applicant party,
otherwise applicants have no
[4]
committed such offence and they are not concened with alleged
offence.
415. That prior to registration of FIR, the complainant and

his supporter so many time launch attack upon the applicant
party and they so many time maltreated the applicants party
to come in their illegal ande unwarranted promises otherwise
life of the applicants and others will be destroyed and they
will be implicated in false cases, evne applicants party have
been implicated in this false and factitous case.

verified from the facts that, complainant party shown huge
number of persons with deadly weapons, but how it can be
possible that having the superior number of the persons with
deadly weapons, the coud not made single fire upon
complainant party , so looking to the circumstances it be
indicated that whole story has been managed by the
complainant, with core consultation of his sweet obligor
witnesses.
417. That complainant with collusion of the Niaz Rahejo

have knowingly and intentionally roped the applicant party
in this false case and Niaz Rahejo has excited to complainant
party to implicate the applicant party and others in false case
while they may vacate the land and houses premises.
418. That nothing has been committed but whole drama has
been staged by the complainant with core consent of his
sweet obliger
[5]
419. That offence as alleged in the FIR is stereotyped and
complainant has malafidly implicated the applicants accused
just to drag them in false case so that they may come in their
terms.
420. That there is no role, part or injury on the person of

complainant, which can be verified in commission of the
offence, but complainant by choosing false story has booked
the applicants and others in this false case.
421. That all sections cited in the FIR doesn’t fall within the
prohibitory clause of section 497 Cr PC.
422. That no incriminating is pertaining with the applicants

accused but complainant by taking advantage of false story
has implicated the applicants/accused.

nor there is previous criminal record against them as per
instructions of the applicants/accused.

complainant

evidence as applicants/accused are ready to furnish solvent

arguments.

APPLICANTS/ACCUSED
[6]
CERTIFICATE

on behalf of the applicants/accused prior to this no any bail or
other case has been filed by the applicants accused before this
Advocate for Applicants/accused

BENAZIRABAD
B. A. No OF 2015.
Atta Muhammad son of Loung Khoso

Presenlty confined in District Jail Shaheed
Benazirabad …………………………………..……….Applicant
VS
Crime No: 10 /2014, PS Kazi Ahmed

U/S 399, 402 PPC .
BAIL APPLICATION

grounds:-
-: F A C T S :-
Syed Laiq Hyder lodged his FIR at PS Kazi Ahmed, On 17-1-
complainant along with his subordinate staff , with poice
ammunition, on police
[2]
mobile NO 3578, along with driver, departed for patrolling,

various place when the police party leading and protloing
from N.W.S and leading from Sarkari Khooh, they were
coming towards Kazi Ahmed, when at about 22:00 Hours near
Nursery Stop, they saw on the light of Police Mobile and on
light of passerby, about 19 persons emerged from Nursery
and they came at road side, who by aiming their weapons
upon complainant and signaled to stop with intention to
commit offence, the HC Abdul and PC Abdul hameed
identified them on light of the vehicles which to be each
Waheed, with gun, Allah Dad with KK, Illahu with KK,
Khanzada with KK, Lalo with KK, Hafiz with KK, Mustafa
with KK, Barkat with KK, Muhammad Malooq with pistol,
Bashir with Pistol, Haji Mallah with repeater , Sahib Jokhio
with Repeater, Mushtaque Manio with Pistol , Atta
Muhammad with pistol, Saiful with KK, Kheru with repeater,
Atta Muhammad with Pistol, Muneer Khoso with Pistol, the
complainant party at once stopped their vehicle and tried to
apprehend the accused persons, the accused by seeing the
police in police uniform they run away towards eastern side
in nursery, thereafter, complainant party brought,
governmental foot tracker and took foot prints, which missed
on Pubjo Link Road, thereafter complainant party returned
back and lodged present FIR.
After registering the FIR, police arrested the applicant
[3]
-: G R O U N D S :-

intention.

intention by showing false story has implicated the applicant
and others in present FIR otherwise applicant accused has no

vierfied from the facts that as per contents the complainant
shown that accused with deadly weapons but they could not
made a single fire upon complainant in their defence nor
complainant party made a single fire to perform their duty
honestly but complainant only shown his malafide with
intention to rope the applicant and other in this false case so
that a,pplicant may come in his terms .
430. That there is no specific role part or injury assigned to

the applicant accused but there are general allegation of
attempt to commit offence which is unbelievable and such
story made with consultation of each other of police officials.
431. That nothing has been committed but whole drama has
been staged by the complainant with core consent of his
sweet obliger staff.
[4]
432. That offence as alleged in the FIR is stereotyped and

complainant has malafidly implicated the applicant accused
just to drag them in false case so that they may come in their
terms.
433. That section 399 PPC is not punishable more then 10

years and nor less then 4 years which, as per story has been
misapplied and section 402 which is not attribuging to the
present case due to false and fabricated story made by the
complainant which is not implausible.
434. That there is no role which can be verified in

commission of the offence, but complainant by choosing false
story has booked the applicant and others in this false case.
435. That no incriminating is pertaining with the applicant

has implicated the applicant/accused.

nor there is previous criminal record against him as per

complainant
evidence as applicants/accused is ready to furnish solvent
[5]

arguments.

APPLICANT/ACCUSED
CERTIFICATE


P/2…
Complainant and othe restrained whom, but to no avail, on
which whose wife Mst Naseem Bibi become annyed and took the
hatchet and caused straight hatchet blows to the broher of
compliannat on his head and her daughter to rescue herself aused
whome Danda blows on back and other part of person, on the hue
and cries complianant’s relative Muhammad Yaseen arain and
Yousif Bhatti Rajput arrived but due to lot of bleeding
complainant’s brother passed away in the house, complianant then
with the help of above named PWs brought corpse of his brother at
PMCH Nawabshah and after completing legal formalities brought
the daed body at home and afer free from funeral rites complainant
ame at PS and lodged present FIR .
After registration of FIR applicant accused was arrested and
presently conined in Jail , hence this bail a,pplication on the
following grouinds.
GROUNDS
1) That applicant is in jail and has minor chidlen and in case if bail
is not granted to the applicant/accused the lives as well as future
of minor chidlen will be ruined as there is no any elder member
to look after the minors.
2) That it is also worthwhile to mention here that false hood of the
case of complainant can be judged that in fact the police released
nominated accused Mst Saima under section 497 Cr PC, therefore
the case of the applicant accused is also requires one of further
inquiry, due to circumstances of the case.
P/3…
3) That complainant as well as other legal heirs/brother of
deceased have also sworn their no objection affidavits for the
grant of bail to the applicant/accused due to intervention of their
neckmard the faisla was held between them and they have
excused the accussed in the name of Almighty Allah.

4) That applicant accused is not a previouis convict as per
instruction
5) That case has been challaned and applicant /accused is in jail
hence she is no more requires police for further investigating
purpose .
6) That applicant accused is prepared furnish solevent surety to
satisfaction of this Honourable court .
7) That other grounds will be urged at the time of arguments
CERTIFICATE


BENAZIRABAD
B. A. No. of 2015.
The state
VERSUS
Mst Naseem Bibi
Crime No: 95/2015, P.S, B

Section Nawabshah
OFFENCE U/S 302 34 PPC
AFFIDAVIT
I , Zafar Irshad son of Abdul Hameed Arain Adult

Muslim R/O Ali Raza Shah Colony Line Par Nawabshah
district Shaheed Benazirabad , do hereby state on oath as
under:-
1] That I am one LRs and brother of deceased namely Zafar Iqbal

hence fully conversant with the facts of the same.
2] That accused is wife of my brother and she has minor chidlen

saima, Shahzad, Samra, Samreen, Muqadas, Noor Eman and
Ali Raza, we have compromise in the above case with accused
Mst Naseem due to intervention of our neckmards to promote
better relations in society.
3] That I have forgiven the accused in the name of Almighty

Allah on my behalf I have no objectin if bail is granted to
accused.
4] That I am swearing this affidavit on my own free will and

ccord.

Advocate

BENAZIRABAD
B. A. IN SC No OF 2014.
Abdul Rasheed son of Noor Muhammad Durani Pathan

Benazirabad …………………………………..
…………………….Applicant
VS
The State …………………………..

………………………………..Opponent
Crime No: 157 /2014, PS A Section

Nawabshah
U/S 324, 337—H(ii), 506/2, 504, 34
PPC .
BAIL APPLICATION
applicant/accused , named above , that this Honorable Court
may be pleased to release him , on bail in the above
grounds:-
-: F A C T S :-

Jabbar Shah lodged his FIR at PS A Section Nawabshah, ON
10-8-2014 at about 14:30 hours, alleging therein that, he
reissiding at above mentioned address namely Abdul
Rasheed son of Jan Muhammad , Imran durani all sons of
Noor Muhammad R/O Pathan Colony Nawabshah, are
residing in their neighbor , who are persons of define nature,
and they used to stay diffirent persons, complainant and his
sno KHair Muhammad aged about 34/35, prohibited them to
not use to stay bad persons at there, on which all accused
were seriously angered with complainant party and were
threatening the
[2]
compliannat party that they will see the complainant party.

On 5-8-2014 complianant and his son khair Shah and nephew
Muammad Azam son of Rehmatullah, Ghulam Nabi alias
Bugti son of Abdullah Durani Pathan resident Pathan colony
Nawabshah were going to their house from city, when at
about 11:30 hours they reached near street of their house,
where they saw above mentioned accucsed Abdul Rasheed
Durani Pathan, Jan Muhammad Durani Pathan, Imran durani
Pathan were already standing there, out of them one
unknown accused was standing who will be identified if seen
again , they controlled over the complainant party and all
accused pointed out their pistols they threatened that
complainant party have prohibited them on staying of the
friends towards there, so today they will see them, by saying
so, and extended abuses to the complainant party, meantime
accused made straight firing upon son of the complainant
namely Khair Shah which hit him on left side of leg and Jan
Muhammad made straight upon right side of arm of the
complainant’s son, and who by making cries fallen down and
blood was oozing, thereafter all accused persons just to harass
the compliannat party they went to weastren side towards
street side , therafter complainant shifted the injured towards
PMCH for treatment and after getting free, he came at PS
regsiered present FIR.
After registering the FIR, applicant accused was

arrested, who is in jail custody , hence the present bail
-: G R O U N D S :-

intention.
441. That in fact there is in ordinae delay in lodging the FIR 5

days without any plausible explanation which goes to show
tha the same has been registered after consultaion and
deliberation as such false implicaton of the applicant accused
can not be ruled out.
[3]
intention by showing false story has implicated the applicant
and others in present FIR actual facts are that dispute in
between the both parties is existed since long therefore
compliannat by managing a false story by showing the name
of the applicant and others has involved them in present case
otherwise applicant accused has no concerned with the
present case.

shown that accused made straight firing with intention to
commit murder of his son but no a single person was
associated there as to be witness of the case otherwise
applicant/accused has no concerned with the alleged
offence .

shown that accused made firing upon son of the complainant,
but complainant and his nephew remained secure and no
single scretch is existed on the persons of the complainant.
445. That no incriminating is pertaining with the applicant

has implicated the applicant/accused.
446. That the case has been challaned and applicant/accused

is no more required to police for further investigation.
447. That section 324 is misapplied there is no part, overt act

and porbablity of the incrimainting but complainant just to
get ill-repute and by showing a false incident take good
advantage implicating the applicant otherwise applicant has
no cocnerend with the alleged offence.

nor there is previous criminal record against him as per
[4]
449. That after registering of the FIR applicant is under jail

custody.

complainant


arguments.

APPLICANT/ACCUSED
CERTIFICATE


BENAZIRABAD
A.B. A. No OF 2015.
1. Gulbaig
2. Abdul Hameed
Both sons of Sultan
3. Gulbahar son of Gulbaig
R/O Village Muhammad Khan Dahri
Deh 6 Nusrat Taluka Daur District
Shaheed Benazirabad ………………………………..
……….Applicant
VS
The State ………………….………..…..

……………………………..Opponent
Crime No: 1 /2015, PS 60th Mile
U/S 506/2, 34 PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

Moula Bux son of Dur Muhammad Mari. On 4-1-2015 at about
14:00 hours, alleging therein that, complainant is running
business of saling and purchasing the motorcycle, whereas
due amount of Rs 81,000/- of the complainant were rested
against Gul Baig, in regard of said amount complainant used
to visit to gul Baig and requesting him to pay the amount, on
which he annoyed and was threatening that he will see the
complainant. On 5-12-2014 at about 3:00 PM noontime,
complainant and Mir Muhammad son of Jumo khan Mari,
Mureed son of Sahib Khan Mari, were coming from Umar
Bhurat Hotel Near Sadah Wah, they saw each Gul Baig,
Gulsher, Abdul hameed all sons of the Sultan, Gul Bahar
[2]
son of Gul Baig all by caste Ujjan all Reisdent of Village

Muhammad Khna Dahri Deh 6 Nusrat Taluka Duar were
standing there, meantime complainant met with Gul Baig and
demanded his due amount, on which he extend hot words
meantime Gulsher pointed out his pistol from fold of his
shlawar, which aimed upon complainant and threatened that
if the complainant ever demand hi amount then he will be
killed and today they will see him, meantime Gul Bahar got
fallen downt to complainant, Abdul majeed gve kicks fists
blows to the complainant, meantime, witness of the
complainant and present were sitting at hotel they rescued the
complainant by giving the name of Almighty of Allah,
thereafter complainant approached to Honourable sessions
judge for registering the FIR and which was transferred to 1 st
Addj, Sessions Judge, who issued Order No 4032 dated 29-12-
2014, thereafter complainant after getting order came at PS
and lodged present FIR.
After usual investigation, the applicant/accused was

arrersted, who is in judicial custody, hence the present bail
-: G R O U N D S :-

intention just to show his efficiency otherwise nothing
incriminating has been secured as alleged from the
applicant/accused.
454. That admittedly there is delay in lodging the FIR for

about one month without any plausible explanation which
goes to show that the same has been lodged after deliberation
and consultation as such false implication of the
applicant/accused in present case can not be ruled out.
455. That no such incident whatsoever stated in the FIR has

ever taken place but compliannat with malafide intentin for
the utlrior reason have implicated him in false case, actual
facts are that complainant is persnos of greed type and has
highly influence
[3]
sources, he by applying his sharp mind and looking to the

poor condition of the applicant accused was coercing and
pressurizing the applicant without any bad acitivites so that
he may come in his illegal demands and other terms, therefore
applicant looking to the apprehension of complainant co
accused Gul Baig brother fo the applicant accused got
protection order on 25-9-2014 by sessions judge Shaheed
Benazriabad
456. That it is malafide on the part of the complainant that

he after getting order On 29-12-2014 of loding the FIR from
Honourable 1st Additional Sessions Judge, he approached at
PS with inordinate deslay of 6 days thus case of the
compliannat is managed one.
457. That in fact no such incdietn whatsoever stated in the

FIR has taken place there are general allegation against the
applicant accused, whereas it is indicated from version of the
FIR that same FIR has been lodged by complainant just to
pressurizing him otherwise applicant accused has no
458. That applicant has possessed good reputation but

complainant without any plausible explanation has falsely
implicated the applicant accused/
459. That there is no direct role or attributing of the offence

but compliannat just by showing his efficiency has
implicated him in false case.
460. That section applied in the FIR don’t comes within
prohibotry clause of section 497 Cr PC .
461. That section 506/2 is misapplied in the FIR which is part

of the malafide by the complainant.

evidence as all the PWs are interested witness of the
complainant .
463. That the applicant/accused is ready to furnish solvent

[4]

arguments.

APPLICANT/ACCUSED
CERTIFICATE

application on behalf of the applicant/accused prior to this,
no bail or other case has been filed by the applicant/accused
before this Honourable Court.
ALLAH BUX SHAR

IN THE COURT OF JUDICIAL MAGISTRATE & FAMILY
JUDGE NAWABSHAH
B. A. No OF 2015
Gulzar alias Guldar son of Punhal Mallah

presently confined in Sub-Jail Sakrand …………..
……….Applicant
VS
The State ………………….………..…..…….

………………………..Opponent
Crime No: 7/2013, PS Mehrab Rahu

U/S 337-A(ii) H( ii), 148 , 149 , 506/2,
504 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-

Sajjan Mallah lodged his FIR at PS Mehrab Rahu, alleging
therein that he is doing Harap , whereas there is dipute with
his relative Master Muhammad Hussain over the agricultural
land. On dated 17-11-2013 he along with his brother Arbab Ali
and relative Shaman were going towars Kazi Ahmed on his
motorcycle, when at 2:00pm they reached at Link Raod Razi
Jaoti near, land of Anwar Jatoi they saw Master Muhammad
Hussain having lathi in his hand, Wali Dino having pistol in
his hand, Ghulam Ali having pistol in his hand, Muhammad
Qasim having hatchet in his hande Sajjid Ali alias Rakho
having pistol in his hand, Mir Muhammad having hatchet , all
resident of village Qasim Mallah Taluka Kazi Ahmed and
Guldar hving repeater, and two unknown persons having
hatchets in their hands, and they have been seen clearly and
[2]
would be identified if seen again, they were standing there ,

meantime Master Hussain gave signal to stop them, the
complainant party stopped their motorcycle and got down
from their motorcycle, the accused Master Hussain by seeing
the complainant extend abusive language, and told that they
are not removing the dispute over the land so today they will
see them , by saying so , he caused lathi blows to complainant
which hit him on his neck, head and blood was oozing from
the nose of the complainant, and other other accused made
aerial firing just to put the compliannat in pressure, then
complainant party beseeched them and thereafter they while
issuing abuses went away, the complainant party straight
their weapsons and told that today they have left them and if
again if they made any complain against them then they
would be killed, thereafter all accused went towards the
notthren side in sugarcane crop, meantime complainant was
bleeding at he came at PS Mehrab Rahu wherefrom he got
letter for medical treatment and thereafter he went towards
rural hospital at Kazi Ahmed where he got treated hisemlf,
after getting free he came at PS where he lodged present FIR

arrersted, who is in Jail custody, hence the present bail before
this Honourable court on behalf of the applicant accused, on
-: G R O U N D S :-

intention .

about 5 days without any plausible explanation which goes to
show that the same has been lodged after deliberation and
consultation as such false implication of the
[3]

facts are that enmity in between the complainant and Master
Muhammad Hussian Mallah is existed even that parties
relative inter-se .
468. That after registering of the FIR and submitting the

challan that the complainant and accused master Muhammad
Hussain Mallah and other co accused are patching up thier
dispute in the shape of filling compromise before this
Honourable court.
469. That after filling the compromise the Honouirable court

has been release/acquitted the co-accused Muhammad
Hussain Mallah and others on 12-9-2014 , while the case
against the applicant accused is pending before this
Honourable court for further proceeding.
470. That due to malafidly of the complainant with collusion

of the police officials arrested the applicant accused now he is
confined in Sub-Jail Sakrand and invesgiation has been
completed during invesgation nothing has been recovered or
secured from the possession of the applicant accused of
incriminating articles.
471. That the allegation against the applicant is general in

naute according ot the facts of the FIR thre is no specific role
assigned to the applicant accused, the complainant has been
received injury in the hands of co-accused Muhammad
Hussain Mallah the section 337_A(ii) is not attracting to the
present applicant accused.
472. That case is fit for further inquiry as the main accused
and complainant has been patched up their dispute in the
shape of compromise and they have no more grudge, now the
present accused is behind the Bar, having the compromise in
between the parties the applicant is entitle for the cocession of
the bail.
473. That, sections applied in the FIR which doesn’t fall

within the prohabatity clause of section 497 Cr PC.
[4]

475. That the applicant accused was not aware about his
implication or his name which to be given in present case by
the complainant, when police has been arrested to the
applicant thereafter first time he was informed through the
police about the involvement in present FIR.

complainant.


arguments.

APPLICANT/ACCUSED
CERTIFICATE

no bail has been filed by the applicant/accused before this
Honourable Court.
ALI HASSAN LUND

IN THE COURT OF CIVIL JUDGE JUDICIAL

MAGSITRATE –II SAKRAND
B. A. No OF 2015
Shahid son of Muhammad Ibrahim Arain

presently confined in Sub-Jail Sakrand …………..
……….Applicant
VS
The State ………………….………..…..…….

………………………..Opponent
Crime No: 01/2015, PS Sakrand

U/S 506/2, 34 PPC.
BAIL APPLICATION
grounds:-
-: F A C T S :-

Waheed Murad lodged his FIR at PS Sakrand, on 4-1-2015 at
about 16:00 hours, alleging therein that, complainant is
running business of salling and purchasing Banana crops, one
namely Shahid Arain son of Muhammad Ibrahim resident of
Sahiwal Punjab present Malak Colony Nawabshah, some 2 ½
years back he purchased Banana crops from complainant in
sums amount of Rs. 6,25000/- in respect of above amount
complainant used to visit to him for receiving the amount but
he was keeping him on hollow hopes. On 2-1-2015,
complainant, alongwith Ghulam Abbas, Mushtaque son of Ali
Sher Khoso were sitting at Jeo Goods transport’s company at
Sakrand, whre at about 2:00-noontime, one white colour
Corolla car came there, in which persons got down which to
be Shahid
[2]
Arain, Yaseen both sons of Muhammad Ibrahim Arain,

Zulfiqar son of not known Arain all permanently resident of
Sahiwal Punjab presently at Malaki Colony Nawabshah town,
they all came towards the complainant, meantime all accused
pointed out their pistol from their fold of shalwar and aimed
upon complainant and said that if the complainant ever
demanded his amount then he will be killed, meantime above
witnesses of the complainant beseeached the accused persons,
thereafter all accused went away towards Nawabshah twon
side, thereafter complainant narrated whole facts with his
relative who advised him to lodge the FIR hence this present
FIR

arrersted, who is in Jail custody, hence the present bail before
this Honourable court on behalf of the applicant accused, on
-: G R O U N D S :-

applicant/accused.

about 2 days without any plausible explanation which goes to
show that the same has been lodged after deliberation and

highly influence sources, he by applying his sharp mind and
looking to the situation he with bad activities and with dint
of sheer force is coercing and pressurizing the applicant , so
that he may come in his illegal demands and other terms,
actual facts are that
[3]
applicant accused is residing at Karachi and labouring in

Kashif Cotton factory and permanently residence of applicant
is Chak No 74-4 at Sahiwal Punjab, but complainant withouit
beneficient and mercy has implicated the applicant accused in
present case otherwise applicant accused has no concerned
482. That no single paisa or is rest or due against the

applicant accused and such amount mentioned in the FIR by
the complainant is only body of the facts just to form the
contents of the FIR otherwise applicant accused has no
cocnerend with the alleged offence as such amount allegedly
has been foisted upon the applicant accused.


485. That there is no direct role or attribution of the offence

but compliannat just by showing his efficiency has implicated
the applicant accused in this false case.
486. That section 506/2 PPC is misapplied in the FIR which

is part of the malafide by the complainant and seciotns which
too doesn’t fall within the prohibitory clase of section 497 Cr
PC.

complainant.

[4]

arguments.

APPLICANT/ACCUSED
CERTIFICATE

ALLAH BUX SHAR

MAGSITRATE –II NAWABSHAH
B. A. No OF 2015
Gulsher Ujjan son of Sultan Ujjan

presently confined in District
Jail Shaheed Benazirabad ………………………………..
……….Applicant
VS
The State ………………….………..…..

……………………………..Opponent
Crime No: 1 /20154, PS 60th Mile

U/S 506/2, 34 PPC.
BAIL APPLICATION

grounds:-
-: F A C T S :-

Moula Bux son of Dur Muhammad Mari. On 4-1-2015 at about
14:00 hours, alleging therein that, complainant is running
business of saling and purchasing the motorcycle, whereas
due amount of Rs 81,000/- of the complainant were rested
against Gul Baig, in regard of said amount complainant used
to visit to gul Baig and requesting him to pay the amount, on
which he annoyed and was threatening that he will see the
complainant. On 5-12-2014 at about 3:00 PM noontime,
complainant and Mir Muhammad son of Jumo khan Mari,
Mureed son of Sahib Khan Mari, were coming from Umar
Bhurat Hotel Near Sadah Wah, they saw each Gul Baig,
Gulsher, Abdul hameed all sons of the Sultan, Gul Bahar
[2]
son of Gul Baig all by caste Ujjan all Reisdent of Village
Muhammad Khna Dahri Deh 6 Nusrat Taluka Duar were
standing there, meantime complainant met with Gul Baig and
demanded his due amount, on which he extend hot words
meantime Gulsher pointed out his pistol from fold of his
shlawar, which aimed upon complainant and threatened that
if the complainant ever demand hi amount then he will be
killed and today they will see him, meantime Gul Bahar got
fallen downt to complainant, Abdul majeed gve kicks fists
blows to the complainant, meantime, witness of the
complainant and present were sitting at hotel they rescued the
complainant by giving the name of Almighty of Allah,
thereafter complainant approached to Honourable sessions
judge for registering the FIR and which was transferred to 1 st
Addj, Sessions Judge, who issued Order No 4032 dated 29-12-
2014, thereafter complainant after getting order came at PS

arrersted, who is in judicial custody, hence the present bail
-: G R O U N D S :-

applicant/accused.

about one month without any plausible explanation which
and consultation as such false implication of the

highly influence
[3]
sources, he by applying his sharp mind and looking to the

poor condition of the applicant accused was coercing and
pressurizing the applicant without any bad acitivites so that
he may come in his illegal demands and other terms, therefore
applicant looking to the apprehension of complainant co
accused Gul Baig brother fo the applicant accused got
protection order on 25-9-2014 by sessions judge Shaheed
Benazriabad
493. That it is malafide on the part of the complainant that

he after getting order On 29-12-2014 of loding the FIR from
Honourable 1st Additional Sessions Judge, he approached at
PS with inordinate deslay of 6 days thus case of the
compliannat is managed one.

implicated the applicant accused/
496. That there is no direct role or attributing of the offence

but compliannat just by showing his efficiency has
implicated him in false case.
497. That section applied in the FIR don’t comes within

prohibotry clause of section 497 Cr PC .
498. That section 506/2 is misapplied in the FIR which is part

of the malafide by the complainant.

complainant .

[4]

arguments.

APPLICANT/ACCUSED
CERTIFICATE

ALLAH BUX SHAR

BENAZIRABAD
A. B. A. No. of 2014.
Wazeer son of Muhammad Bux jatoi

R/O Village Lakhat Taluka Sakrand District
Shaheed Benazirabad presently Confined
in district Jail Shaheed Benazirabad …………
Applciant/accused
VS
The State
…………………………………………………………..Opponent

OFFENCE U/S 324, 353, 148, 149 PPC


applicant/accused, , that this Honorable Court may be
pleased to admit him , on bail in the above case/crime on the
-: F A C T S :-

SIP/SHO Ghulam Shabir Sahito lodged his FIR at PS Lakhat
on 10-12-2014 at about 22:00 hours, alleging therein that on the
day of incident complainant party were present at PS and
received spy iformation that accused involved in crime No
5/2014, under sectin 7 ATA 302, 385, 404, 363 , 148, 149, 337-
H(ii) PPC. Of PS Lakhat, are sitting at the landhi of accused
Gulzar Jatoi and others, and abbductee Mansoor Ali is
available there, the compliainant after receiving such
information he got informed to their higher Officer DSP
Lakhat , thereafter complainant alonwiht his staff, containing
[2]
the ammunition on police mobile No SP-6887 under entry No

12 dated 10-12-2014 at about 16:00 hours when they reached
village Lakhat where they treid to make private mashirs
which Ghulam Nabi son of Haji Ismail Jatoi , Ashqiue Ali son
of Zanwar yaqoob jaoti all R/O Lakhat Taluka Sakrand police
taken with them and came at Bacha Pand at Lakhat, Maqbool
Ahmed DSP Lakhat alognwiht his staff, on police mobile, SIP
SHO Dodo khan Rahu PS Khah with staff and containing the
ammunition came there SIP Jam Farhad Khan IC Nawab Wali
Muammad with their staff and containing the ammunition ,
SIP SHO Ahmed Khan Khaskhlei of PS Ali ABad with his staff
on government vehicle containing the ammunition came
there, with direction of the DSP Maqbool Ahmed Memon the
complainant party approached at Landi of Gulzar jatoi near
Katcho Bailo, after arrival compliannat party got down from
their mobile and they saw accused each Gulzar , Kirar alias
Wazeer, Akuldar all sons of Mehmood, Saiful alias Baghi ,
Sikandar, Ghulam Sarwar all sons of Kandero , Punhoon Haji
Deedar alias deedu Adnan alias Soomar alias Porho all sons of
Bahadur, Rustam Shahnawaz, Ghulam Qadir alias Bhoori,
Mehmood alias Porho , all sons of Shafi Muhammad, Wazeer
and Ghulam Rasool boths Muhammad Bux , Kabootar son of
Pathna , Nazeer son of Wazeer alias Kirar Jatoi all resident fo
Lakht Taluka Sakrand , Nazeer Muneer Hussain both sons of
Illahi Bux caste tunio R/O Sobho Dero all armed with KKs ,
who by seeing the police party in uniform they made straight
firing upon them with intention to commit murder, the police
party by taking position also made firing in their defense,
such encounter continued about 30 mintues therafter police
party went towards Landhi side where they saw accused
involved in crime No 5/2014, under sectin 7 ATA 302, 385,
404, 363 , 148, 149, 337-H(ii) PPC. Of PS Lakhat , they saw
Abductee Mansoor Ali son of Ghulam Shabir Jatoi was
weeping there, the privte mashirs also informed the
complainant party that is Abductee Mansoor Ali who was
abducted by accused persons, thereafter complainant went
behind the accused persons but they run away by taking the
advantage of Jangle, thereafter mashir each Ghulam Nabi and
Ashqiue Ali Jatoi disclosed the names of the accused persons
to be above detailed, thereafter
[3]
complainant party made the mashir before the privates

mashirs and came at PS where they lodged FIR by stating
therein that accused have detttered the complinant party to
perform their duty thereafter complainant lodged above FIR
whereas complainant from his SMG fired 30 Bullets and
further other officer will disclosed in their statement hence
this FIR.
After registering of the FIR , the police of PS Lakhat is behind

the applicant hunting for the applicant finding him not there
have left the threats to come again to arrest him, hence thereis
great apphrension of his imminent arrest therefore applicant
surrederned himself before this Honourable court , on the
following grounds.
-: G R O U N D S :-
502. That the applicant/accused is innocent and had not

committed the alleged offence as applicant accused is
respectable person and falsly has been implicated in this case
hence he has no concerned with the alleged offence .
503. That Co-accused Ghulam Rasool is already granted on
bail by this Honourable therefore applicant as right of same
sort of relief on the rule of consistency.
504. That as per the facts of the FIR encounter was continued
for about 30 minutes but none of a single fire arm received by
either party nor single bullet hit to anyone of police mobile
therefore looking to the circumstances which creates the
doubt and creates highly doubt in prosecution story
otherwise applicant/accused has no concerned with the
alleged offence.
505. That neither the abductee Mansoor Ali son of Ghulam

Shabir Jatoi was kidnapped nor this encounter was taken
place but the whole story of the complainant managed just to
show his influence against the present applicant/accused
persons with intention to pressurized them while they may
come in their terms .
[4]
506. That mashirs are real brothers of complainant in crime

No 5 of 2014 of PS Lakhat, namely Ghulam Sarwar son of Haji
Ismail Jatoi therefore they are interested and are not
independent witnesses, thereore there is clear crystal
violation of 103 Cr PC.
507. That ineffective firing have been shown by the

complainant no direct role, overt act or injury is attributed to
the applicant/accused mere there are general allegation
508. That the police of PS Lakhat is behind the applicant
hunting for the applicant finding him not there have left the
threats to come again to arrest him, hence thereis great
apphrension of his imminent arrest of the applicant if the
applicant accused is not admitted on pre arrest bail then he
would be toruted, humiliated subjected to maltreatment at
the hands of the police of PS lakhat .
509. That nothing as alleged or has been recovered from the

possession of the applicant and no probabilities of allegation
made out against the applicant accused, during investigation,
moreover allegedly such reocery of the weapons has been
foisted.
510. That there is ineffective firing and no specific role, part,

injury or overt act is assigned to the applicant/accused mere
there are general allegation against the applicant/accused.
511. That at this stage the case is requires for further inquiry.

evidence as all the PWs cited in the FIR interested witnesses
of the complainant.
513. That grant of bail is the largest interest of justice .

applicant accused as he is ready to furnish solvent surety to
the satisfaction of this Honourable Court for his regular
appearance.
[5]
arguments.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application, on

behalf of the applicant/accused before this competent court of law.
ALTAF HUSSAIN CHANDIO

ADVOCATE FOR
APPLICANT/ACCUSED
BENAZIRABAD
A. B. A. No. of 2014.
Wazeer …………………………………… …………

Applciant/accused
VS
The State
…………………………………………………………..Opponent

OFFENCE U/S 324, 353, 148, 149
PPC
AFFIDAVIT
I Wazeer son of Muhammad Bux jatoi Muslim Adult

R/O Village Lakhat Taluka Sakrand District Shaheed
Benazirabad presently Confined in district Jail Shaheed
Benazirabad , do hereby state on oath as under:-
1] That I am the applicant /accused in the above case hence fully



4] That Police of PS lakaht is behind me and have raided my


Advocate

MAGSITRATE-III NAWABSHAH

Noor Muhammad and others
VS
The State

Nawabshah
OFFENCE U/S 452, 363, 496-A, 498, 34
PPC
APPLICATION

pleased to Cancel the Bail Order passed on 3-7-2014 in favour
of the Noor Muhmamad and Abdul Razzak alias Motu and to
grounds:-
-: F A C T S :-

Muhammad Usman lodged his FIR at PS A Section
Nawabshah on 31-5-2014 at about 11:00 Hours , alleging
therein that he is married with the Mst Haleema aged about
46 years, ouit of this wedlock she gave birth 08 chidlren and
baby Sanam aged about 9 years is last one, his relative are
residing in District Snaghar, complainant and his relative are
vesting t3rms with Abdul Razzak alias Moto, Noor
Muhammad and Reheem Leghari, some time back the
complainant came to know that which he asked his wife to
not
[2]
talk with him. On 3-5-2014 at morning time as usual he went

to his job at PMC Nawabshah while leaving his brother Ali
Khan son fo Nadir Ali and other inmates were present in the
house, when at about 1:00 PM the compliannat came for lunch
at thwe same time he heard sound of vehicle and there was
knock on the door as soon as he opened the door the above
referred accused each Abdul Razak alias Moto with pistol ,
Noor Muhammad Leghari with pistol, Raheem Leghari and
one unknodied person who trespassed his house, who
straight their weapons upon them dyue to fear compliannt
remained silent the above accused kndiapped away his wicfe
and daughter Sanam saying so that Abdul Razzak alias Moto
will marry with his wife and went away in white colour coure
car, due to harassment he could noted the number of the Car
he further stated that his wife was with amouitn of Rs.
25000/- and she was worn with gold ornaments i.e Gold
Kangan , Gold Locket earning, he approached to BAdul razak
and his brothery for get return of his wife and daughter who
kept him on false hopes and later on refused to return them
hence this FIR.
After registering of the FIR applicants/accused Noor

Muhammaad and Razzak filed their bail application, before
this Honourbale court which was granted, after granting of
bail to the accused now both accused are not returning the
wife and daughter of the applicant they are detained in
private confinement of the both accused persons as there is
apprehension that wife and daughter of the complainant
might be killed by accused and now they are threatening the
complainant to come in thier terms otherwise he harm will be
caused to compliannat and abductees hence this present
application for cancellation of bail on the following grounds.
-: G R O U N D S :-
516. That order passed in favour of the applicants /accused

namey Noor Muammad and Abdul Razzak is against the
principle law and justice and equities.
517. That applicants/accused are clear crystal nominated in

the above FIR and they are hardened and criminal and
culprit.
[3]
518. That there was no possibility to granting the accused

persons on bail as since offence they have kept the wife and
daughter of the complainant in their detentions and are not
ready to release them.
519. That now contrary they are threatening the complainant

that if the complainant did not come in their illegal demands
and terms and furthermore threatened that if the complainant
did not patch up with forcefully with them then they will
cause the harm to his detained wife and daughter.
520. That criminal record in respect of the above case is

existed in the FIR but having the heinous shocking offence
accused were released on bail and grevancies of the
compliannat could be redressed by this Honourable court and
since offence he abductees are under pressure and threats of
the accused persons therefore such order of granting the bail
is liable to be cancelled and accused should be committed in
the custody of the police and inquiry may be made abouit
cruelties of the accused persons.
521. That after granting of bail to the accused now both
accused are not returning the wife and daughter of the
applicant they are detained them in private confinement of
the both accused persons as there is apprehension that wife
and daughter of the complainant might be killed by accused
and now they are threatening the complainant to come in
thier terms otherwise the harm will be caused to compliannat
and abductees.
522. That there is great apphresnion to the life of the

complainant and accused persons are behind the complainant
and in odd hours and other time are roaming with deadly
weapons just to give harm to the complainant.
523. That Bail order granted by this Honourable court may

kindly be cancelled otherwise complainant and abductees
will sustain harm by the hands of the accused.
524. That police has no interest with above case whereas

complainant
[4]
has lot expectations t o get justice from this Honourable court

and to get release the abductees from illegal detentions of the
accused persons.
525. That complainant has been threatened by the accused

persons that they are not providing foods and clothes to the
abductees and abductees are in troubles under wrongful
confinement of the accused persons.
526. That complainant is aggrieved party and they have
legally right to redressing their grevancies and accused may
kindly be committed in custody of the police and their bail
order may kindly be cancelled with interest of justice.

COMPLAINANT
BENAZIRABAD
B. A. No. of 2014.
Ghulam Rasool son of Muhamad Jatoi

R/O Village Lakhat Tlauka Sakrand
District SBA presently Confined in district
Jail Shaheed Benazirabad …………………………
Applciant/accused
VS
The State
…………………………………………………………..Opponent

OFFENCE U/S 324, 353, 148, 149 PPC
BAIL APPLICATION
pleased to release him , on bail in the above case/crime on
-: F A C T S :-

SIP/SHO Ghulam Shabir Sahito lodged his FIR at PS Lakhat
on 10-12-2014 at about 22:00 hours, alleging therein that on the
day of incident complainant party were present at PS and
received spy iformation that accused involved in crime No
5/2014, under sectin 7 ATA 302, 385, 404, 363 , 148, 149, 337-
H(ii) PPC. Of PS Lakhat, are sitting at the landhi of accused
Gulzar Jatoi and others, and abbductee Mansoor Ali is
available there, the compliainant after receiving such
information he got informed to their higher Officer DSP
Lakhat , thereafter complainant alonwiht his staff, containing
[2]
the ammunition on police mobile No SP-6887 under entry No

village Lakhat where they treid to make private mashirs
which Ghulam Nabi son of Haji Ismail Jatoi , Ashqiue Ali son
of Zanwar yaqoob jaoti all R/O Lakhat Taluka Sakrand police
taken with them and came at Bacha Pand at Lakhat, Maqbool
Ahmed DSP Lakhat alognwiht his staff, on police mobile, SIP
SHO Dodo khan Rahu PS Khah with staff and containing the
ammunition came there SIP Jam Farhad Khan IC Nawab Wali
Muammad with their staff and containing the ammunition ,
SIP SHO Ahmed Khan Khaskhlei of PS Ali ABad with his staff
on government vehicle containing the ammunition came
there, with direction of the DSP Maqbool Ahmed Memon the
complainant party approached at Landi of Gulzar jatoi near
Katcho Bailo, after arrival compliannat party got down from
their mobile and they saw accused each Gulzar , Kirar alias
Wazeer, Akuldar all sons of Mehmood, Saiful alias Baghi ,
Sikandar, Ghulam Sarwar all sons of Kandero , Punhoon Haji
Deedar alias deedu Adnan alias Soomar alias Porho all sons of
Bahadur, Rustam Shahnawaz, Ghulam Qadir alias Bhoori,
Mehmood alias Porho , all sons of Shafi Muhammad, Wazeer
and Ghulam Rasool boths Muhammad Bux , Kabootar son of
Pathna , Nazeer son of Wazeer alias Kirar Jatoi all resident fo
Lakht Taluka Sakrand , Nazeer Muneer Hussain both sons of
Illahi Bux caste tunio R/O Sobho Dero all armed with KKs ,
who by seeing the police party in uniform they made straight
firing upon them with intention to commit murder, the police
party by taking position also made firing in their defense,
such encounter continued about 30 mintues therafter police
party went towards Landhi side where they saw accused
involved in crime No 5/2014, under sectin 7 ATA 302, 385,
404, 363 , 148, 149, 337-H(ii) PPC. Of PS Lakhat , they saw
Abductee Mansoor Ali son of Ghulam Shabir Jatoi was
weeping there, the privte mashirs also informed the
complainant party that is Abductee Mansoor Ali who was
abducted by accused persons, thereafter complainant went
behind the accused persons but they run away by taking the
advantage of Jangle, thereafter mashir each Ghulam Nabi and
Ashqiue Ali Jatoi disclosed the names of the accused persons
to be above detailed, thereafter
[3]
complainant party made the mashir before the privates

mashirs and came at PS where they lodged FIR by stating
therein that accused have detttered the complinant party to
perform their duty thereafter complainant lodged above FIR
whereas complainant from his SMG fired 30 Bullets and
further other officer will disclosed in their statement hence
this FIR.
After registering of the FIR applicant accused Ghyulam

Rasool was arrested and after usual investigation challan was
submitted before civil judge JM-III Daulatpur. Hence
applicant/accused filed this present application before this
Honourable court on the following grounds.
-: G R O U N D S :-

respectable person and neckmard of locality and by
profession he is Zamindar (landlord), as he has falsely
involved by the compliannt on the instance of complainant of
main case/crime No 5/2014 namely Ghulam Sarwar son of
Haji Ismail jatoi.
528. That applicant accused Ghulam Rasool is not involved

in crime No 5 of 2014 of PS Lakhat, but he is caste fellow and
relative of other accused persons which are nominated in the
Crime No 5 of 2014 of PS Lakhat therefore he has falsely been
involved in above case/chrime.
529. That as per the facts of the FIR encounter was continued
for about 30 minutes but no single fire arm received by either
party nor single bullet hit to anyone of police mobile therefore
looking to the circumstances which creates the doubt and
creates highly doubt in prosecution story.
530. That neither the abductee Mansoor Ali son of Ghulam
Shabir Jatoi was kidnapped nor this encounter was taken
place but the whole story of the complainant managed
[4]
against the present applicant accused persons with intention

to pressurized them while they maya come in their terms .
531. That mashirs are real brothers of complainant in crime

No 5 of 2014 of PS Lakhat, namely Ghulam Sarwar son of Haji
Ismail Jatoi therefore they are interested and are not
independent witnesses, thereore there is clear crystal
violation of 103 Cr PC.
532. That nother has been recovered from the applicant

accused Ghulam Rasool during investigation but alleged
reocery of the weapons has been foisted.
533. That there is ineffective firing and no specific role, part,

injury or overt act is assigned to the applicant/accused mere
there are general allegation against the applicant accused.
534. That at this stage the case is requires for further inquiry.

evidence as all the PWs cited in the FIR are well wisher of the
complainant.

surety to the satisfaction of this Honourable Court for his
regular appearance.

arguments.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application, on

behalf of the applicant/accused before this competent court of law .

ADVOCATE FOR
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No. of 2014.
Hanif Rahu
VS
The State

Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
BAIL APPLICATION

applicant/accused , namely Hanif Son of Pir Bux Rahu,
presently confined in District Jail Shaheed Benazirabad, that
this Honorable Court may be pleased to release him , on bail
in the above case/crime on the consideration of the fallowing
facts and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, Haji

son of Taj Muhammad Rind lodged his FIR at PS Kazi
Ahmed, On 10-11-2011 at about 2200 hours, alleging therein
that, complainant and other are 6 brothers interse , second
number brother namely Yousif is aged about 60 years, some
9/8 months back daughter of Muhammad Ayoob Rahu
namely Imam Zadi consummated love marriage with relative
of the complainant namely Gul Hassan son of Qaim Khan
Rind, on which Sher Muhammad Rahu and others were not in
talking termed with complainant party, and they are
threatening the complainant of murder, today complainant
and his
[2]
brother Youisif Ali and relative Gul Muhammad son of Khan

Muhammad Rind and Sikdandar son of Muhammad Essa
Rind they all in gathering were gone to Nawab Wali
Muhammad town for their personal work on their
motorcycles, after completing the work complainant and Gul
Muhammad seated on one motorcycle, Yousif and Sikandar
seated on another motorcycle, brother of the complainant
Yousif Ali was driving the motorcycle, they were afore from
the motorcycle of the complainant when at about 3:30 hours
they reached near village Allah Bux Khatiyan , where they
saw 7 persons were standing there and they were identified
each to be, Sher Muhammad son of Rasool Bux Rahu, R/O
Village Saindad Rahu, Chutto Khan son of Hubdar Rahu
having KK Hanif son of Pir Bux resident Bilawal Rahu having
KK, Dilawar son of Ali Nawaz Rahu having rifle, three
unknown accused persons, who can be identified if seen
again, they straighten their weapons and signaled to stop the
motorcycles, and they stopped to Yousif and Sikdanr, and
they by getting down the brother of the complainant namely
Yousif also threatened that today they will kill them, by
saying so Sher Muhammad made fire from his rifle, Chutto
Khan made fire from his KK, Hanif Rahu made fire of KK,
Dilawar made fire of rifle two unknown accused persons
made fires of rifles and one made fire of KK in back side of
Yousif brother of the complainant, who by raising cries fallen
down meantime sher Muhammad made fire on chest of
Yousif, due to fear of weapons the complainant run away in
crop of Sugarcane, and Sikandar also by raising cries run
away towards the complainant, thereafter all accused made
straight fires upon complainant party with intention to
commit their murder, but complainant party fallen down in
crop of Sugarcane, and made hue and cries on the cries of the
complainant the villagers attracted there, meantime accused
by seeing the villagers run away towards village of Bilawal
Rahu, thereafter complainant went and saw brother of the
complainant namely Yousif sustained 6 firearm on his
backside and one fire was hit on his chest side, and who was
died, and they saw the bullets were hit to motorcycle of the
Yousif, and one bullet was hit to cover of the motorcycle of
the complainant, thereafter complainant and his witnesses by
shifting
[3]
the dead body of Yousif to Taluka Hospital Kazi Ahmed and

after conducting postmortem and they after completing burial
subsequences came at PS and lodged present FIR.
After usual investigation the police submitted challan ,

thereafter prenet applicant acused was arrested and police
submitted supplementary challan before this Honourable
court, he is confined in District Jail Shaheed Benazirabad,
thereafter 1st Bail application of the applicant accused was
filed his first bail applicant which was dimsised on merit, by
this Honourable court, thereafter applicant accused filed a bail
application before Honourable High Court Circuit Bench
Hyderabad which was withdrawn in view of compromise
talks and thereafter 3rd Bail application was filed on merit
before this Honourable court and same was dimsised being
withdrawn, now this is 4th bail application befote this
Honourable court on behalf of the applicant on fresh
grounds.
-: G R O U N D S :-
539. That the applicant/accused are innocent and had not

respectable person and neckmard of locality and by
profession he is Zamindar (landlord).
540. That 1st Bail application of the applicant accused was

filed his first bail applicant which was dimsised on merit, by
this Honourable court, thereafter applicant accused filed a
bail application before Honourable High Court Circuit Bench
Hyderabad which was withdrawn in view of compromise
talks and thereafter 3rd Bail application was filed on merit
before this Honourable court and same was dimsised being
withdrawn.
541. That parties viz complainant and applicant/ accused

Muhammad Haneed Rahu have agreed to talks about
compromise and they have also been agreed upon and the
case is hereby to be compounded and it is necessary that
applicant/accused Muhammad Hanif also participated in
Faisla proceedings.
542. That complainant has no objection as per his affidavit

that if this Honourable court may grant of bail to
applicant/accused Muhammad Hanif for the purpoe of
participating in the faisla and the matter is hereby to be
compounded .
543. That no recovery has been affected from present

applicant/accused during the investigation.
complainant.

surety to the satisfaction of this Honourable Court for his
regular appearance.

arguments.

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is 4 th bail application on

behalf of the applicant/accused before this competent court of law .

ADVOCATE FOR
APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2014.
Hanif Rahu
VS
The State

Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
AFFIDAVIT
I, Haji son of Taj Muhammad by caste Rind Muslim Adult

R/O Village Allah Bux Rind Taluka Kazi Ahmed Distrcit
Shaheed Benazirabad, do hereby state on oath as under:-
1. That I am complainant in the above FIR hence well

2. That I and applicant accused persons Muhammad Hanif

Rahu are ready to talk of compromise application and I am
agreed upon, as the case is hereby to be compounded and it is
necessary for the aplicnat/accused Muhammad Hanif Rahu
may participate in faisla proceedings. Therefore I have no
objection to grant of Bail to accused Muhammad Hanif Rahu
for the purpose of participating in faisla and the matter is
hereby to be compounded.

knowledge and belief.
Advocate
4TH BAIL APPLICATION

BENAZIRABAD
B. A. No: OF 2014.
Hanif Rahu
VS
The State

Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
BAIL APPLICATION

facts and grounds:-
-: F A C T S :-

and his
[2]
shifting
[3]

After usual investigation the police submitted challn by

showing the applicants as absconder, thereafter present
applicant accused was arrested and police submitted
supplementary Challan before this Honourable Court who is
in District Jail Shaheed Benazirabad, therefore applicant got
filed filed his First bail application which was dismissed on
merit, thereafter2nd Bail Application was filed before
Hinourbale High Court Ciruict Bench Hyderabad which
dismissed being withdrawn on merit, thereafter third bail
application was filed and same was withdrawn now this is 4 th
Bail application on fresh grounds hence this 4th bail
-: G R O U N D S :-

committed the alleged offence , but he has falsely implicated
by the complainant with the malafide intention due to
suspecisous enmity which is existed in between Rind and
Rahu community .
549. That there are general allegation no specific role, or

overt act is attributed to present applicant accused, mere
there are general allegation of causing the injuries on the
person of deceased and there is no specific role that which fire
arm injuries received by whom accused persons .
550. That the complianat Haji Son of Taj Muammad Rind

filed affidavit alongwith this bail application that the name of
the accusd persons has been given by him in FIR on
suspicious basis as after registration of FIR brothery faisla
was held on Holy Quran in which present applicant accused
was found innocent therefore complainant Taj Muhammad
has no objection if this Honourable court may grant him bail.
[4]
551. That as per contents of the affidavit filed by the

complainant Haji son of Taj Muhammad Rind that his names
has been given in FIR on suspicious basis and deceased
Yousaf Ali Rind was brother of complainant therefore at this
stage this matter is requires for further inquiry and it is well
settled principal law that if suspecisous found in any stage of
case then benefit of doubt which goes in favour of accused
persons.
552. That all the PWs cited in the FIR are kith and kin of the
complainant hence they are well wisher of the complainant.
553. That no recovery has been affected from the present
applicant/accused.
554. That this case doesn’t require for further investigation

but requires for further inquiry.

complainant.


arguments.

APPLICANT/ACCUSED
CERTIFICATE


ADVOCATE FOR
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Hanif Rahu
VS
The State

Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
AFFIDAVIT
I, Haji son of Taj Muhammad by caste Rind Muslim Adult

R/O Village Allah Bux Rind Taluka Kazi Ahmed Distrcit Shaheed
Benazirabad, do hereby state on oath as under:-
1]. That I am complainant in the above FIR hence well

2]. That after the incident I have lodged this FIR and name
of the present applicants accused were given on suspicious
ground.
3] That after registering of the FIR a brothery faisla has

been hold on Holy Quran in which present applicant accused Hanif
Rahu was found innocent as his name was given in FIR on
suspicious basis therefore if this Honourable court grant him
bail at this stage then I have no objection .

Advocate
IN THE COURT OF FAMILY JUDGE &CIVIL JUDGE
NAWABHAH
B. A. No OF 2014.
Abdul Rasheed Qureshi Son of Mansib Ali

Presently confined R/O House No 186-IIC Mohalla
Liaquatabad Issarpura Nawabshah District Shaheed
Benazirabad …………………………………….
….Applicants/Accused
VS
The State ………………….………..

………………………………..Opponent
Crime No: 87 /2014, PS Airport NWS

U/S 294-A, 8, & 420 PPC
BAIL APPLICATION

applicants/accused , named above , that this Honorable Court
may be pleased to accept the surety of applicant/accused
named above in the above case crime, as all the sections
applied in the FIR are bailable, on the consideration of
following grounds.
GROUNDS
1. That the case against the applcinat/accusd is false and

fabricated one.
2. That the applicant/accused is innocent.
3. That all the section applied in the FIR are bailable.
4. That applcint /accused is not previous convict as per

instruction.
[2]
5. That applicant/accused is ready to furnish his solvent

surety to satisfaction of this Honourable court.
CERTIFICATE
This is to certify that prior to this no bail

application has been filed by the applicant/accused in the
above mentined case/crime (per instructions) .

BENAZIRABAD
A.B. A. No OF 2014.
1. Ashique son of Faiz Muhammad Jamali
2. Khadim Hussain son of Ahmed Khan Jamali
Both R/O Deh 57 Nusrat Taluka Daur
………………….Applicants/Accused
VS
The State ………………….………..

………………………………..Opponent
Crime No: 116 /2014, PS Daur

U/S 354, , 506/2, 34 PPC


may be pleased to admit them , on bail in the above
grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, Mst

Zohra lodged her FIR at PS Daur. On 9-12-2014, at about 16:30
hours alleging threin that, husband of the complianat Moula
Bux and her son Ali Bux and Sher Ali were going to cultivate
their lands, whereas complainant was going to her lands,
when at about 10:30 hours, complainant crossed the land of
Khadim Husain party, where she saw one khadim Hussian
having pistol, Ata Muhammad having lathi, Ashique having
hatchet all resident Deh 57 Nusrat Taluka Duar, meantime
accused Khadim Hussain put
[2]
the hands her hiars and dragged by saying so that they have
so many time prevented them to not cultivate lands but you
did not obeyed, therefore they intimidated that if they came at
land then her husband and sons will be killed, meantime on
the spot persons namely Ashraf and Hazoor Bux were present
they gave the name of Almighty fo Allah to the accused
persons and rescued the complainant, therefore complainant
moved an application before Honourable sessions judge SBA
and got order for registering her FIR hence this FIR.
After usual investigation, the police of PS Daur is

hunting for the applicants/accused finding them not there
have left the threats to come again, to arrest the
applicants/accused, there is great apprehension of their
imminent arrest therefore applicants/accused surrendered
themelves before this Honourable court , hence the present
pre arrest bail application, on the following grounds.
-: G R O U N D S :-

applicants/accused.

about 23 dayus without any plausible explanation which goes
to show that the same has been lodged after deliberation and
applicants/accused in present case can not be ruled out.
the utlrior reason have implicated them in false case, actual
facts are that the applicant/accused Khadim Hussin lodged
his FIR at PS Daur against the husband of complainant and
sons, therefore complainant of this case just to falsly
implicated the applicants/ accused lodged present FIR .
[3]
561. That there is no specific role part, injury or overct is

assigned to the applicants/accused mere there are general
allegation otherwise section 506/2 which and 354 PPC are
misapplied.
562. That malafide on the part of the compliannat is that

police of PS Daur is hunting for the applicants/accused
finding them not there have left the threats to come again, to
arrest the applicants/accused, there is great apprehension of
their imminent arrest that if the applicants/accused are not
admitted on pre arrest bail application, they will be
humiliated, maltreated and arrested at the hands of the police
of PS Daur.

complainant.
564. That there is no apprehension of the abscnsion of the

arguments.

APPLICANTS/ACCUSED
CERTIFICATE
This is to certify that this is first Pre arrest bail

application on behalf of the applicant/accused prior to this ,
no pre arrest bail or other case has been filed by the
applicant/accused before this Honourable Court.
ABDUL HAMEED JAMALI

Advocate for the applicants/accused

BENAZIRABAD
A.B. A. No OF 2014.
Ashique and another ……….

VS
The State ………………….………..

………………………………..Opponent

U/S 354, , 506/2, 34 PPC
AFFIDAVIT.
I Ashique son of Faiz Muhammad Jamali Muslim Adult R/O

Deh 57 Nusrat Taluka Daur District Shaheed Benazirabad
do hereby state on oath as under:-



4] That Police of PS Daur is behind me and have raided my


Advocate

BENAZIRABAD
A.B. A. No OF 2014.
3. Ashique son of Faiz Muhammad Jamali

4. Khadim Hussain son of Ahmed Khan Jamali
Both R/O Deh 57 Nusrat Taluka Daur
VS
The State ………………….………..

………………………………..Opponent

U/S 354, , 506/2, 34 PPC


may be pleased to admit them , on bail in the above
grounds:-
-: F A C T S :-

accused Khadim Hussain put
[2]
the hands her hiars and dragged by saying so that they have
so many time prevented them to not cultivate lands but you
did not obeyed, therefore they intimidated that if they came at
land then her husband and sons will be killed, meantime on
the spot persons namely Ashraf and Hazoor Bux were present
they gave the name of Almighty fo Allah to the accused
persons and rescued the complainant, therefore complainant
moved an application before Honourable sessions judge SBA
and got order for registering her FIR hence this FIR.
After usual investigation, the police of PS Daur is

hunting for the applicants/accused finding them not there
have left the threats to come again, to arrest the
applicants/accused, there is great apprehension of their
imminent arrest therefore applicants/accused surrendered
themelves before this Honourable court , hence the present
pre arrest bail application, on the following grounds.
-: G R O U N D S :-

applicants/accused.

applicants/accused in present case can not be ruled out.

the utlrior reason have implicated them in false case, actual
facts are that the applicant/accused Khadim Hussin lodged
his FIR at PS Daur against the husband of complainant and
sons, therefore complainant of this case just to falsly
implicated the applicants/ accused lodged present FIR .
[3]

assigned to the applicants/accused mere there are general
misapplied.
570. That malafide on the part of the compliannat is that

police of PS Daur is hunting for the applicants/accused
finding them not there have left the threats to come again, to
arrest the applicants/accused, there is great apprehension of
their imminent arrest that if the applicants/accused are not
admitted on pre arrest bail application, they will be
humiliated, maltreated and arrested at the hands of the police
of PS Daur.

complainant.
572. That there is no apprehension of the abscnsion of the


arguments.
APPLICANTS/ACCUSED
CERTIFICATE
This is to certify that this is first Pre arrest bail

no pre arrest bail or other case has been filed by the
applicant/accused before this Honourable Court.
ABDUL HAMEED JAMALI


BENAZIRABAD
A.B. A. No OF 2014.

VS
The State ………………….………..

………………………………..Opponent

U/S 354, , 506/2, 34 PPC
AFFIDAVIT.
I Ashique son of Faiz Muhammad Jamali Muslim Adult R/O
Deh 57 Nusrat Taluka Daur District Shaheed Benazirabad
do hereby state on oath as under:-





Advocate

BENAZIRABAD
A.B. A. No OF 2014.

VS
The State ………………….………..

………………………………..Opponent

U/S 354, , 506/2, 34 PPC
AFFIDAVIT.
I Khadim Hussain son of Ahmed Khan JamaliMuslim Adult

R/O Deh 57 Nusrat Taluka Daur District Shaheed
Benazirabad do hereby state on oath as under:-





Advocate
MAGSITRATE –III NAWABSHAH
B. A. No OF 2014.
Atta Muhammad SON OF Ali Muhammad

By caste Jamali presently confined in District
Jail Shaheed Benazirabad ……………………………..
……….Applicant
VS
The State ………………….………..

………………………………..Opponent

U/S 354, , 506/2, 34 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-

accused Khadim Hussain put the hands her hiars and
dragged by saying so that they have so many time prevented
them to not cultivate lands but you did not obeyed, therefore
they intimidated that if they came at land then
[2]
her husband and sons will be killed, meantime on the spot

persons namely Ashraf and Hazoor Bux were present they
gave the name of Almighty fo Allah to the accused persons
and rescued the complainant, therefore complainant moved
an application before Honourable sessions judge SBA and got
order for registering her FIR hence this FIR.
arrersted, who is applicant/accusd is in judicial custody,
hence the present bail application on the following grounds
-: G R O U N D S :-

applicant/accused.


facts are that the co-accused Khadim Hussin lodged his FIR at
PS Daur against the husband of complainant and son, in
which applicant/accused is one of the wtiness therefore
complainant of this case by taking advantage of false story
have implicated the applicant accused just to pressurize the
applicant accused while he may not adduce his evidence .

assigned to the applicant accused mere there are general
misapplied.
[3]
578. That no recovery has been affected from the

complainant.

complainant .


arguments.

APPLICANT/ACCUSED
CERTIFICATE

ABDUL HAMEED JAMALI

BENAZIRABAD
Muhammad Arslan son of Muhammad Yousif Khanzada

R/O Daulatpur town Taluka Kazi Ahmed District SBA
Benazirabad ……………………………………………..
……….Applicant
VS
The State …………………………..

………………………………..Opponent
Crime No: 105 /2014, PS Daulatpur

U/S 324, 399, 398, 353, 402 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, HC

Altaf Hussain Memon lodged his FIR at PS Daualtpur, On 23-
10-2014 at about 10:30 hours alleging therein that, he
alognwiht his subordinate staff left the PP, Shahpur Jahania
vide roznamacha 13 dated 23-10-2014 at about 02:00 hours for
patrolling within their beat, various palcece whne they
reached Pakka Water adjacent Deh Phulel at about 03:40
hours and saw on the lights of the vehicle and identified each
Abdul Majeed Bughio having revolver Jangsar Machi having
KK, Arslan Khanzada having pistol, Muhammad Hanif
Mallah having repeater, Bagho Machi having pistol, Khadim
Hussain Mallah having KK, were sanding on the road who
presumed vehicle fo the compliantn to be private
ASI Moula Bux Chandio lodged on behalf of the state, lodged
his FIR, on 7-3-2014, at about 22:30 hours, alleging therein that
, today complainant alongwith his subordinate staff each, PC
Kareem Bux Lakho, PC Khuda Dino Otho, PC Ghulam Qadir,
with ammunitions, on police mobile No. SP-357, alongwith
driver PC pyaro Khan, under the entry No. 13, dated 7-3-2014,
at about 18:00 hours, departed for patrolling, when
complainant party by proceeding towards NHW road reached
Sehwan road near chock of Village Guhram Mari, where they
saw the 5 accused persons with
[2]
weapons were standing there, with intention to commit

offence, they by sensing the private vehicle also, signaled to
stop with intention to commit robbery, the complainant party
scrupulously got down and saw each to be, Abdul Jabbar son
of Neck Muhammad Khoso armed with pistol, Ali AKbar son
of Haji Kamil Khoso with pistol, Dhani Bux Son of Haji Kaimil
Khoso with pistol, Lalu son of Beg Gaecho with pistol,
resident of village Garwari Gaecha Taluka Manjhand, Ghulam
Mustafa alias Mustu, son of Umar Ghallu, resident of near
Dainan Taluka Kaiz Ahmed with KK, who by seeing the
police party also made straight firing upon them, meantime
compliannat party by taking shelter also fired upon accused
persons in their defense, such encounter continued for about
10/12 minutes, the compliannat party very tactfully apprened
to one accused person with pistol, and other accused by
making firing skipped away towards nothren side in crop of
sugarcanes, due to none availbality of the private mashirs, the
complainant made mashir to PC kareem Bux, and PC Abdul
Hameed at place of Wardhat, compliannat party inquired
about name and parentage of accused who disclosed his name
to be Abdul Jabbar, son of Neck Muhammad Khoso, resident
of Village Majhand Khoso aluka Kazi Ahmed District
Hyderabad, compliannat party opened the pistol, and which
was 9MM with magazine without number, compliannat party
unloaded the pistol in which they secured 4 bullets of 9MM
which were loaded in pistol, meantime complianat party
inquired about the liecnse of the pistol which accused
disclosed unlicensed, meantime compliannat party sealed to
pistol and bullets, further complianat conducted body search
of the accused but nothing else was recovered , accused have
committed the offence by dettering the complainant party to
perform their lawful duty, and by sensing privte vehicle
stopped the compliannat party to commit offence and fired
upon them , they have committed offence under section 398,
353, 324,399, 402, PPC , furtheremore complainant party
through wireless got checked record of District Hyderabad,
wherefrom compliannat party got information that accused
Abdul Jabbar is absconded in crime No 44/2013 udner section
381, 34 PPC, crime No 10/2013 under sectin 20 Hadood
ordinance, 34 PPC, crime NO 53/2013 udner section 17/3,
Crime No 54/2013 udner section
[3]
17/3, crime No 55/2013, under section 17/3, crime No

71/2013 udner section 324, 353, 34 PPC, thereafter
compliannat party made such mashirnama before the mashirs
on tortch head light of mobile, and they arrested the accused
in above case/crime, compliannat fired 15 bullets from his
SMG, furthermore other policemana will give their detail of
bullets which they fired and complainant party lodged FIR
under section 23-A Sindh Arms Act 2013 and lodged FIR,
hence this FIR.
-: G R O U N D S :-

incriminating has been secured as alleged from the applicant
accused.
583. That in fact, nothing has been recovered from the

applicant/accused from his possession, but complainant
party by showing their effeiceincy and power of force has
implicated the applicant in this false case by foisting pistol
and its bullets otherwise applicant/accused has no concerned
with alleged offence.
584. That as per facts of the case there is ineffective fireing at

the place of inceint, as per content of the FIR compliannat
alleged that he has fired 15 bulelts from his SMG but no
single fire arm hit to accused person or police party and not a
single scratch hit to police mobile but compliannat is agile
and he very tactically made this story by leveling false
allegation otherwise applicant/accused has no concerned
585. That as per contents he state that he recovered pistol

and bullets of 9MM but no single empty was recovered at
[place of incident
[4]
and from further body searching no other article were
recovered form the accused which creates doubt in
prsoeuction story which makes the applicant entitle for the
concession of bail.
586. That as per contents of the FIR furing was continued for
about 10/12 minutes but, as how it can be possible that
during the encounter police mobile remained safe from
damages.
587. That no specific role, part, injury, overt act is assigned to

the applicant/accused, mere there are general allegations
against the applicant/accused.
588. That applicant /accused has already been granted bail

in connected case/crime No 52/2014, of PS Kazi Ahmed,
offence under section 23-A Sindh Arms Act 2013 by 2nd
Additional Sessiosn Judge Shaheed Benazirabad.
589. That compliannat shown absoncdre to the

applicant/accused more other crimes but it is worth to
mention that applicant/accused has already been granted
bail in that crimes.
590. That no such incident has ever taken place but

complainant with malafide intention for the ulterior motive
has implicated him just to obliging to his higher officer
otherwise applicant/accused has no committed alleged
offence.



arguments.

APPLICANT/ACCUSED
[5]
CERTIFICATE


IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE
SHAHEED BENAZIRABAD
B. A. No. OF 2014.
Shahnawaz son of Dado Rind

R/O Village Bilawal Rind deh
30 Dad , Taluka Nawabshah now confined
in Distrit Jail Shaheed Benazirabad…………………Applicant
/Accused
VS
The State ………………………………………………………….

…...Opponent
Crime No: 83 /2014, PS Taluka

U/S 392 PPC 337-M-H(ii) Q .
BAIL APPLICATION

grounds:-
-: F A C T S :-

AMer Ali lodged his Fir at PS Taluka. On 1-12-2014, at about
13:30 hours alleging therein that, complainant is serving in
National Bank Kazi Ahmed as a post of OG-3, On 30-11-2014
complianant departed to Chanesar Staff for his persons work
on his motorcycle No NHJ7173, after purching housely itmes,
complainant alognwiht shoukat Ali and Manthar on
motorcycle of the complainant were retunring back towards
their house, when at about 5:00PM they reached near
Muhammad Sharif Mori, where complainant party saw two
persons having pistols in their hands were standing there, the
complainant identified the accused which to be, Shahnawaz
having pistol, Shahnawaz having pistol, they pointed out
thier pistol and singall to stop the complinant party, due to
fear of weapons complainant stopped his motorcycle,
meantime accused Javed snatched key of motorcycle from
complainant, Accused Shahnawaz snatched Rs 1500/- from
Shoukat Ali, cousin of the complainant, meantime where
motorcycle No 8730 Super Staf of read colour of the accused
persons was parked, the accused Shahnawaz seated on his
motorcycle, meantime complainant caught hold the
Shahnawaz, during that, Accused Javed made aerial firing just
to put the complainant in harassment, meantime compliaannt
prty left them thereafter all accused by taking away
motorcycle of the complainant went away, thereafter
complainant came at PS and lodged present FIR .

arrested who is in judicial custody, hence the present bail
-: G R O U N D S :-

intention .
596. That there is delay in lodging the FIR for about 1 day
without any plausible explanation which goes to show that
the same has been lodged after delierbation and consultation
as such fale implication of the applicant accused can not be
ruled out.

FIR but complainant by managing a false story have
implicated the applicant in present just to take advantage of
false story otherwise applicant has no concerned with the
alleged incident.

verified from the facts that, complainant has shown incident
at broadday-light whereas such place of incident is populated
area and such road is busy one there is no possibility of
commission of the offence but complainant just to put
pressure upon the applicant and others have implicated him
in false case otherwise applicant accused has no concerned

verified from the facts that how it can be possible that
complainant identified the accused with their parentage
without any source of identification which is clearly malafide
on the part of the complainant which creates highly doubts in
prosecution story otherwise applicant accused has no

verified from the facts that complainant shown
applicant/accused armed with deadly weapons but no single
scratch on the person of complainant has been sustained or
from either side thus-far such story is discontented one.
601. That both PWs cited in the FIR are well wisher of the
complainant and are interested witnesses.
602. That the applicant is not hardned criminal, desperate
nor previous convicted as per instructions.
603. That applicant accused has possessed good reputation

in his vicinity but complainant of this case just by mananging
a false story has implicated the applicant/accused in present
case otehwise applicant accused has no concerned with the
alleged offence.

complainant .


arguments.

APPLICANT/ACCUSED
CERTIFICATE


IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE
SHAHEED BENAZIRABAD
B. A. No. OF 2014.
Rashid Ali son of Rao Majid Ali Rajput

R/O Family Qourter Nawabshah District
Shaheed Benazirabad
………………………………………………..Applicant
VS
The State ………………………………………………………….

…...Opponent
Crime No: 88 /2014, PS Airport

U/S 324, 239-A Electricity Act & 353
PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, Lal

Bux Brohi loded his FIR at PS aiprot On 4-12-2014 at about
16;00 hours alleging therein that, complainant is line
suprientendant in WAPDA HESCO, On 3-12-2014
complianant along with staff, departed to checking of line
and Badge 10, when at about 12:00 hours compliannt went to
family quarter Nawabshah where they saw defalter Rashid
Ali who connected PVC wire from the Pool and installed the
electricity and was running AC and other instrucments by
consuming the electricity, whose account No
[2]
10373130668604 having Bill Rs. 30232/- and second aaccont

No 103731306679004 having Bill Rs 12689 bearing arrears, the
complainant party knocked his door, who came ouit from the
house, to whome complianant requested for arrears of the
electricity and further requested that you is installding
electricity illegaly, thereafter compliannt idsocnnencte the
electricity connection, who that time pushed the complainant
party and deter them from performing the duty, thereafter
complainant got informed to SDO WAPDA HESCO who gave
the letter No. 2625-29 datd 3-1-12-2014 and addressed to SSP
District SBA who remaked it to PS thereafter complainant
came at PS and lodged present FIR
After usual investigation, the accusced is in polic

custody , hence the present bail application on the following
grounds
-: G R O U N D S :-

intention .
608. That in fact the applicant is social worker and went to

open Katchhery of WAPDA at Hyderabad and delivered
speech on mike against the highhandedness of WAPDA
authority of the Nawabshah and so also extra billing of the
applicant accused on which the minister of WAPDA assured
the applicant that he will visit the Shaheed Benazirabad and
redress the grevancies of the persons of district Shaheed
Benazirabad and the XCN WAPDA District Shaheed
Benazirabad also assured to the applicant to redress the
grevancies soon .
609. That on the next date of open katchehry the applicant

approached to XCN through phone and apprised extra billing
on which XCN became angered and the extended threats that
he will see the applicant and result of that, the line
suprientedant Lal Bux lodged present false FIR against the
applicant accused.
610. That no private PW has been cited from the locality to

support the version of the complainant and all the PWs are
related to complainant.
611. That offence doesn’t fall within the prohibitory clause of
section 497 Cr PC.
612. That the applicant is not hardned criminal, desperate

nor previous convicted as per instructions.
613. That applicant accused has possessed good reputation

in his vicinity but complainant of this case just by mananging
a false story has implicated the applicant/accused in present
case otehwise applicant accused has no concerned with the
alleged offence.

complainant .


arguments.

APPLICANT/ACCUSED
CERTIFICATE

BENAZIRABAD
Muhammad Arslan son of Muhammad Yousif Khanzada

R/O Daulatpur town Taluka Kazi Ahmed District SBA
Benazirabad ……………………………………………..
……….Applicant
VS
The State …………………………..

………………………………..Opponent
Crime No: 105 /2014, PS Daulatpur

U/S 324, 399, 398, 353, 402 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant, HC

Altaf Hussain Memon lodged his FIR at PS Daualtpur, On 23-
10-2014 at about 10:30 hours alleging therein that, he
alognwiht his subordinate staff left the PP, Shahpur Jahania
vide roznamacha 13 dated 23-10-2014 at about 02:00 hours for
patrolling within their beat, various palcece whne they
reached Pakka Water adjacent Deh Phulel at about 03:40
hours and saw on the lights of the vehicle and identified each
Abdul Majeed Bughio having revolver Jangsar Machi having
KK, Arslan Khanzada having pistol, Muhammad Hanif
Mallah having repeater, Bagho Machi having pistol, Khadim
Hussain Mallah having KK, were sanding on the road who
presumed vehicle fo the compliantn to be private
ASI Moula Bux Chandio lodged on behalf of the state, lodged

his FIR, on 7-3-2014, at about 22:30 hours, alleging therein that
, today complainant alongwith his subordinate staff each, PC
[2]

[3]
hence this FIR.

-: G R O U N D S :-

accused.



[place of incident
[4]
concession of bail.
damages.



offence.




arguments.

APPLICANT/ACCUSED
[5]
CERTIFICATE


BENAZIRABAD
Abdul Jabbar son of Neck Muhammad Khoso

VS
The State …………………………..

………………………………..Opponent
Crime No: 51 /2014, PS Kazi Ahmed

U/S 324, 399, 398, 353, 402 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-

Moula Bux Chandio lodged on behalf of the state, lodged his
FIR, on 7-3-2014, at about 22:30 hours, alleging therein that ,
today complainant alongwith his subordinate staff each, PC
[2]

[3]

hence this FIR.

-: G R O U N D S :-

accused.



[place of incident
[4]
concession of bail.
damages.




offence.




arguments.

APPLICANT/ACCUSED
[5]
CERTIFICATE

MAGSITRATE –III NAWABSHAH
B. A. No: OF 2014.
Rasool Bux son of Pir Bux Magsi

Shaheed Benazirabad …………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 32/2014, P.S, Balu Ja Kuba

OFFENCE U/S 504, 506/2, 337-A
(ii(),, L(ii), 34 PPC
BAIL APPLICATION

to release him , on bail in the above case/crime on the
-: F A C T S :-

Shah Khatoon Magsi, produced order vide dated 19-9-2014
passed by this Honourable court and recorded her statement
U/S 154 Cr PC in the Book of FIR on 22-10-2014 at about 16:30
hours at PS Balu Ja Kuba alleging therein that Pir Bux Magsi is
her relative e against whole civil dispute is going on over the
ownership of 2, ½ Acres agricultural land, he used to issue
threats that if complainant party came at disputed land they
will teach them lesson, On 12-9-2014 at about 08-00 am the
complainant along with her sons Ali Bux and Dhani Bux
Magsi went to look after the
[2]
land, they saw each Pir Bux Magsi, Rasool Bux Mgsi, Mehar
Ali Magsi, duly armed with lathies were present there who
issued threats them since they restrain them to not come at the
land but even that they are not coming to any terms and today
they will not spare them, then all persons having lathies in
their hands caused lathi blows to her son Ali Bux which hit
him on his head, arms and other part of the body who started
raising cries meantime the complainant and her son Dhani
Bux, beseeched them by giving the names of the Allah then
accused went away while issuing threats that in case they
again came at land will be murdered, the complainant
appeared at the police station Balu Ja Kuba and got letter for
medical treatment hence this FIR.
applicant accused. Who is in judicial custody hence this bail
grounds.
-: G R O U N D S :-
643. That the applicant is victim of circumstances and has

committed no offence the prosecution story is false fabricated
untrustworthy and highly unbelievable and is without any
independent or corroborated piece of evidence.
644. That in fact no such incident has ever taken place but
the complainant party had staffed drama just to put the
applicant and his family behind the bars over the issue of civil
litigation which was decided in favour of the applicants.
645. That in fact the alleged injured Ali Bux had fallen from
motorcycle and sustained injuries by falling on the road and
by taking advantage of such injury the complainant chosen to
file this false FIR on false assertions.
646. That medical certificate is in conflict with the ocular

account.
647. That there is delay of 40 days in lodging of the FIR even

after order passed by this Honourable court for recording
statement.
[3]
648. That Co-accused Pir Bux and Mehar Ali have already
been admitted on pre arrest bail application .
649. That all male members of one family are roped in this
false cases without any plausible explanation.
650. That the offence doesn’t fall within the prohibitory

clause of section 497 Cr PC.
651. That the injuries not declared as dangerous to life.
652. That the provisional or final medical certificate has been

managed one.
653. That there is no role assigned to the applicant/accused.
654. That there are general allegation it is yet to be

determined that who will author of the injury of 337-A(ii).
655. That admittedly the parties are relatives.
656. That the section 506/2 PPC is not applicable to the

present case but even that police has miss plied the same.
657. That the FIR is based on false assertions and allegations.
658. That there is no independent witness of the case though

the offence said to have took place in the village and there
was villagers always present there.
659. That the case of the applicant/accuse is of further

inquiry to determine that who is the aggressor.
660. That the implication of the applicant accused on the face

of it is false fabricated untrustworthy and highly unbelievable
and is without any independent witness which makes entitle
to applicant accused for grant of bail .
[4]
661. That the case against the applicant accused is of such a

nature which can only be established after leading material
evidence on record hence at this stage applicant accused is
entitled for grant of bail.
662. That there is no likelihood of tampering with the

prosecution evidence .

surety to the satisfaction of this Honourable court.

arguments.

APPLICANT/ACCUSED
CERTIFICATE


BENAZIRABAD
Nadeem alias Baghar son of Ghulam Abbas Khaskheli

VS
The State …………………………..

………………………………..Opponent
Crime No: 136 /2014, PS Sakrand

U/S 324, 399, 398, 353, 402 PPC
BAIL APPLICATION
grounds:-
-: F A C T S :-

Sajid Hussain Arain of PS Sakrand lodged his FIR On 26-6-
2014 at about 21:30 hours alleging therein that, today
complainant alongwith his subordinate staff with ammunition
on police mobile SP 3504 alongwith driver under the entry No
Shalimar Bux Stop where they got spy information that
accused wanted in crime No 13/2011 under section 458, 392,
crime No 14/2011 under section 380, 457 PPC, Crime No
15/2011 under section 324, 353 PPC crime No 22/2011 under
section 324, 353 PPC, Crime No 23/2011
[2]
under section 457 , 380 PPC of PS Khadhar, namely Nadeem

alias Baghar is standing near Esso Keerio Chock to
committing the offence, the complainant party after receiving
the such information they departed towards the pointed
place, they saw on the light of the mobile accused each
Nadeem alias Baghar, armed with pistol, Anwar alias Annu
armed with KK both resident of village Begari Taluka
Sakrand, Dadan son of Rasool Bux KHokhar resident of
Village Shahid Khan Khokhar Taluka Halla District Matiyari ,
Sabhago son of Sahito Mangsi resident of Taluka Sakrand
armed with Gun, Majid shah son of Wilayat Shah, armed with
pistol , Faiz Muhammad son of Ibrahim Jamali resident of
Kumbli armed with pistol, Ayoob son of Mullo Mir
Muhammad Brohi R/o Village Yar Muhammad Borhi Taluka
Sakrand armed with pistol, were standing there, they by
sensing the private vehicle also signaled to stop police mobile,
the police by stopping their vehicle got down, meantime
accused by taking the position made straight fires upon police
party with intention to commit murder, police party by taking
positions also made firing in their defense which was
continued about 20 minutes, meantime on stopping of firing
one person made cries in crop of Banana, police party went
there and saw one person was in injured condition who
disclosed his name to be Nadeem alias Baghar, to whom fire
was hit on his left side of leg in knee, and blood was oozing,
and one pistol of 30 bore containing the magazine was lying
there, police secured the same and opened which was in
empty condition, the police sealed the same on spot, the police
inquired about the license from accused who disclosed to be
unlicensed, thereafter complainant went behind the ran away
accused persons, and complainant arrested the accused
named above in crime No 136/2014 under section 324, 353,
398, 399 and 402 PPC and under section 23_A Sindh Arms Act
2013 and who was declared proclaimer offender, meantime
due to none availability of the private mashir , complainant
made mashir to PC Raj Muhammad Palli, PC Jan Muhammad
Zardari such mashirnama made on the head light of mobile
and by taking the recovered property and arrested accused
came at Taluka Hospital and admitted him thereafter police
party returned back towards PS and lodged FIR against the
ran away accused persons in crime No 136/2014, under
section 324, 353,
[3]
398, 399 and 402 PPC Of PS Sakrand and police lodged a
separate FIR on arrested accused under section 23-A SA,
complainant made fires 32 Bullets from his SMG hence this
FIR.
After registering the FIR, applicant accused was

arrested, who is confined in District Jail Shaheed Benazirabad
, hence the present bail application on the following grounds
-: G R O U N D S :-

accused..
666. That the accused persons had allegedly made an

ineffective firing and no firearm or other injury was
attributed to the complainant party during the occurrence
and during the firing which continues 20 minutes , case
against the accused therefore needed to further inquiry, it is
further ground pertinent to matter that no overt act is
allegedly ascribed to the accused persons except ineffective
firing which also stood disapproved because no empty was
recovered from the spot and the question of vicarious liability
of accused could be determined at the trial case against the
accused thus requires to further inquiry

implausibly .

ever taken place but complainant just to drag the applicant in
false case has falsely implicated in false case otherwise
applicant/accused is not concerned with the alleged story.
[4]

verified from the facts that place of incipient has been shown
as Esso Keerio Chock allegedly such place is highly
populated place having the superior population police did
not act private mashir to corroborate version of the FIR hence
the case against the applicant accused is false and fabricated
one.
671. That pistol its bullets has been foisted upon the
applicant./accused.
672. That further malafide on the part of the complainant can

be verified from the facts that when police arrested accused
containing the recovered aforementioned property but he
could not find amount, mobile or other article which creates
doubt in persecution story thus far case against the applicant
accused is discontented one.
673. That co-accused Dadan Khokhar has been granted bail

by this Honourable court therefore applicant accused is
entitle for the same sort of relief.
674. That there is no specific role, injury, part assigned to the
applicant accused mere there are general allegation .




arguments.
IMAM BUX KHASKHELI

APPLICANT/ACCUSED
[5]
CERTIFICATE

IMAM BUX KHASKHELI

Reg-LC-No 784/NWS
[3]
679. That the alleged pistol along with magazine containing
fouir live bullets has been foisted upon the applicant accused
680. That since the applicant has been acquitted from the
charge under section 302, 148, 149 PPC from the main case
crime No 78/2013 and the present case is off shoot of the
main case and as such the applicant is also entitle for the
concession of the bail. As his case comes within the ambit of
section 497 (2) Cr PC.
681. That as per the ingredence of section 23-A Sindh Arms

Act 2013 the case against the applicant requires further
inquiry which makes entitle for concession of bail.
682. That the offence as alleged doesn’t fall within the

prohibitory clause fo section 497 Cr PC.
683. That case has been challaned and the applicant accused
is in judicial custody he is no more requires to the police for

complainant.


arguments.

APPLICANT/ACCUSED
CERTIFICATE

to this no bail application has been filed by the applicant/accused
of law.
ADVOCATE FOR
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Yaqoob son of Muhammad Sulleman Mochi

Benazirabad ……………….…….
………………….Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 189 /2014, PS kazi Ahmed

U/S 324, 34 PPC
BAIL APPLICATION

grounds:-
-: F A C T S :-

Manzoor Ali son of Ali Murad Solangi lodged his FIR at PS
Kazi Ahmed On 9-10-2014 at about 18:30 hours, alleging
herein that, he used to do labourer work, and resides at above
mentioned address, some one weak back hot words
exchanged in between complainant and Muhammad Yaqoob
party, on which Yaqoob was angered and was saying that he
will see the complainant party . on 6-10-2014 at about
complainant and Ali Dino son of Nabi Bux Mari, Manik son of
Haji Mir Muhammad Mari, both resident of village Mitho
Mari Taluka Sakrand, they all together had sat at Hotel of
Qaddan Shah near Sehwan bypassed, at about 8:00hours they
saw, suddenly
[2]
Muhammad Yaqoob son of Muhammad Sulleman and two

unknown accused persons with muffled faces all armed with
pistol, by seeing the complainant, they children of
complainant party have bothered them so today they will
teach them lesson, by saying so all accused made straight fires
upon complainant, meanwhile complainant fallen down and
fire were missed which hit to Wall of hotel, meantime
complainant raised hue and cries, thereafter all accused
persons run away towards the sugarcane crop towards
western side, thereafter complainant approached to his
neckmard Syed Shahid Shah son of Mir Muhammad Shah but
who was not present and was gone to his personal work,
when he came back, the complainant narrated whole facts
who advised to register the FIR against the accused hence this
present FIR

applicant/accused, who is in judicial custody, hence this
present bail application on the following grounds
-: G R O U N D S :-

by the complainant with the malafide intention due to enmity
which is existed in between the complainant and accused.
688. That no specific role, injury, or overt act is attributed to

present /applicant accused, mere there are general allegation
of making ineffective firing thus far case against the
applicant/accused is managed one and is not free from
doubt.

verified from the facts that if the fire was made by accused
persons then he without securing the empty, which hit to
wall, he went to PS for lodging the FIR as how it can be
possible that fire was made or not therefore case against the
applicant/accused is managed one just to pressurize him so
that he may come in their terms otherwise applicant accused
[3]
be verified from the facts that such incident shown by the
complainant is thickly populated and but complainant by
alleging such place of incident has booked the
applicant/accused while he may succeed by leveling the
allegation just to take revenge which is admitted by the
complainant.
691. That all the PWs cited in the FIR are setup persons of the
complainant and are well wisher of the complainant.
692. That there is delay in lodging the FIR for about more
then 3 days without plausible explanation which goes to
show that after settling all things complainant went and
lodged the FIR and applicant/accused was not aware about
such incident when he received information that FIR has been
lodged and police with malafide intention by joining the
hands with complainant also arrested the applicant/accused
otherwise applicant/accused is innocent and has not
committed alleged offence.

applicant/accused.
694. That applicant/accused has possessed good reputation

in his vicinity but complainant by showing his sharp mind
just to take revenge of petty matters has lodge present FIR
which is utterly false and discontented one.

complainant.


arguments.

APPLICANT/ACCUSED
[4]
CERTIFICATE


ADVOCATE FOR
APPLICANT/ACCUSED
BAIL APPLICATION

to release him on bail in the above case/crime on the
-: F A C T S :-

complainant, ASI Manzoor Hussain Solangi lodged his FIR at
PS Kazi Ahmed, today complainant alongwith staff, unlocked
to arrested accused named above from police lockup , who
was under remand in crime No 189/2014 under section 324.
34 PPC of PS Kazi Ahmed and started interrogation, during
interrogation he admitted that he became ready and admitted
that he has concealed the Desi Pistol which he used in above
commission of the offence, thereafter complainant alongwith
his staff with ammunition and on police mobile SP No 3578
alongwith driver by taking the accused they departed to
pointed place under the entry No 7 dated 12-10-2014 at about
16:00 hours when they reached Sehwan bypass wherefrom
complainant party took private mashirs namely Sajjan
[2]
son of Shahid khan and Ashraf son of Ali Murad Solangi

police party companied them, when at about 16:30 hours, they
crossed Sehwan bypass near Qaddan Shah Hotel where
accused cautioned to stop the vehicle, accused moved ahead
side and he deg out one plastic shopper which he opened and
got handed over the same Desi pistol of 12 bore containing
two bullets to police party, and admitted that he has fired
upon Manzoor Ali Solangi from same pistol in above
case/crime and by folding the same he kept in sugarcane
crop, Desi pistol was opened by compliant which was of 12
bore, police inquired about license of pistol which accused
disclosed unlicensed, due to unlicensed pistol police lodge a
separate FIR under section 25-A Sindh Arms Act 2013 and
police opened the same , in which smile of arms was feeling
meantime police sealed out the same pistol before the mashirs
and by securing the recovered property in their possession
they brought accused and recovered property came at PS and
lodged present FIR,
After usual investigation the police of PS Kazi Ahmed

arrested the applicant/accuse, who is in judicial custody ,
hence applicant filed present bail application before this
Honourable Court on the following grounds .
-: G R O U N D S :-
1. That the applicant/accused is innocent he has committed no
offence as alleged and he has been falsely implicated in the
present case by the complainant with malafide intention for the
ulterior reasons, otherwise he has nothing to do with the alleged
offence.
2. That, that no such incident whatsoever stated in the FIR has ever
taken place but complainant by managing a false story just to
show his efficiency, has implicated the applicant/accused, so
that applicant/accused come in his terms, otherwise applicant is
innocent
[3]
3. That in fact no such incident has been taken place but

complainant has malafidly implicated him, the present case is
nothing but complainant has no left the lack to implicate him.
4. That as per facts of the FIR complainant has shown place of

incident Sehwan bypass near Qaddan Shah hotel such place is
thickly populated where transport is running for 24 hours and
such area is surrounded with highly populations but police then
how it cane be possible that accused might have been kept the
same pistol at same place , thus-far case is managed is one and is
not free from doubt which requires for further inquiry.
5. That whole story narrated in the FIR is a concocted one and is

stereotyped which shows that police has booked the
applicant/accused in above case, with malafide intention and
have hidden aspectual motives.
6. That the PWs cited in the FIR are hostile towards the applicant
accused and they are setup with police party.
7. That nothing has been recovered from the applicant/accused

whereas pistol of 12 bore and it is bullet has been foisted upon
the applicant/accused just to make a new case, in fact such
property has been foisted otherwise applicant has no concerned
8. That the applicant/accused has possessed good reputation in his

vicinity but complainant just to get ill-repute and by foisting
property mentioned above has implicated the
applicant/accused, whereas FIR lodged by the complainant is
discontented one and is not free from doubt.
9. That there is no apprehension of the tempering in the evidence

and case of the complainant is unsupportable.
10.That the applicant/accused is ready to furnish his solvent

surety to the satisfaction this honorable court .
[4]
11.That other grounds will be urged at the time of hearing.
ADVOCATE FOR
APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is first bail application

on behalf of the applicant/accused, prior to this no any bail
application is pending before this or any other competent
court of law
Advocate for the applicant /accused

BENAZIRABAD
B. A. No: OF 2014.
Jumo son of Sultan Chandio

Jail Shaheed Benazirabad …….
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 402, 399, PPC
BAIL APPLICATION

-: F A C T S :-

complainant, Zahid Hussain Leghari SHO PS Bandhi lodged
his FIR at PS Bandhi On 27-72014 at about 04:15 hours, today
complainant along with his subordinate staff with
government ammunition on government vehicle SP No 3510
along with driver Abdul Wahid , under the rozanamcha entry
No nil dated 27-7-2014 at about 02:15 hours, left the PS for
patrolling various places when they were coming from
Dargah Khanan Shah which leads from Bandhi Road, they
saw on the head light of mobile 6 persons were standing
towards both side of road with intention to commit offence,
they have been identified by the police each to be Umar son of
Imam Bux Chandio armed with repeater resident of Village
Nawab Wali Muhammad, Akbar son of Photo alias Punhoon
[2]
chandio armed with repeater, Abdul Raheem son of Bux Ali

Chandio armed with KK both resident of village Sono
Chandio Taluka Kazi Ahmed, jumo son of Sultan Chandio,
Manthar son of Ismail Chandio resident of village
Muhammad Chandio Taluka Kazi Ahmed , Abbas Chandio
son of not known resident of Sarkari Khooh Taluka Kazi
Ahmed who were armed with KKs, they all by sensing private
vehicle also signaled to stop, the police party immediately by
getting down they told them to hands up, who by taking the
advantage of darkness also run away in stand bushes and
jungle side, the police by alighting the torch also went behind
the accused persons but they decamped away, thereafter
police party came at PS and lodged present FIR.
After usual investigation the police of PS Bandhi

arrested the applicant/accuse, who is in judicial custody ,
hence applicant filed present bail application before this
Honourable Court on the following grounds .
-: G R O U N D S :-

committed the alleged offence, but he has been falsely
implicated by the complainant with the malafide intention
and nothing has been recovered from the possession of the
applicant accused but same has been foisted upon the
applicant accused with malafide intention and ulterior
motive.
2. That accused persons were allegedly armed with deadly

weapons and complainant party was also having government
arms and ammunition and they were on patrolling purpose in
order to stop the crimes but without any resistance and
encounter one out of above arrested by the complainant party
which aspect of the case cuts very roots of the prosecution
story and it is out of understand of the prudent mind to
believe or rely upon the story setup by the complainant party
and their false implication could not be rule out
3. That no any private witness, Mashir or person of locality has
been shown associated by the complainant party in

completing of all
[3]
alleged formalities and all the witness are same police

personal , therefore in-spite of fact that alleged place of
incident thickly populated and residential area and Dargah
of Syed Khanan Shah therefore the false implication could not
be ruled out all to gather and case of the applicant accused
become of further inquiry there is clearly violation of section
103 Cr PC.
4. That applicant/accused is respectable persons and he can not
think into such criminal activities and he has been falsely

implicated in this false and ineffectual case with malafide
intention for the ulterior motive .
5. That the case has been challaned and applicant/accused is no
more required to police.
evidence as all the PWS are police officials and interested

witnesses of the complainant .
7. That applicant/accused is ready to furnish solvent surety to

APPLICANT/ACCUSED
CERTIFICATE


ADVOCATE FOR APPLICANT
/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Hanif Rahu
VS
The State
Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
BAIL APPLICATION

facts and grounds:-
-: F A C T S :-

and his
[2]

shifting
[3]

After usual investigation the police submitted interim

challn by showing the applicant as absconder, thereafter
present applicant accused was arrested and police submitted
supplementary Challan before this Honourable Court who is
in judicial custody hence this Bail application before this
Honourable court on the following grounds .
-: G R O U N D S :-

by the complainant with the malafide intention due to enmity
which is existed in between the complainant and accused.
700. That there are general allegation no specific role, or

overt act is attributed to present applicant accused, mere
there are general allegation of causing the injuries on the
person of deceased and there is no specific role that which fire
arm injuries received by whom accused persons .
701. That as per contents of the FIR complainant stated in his
FIR that some bullets hits to motorcycle by the hands of
accused persons but there is no plausible role against the
accused and once complainant has stated that accused
persons got down the deceased from motorcycle and
thereafter they made firing upon deceased and he fallen
down, wherein one firearm injures was hit to deceased on his
chest which he sustained by co-accused sher Muhammad
then for what purpose accused made firing upon motorcycle,
which makes the clearly doubt in prosecution story alleged in
the FIR is unseen which has not been seen by the complainant
party but they managed a false story and has implicated the
applicant/accused in present case after making consultation
due to above enmity.
[4]
702. That as per facts of the FIR the motive of incident have
been shown to co accused Sher Muhammad but not with
present applicant accused person but mere with the intention
suffering purpose has involved the present applicant accused
otherwise applicant has not participated with co accused.
complainant hence they are well wisher of the complainant.

applicant/accused.

complainant.


arguments.

APPLICANT/ACCUSED
CERTIFICATE


ADVOCATE FOR
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Hanif Rahu
VS
The State

Ahmed
OFFENCE U/S 302, 324, 148, 149 , 427
PPC
AFFIDAVIT
I Haji son of Taj Muhammad by caste Rind Muslim Adult

R/O Village Allah Bux Rind Taluka Kazi Ahmed Distrcit Shaheed
1]. That I am complainant in the above FIR hence well

2]. That after the incident I have lodged this FIR and
implicated the applicant/accused Hanif Rahu who is confined
in District Jail Shaheed Benazirabad.
3] That after registration of FIR our talk for patch up and

make compromise is going mutually with accused Hanif
Rahu, I hope that we will succeed to make compromise with
accused Hanif Rahu in present case/crime.
4] That I have no objection if this Honourable Court may

grant him bail and release him as I can make
compromise with accused Hanif Rahu, I have no more grudge
and hindrance against the accused Hanif Rahu.

Advocate
BENAZIRABAD
B. A. No: OF 2014.
Raham Ali son of Yar Muhammad Mari

.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
OFFENCE U/S 489, 496-A, 450 PPC
BAIL APPLICATION

to release him , on bail in the above case/crime on the
-: F A C T S :-

Ghulam Hussain son of Ghulam Akbar Jamali lodged his FIR
at PS Bandhi On 2-9-2014 at about 16:30 hours, alleging
therein that, he is residing in above mentioned address, he is
married with Mst Ameeran daughter of late Imam Bux Jamali
some 30/32 years ago. To whom he is issueless,. On 24-8-2014
at night time complainant along with his wife Mst Ameeran
and son Zameer Hussain and brother Zanwar Hussain and
other house inmates after taking night meals they went to
sleep on separated cots, the bulbs were alighted of electricity.
At about 3:00 AM, on a
[2]
voice of vehicle and on barking of dogs complainant awoke

up, he went and saw one Dotson was parking outside of their
house , out of them 6 armed persons got down, they forcibly
entered into house of the complainant, the complainant
identified them on light of electricity, namely to be Khan
Muhammad son of Din Muhammad armed with pistol, Din
Muhammad Mari, Arbab Ali Mari, Jafar Ali Mari, Raham Ali
Mari, who all armed with guns, Band Ali Mari armed with
Pistols all sons of Yar Muhammad Mari all R/O Village Illahi
Bux Jamali Deh 65 Nusrat Taluka Daur , meantime Khan
Muhammad Mari and other accused straighten their weapons
and gave Hakkal to keep quit and stated that they will kidnap
to Mst Ameera by saying so Khan Muhammad Mari and
others by dragging wife of the complainant took out, she
raised cries, due to fear of the weapons the remained silent
and not went behind them, meantime all accused went away
by taking away wife of the complainant, towards Katcha path
of northward, thereafter complainant kept themselves on
search but till today complainant could not succeeded to
search out to his wife hence this FIR.

applicant accused . who is in judicial custody hence this first
bail application before this Honourable court on the following
grounds .
-: G R O U N D S :-

by the complainant with the malafide intention.
710. That there is inordinate delay in lodging the FIR for

about more then 7 days without plausible explanation which
and consultation as such false implication of the applicant
accused in present case can not be ruled out.

place but complainant with malafide intention for the ulterior
reasons has
[3]
implicated the applicant accused and other in present case by
managing a strong false story, actual facts are that there is
altercation in between complainant and Illahi Bux and it is
further worth to mention that applicant is Hari of Illahi Bux
Jamali, therefore just to take revenge from Illahi Bux and to get
pressurize to Illahi Bux and his Haries have implicated the
applicant and others in present case otherwise applicant accused
712. That malafide on the part of complainant can be verified

from the facts that house of the complainant is consisted in
mid village and there is no way to enter into house of the
complainant or to commit the offence he without any
applying present mind has used sharp mind just to succeed in
his planning whereas further he disclosed that accused with
deadly weapons have kidnapped to Mst Ameeran but having
the superior population of the village no one single persons
has been associated as a mashir of the case except his well
wisher and family members therefore this story is clearly false
and fabricated one and there is no plausible fact as such case
of the complainant is discontented one.
713. That complainant at the time of leveling the allegation

he could not indicate single scratch or injury or any other
harm but only he has managed present story so that applicant
party come in his terms otherwise applicant is innocent.
714. That the complainant is very well known about the

parentage of the applicant accused and are aware from each
other since long and they are residing same vicinity then how
it can be possible that Mst Ameera has been taken away by
the applicant/accused and others.
715. That there is only malafide on the part of the
complainant no such offence has been committed as such
story narrated in the FIR is not free form doubt and is not
understandable, plausible which is false and fabricated one.
716. That applicant is poor and Hari type whereas due to

arrest of the applicant accused his family members are
sustaining great difficulties of their livelihood.
[4]
717. That during the course of investigation the police was

arrested the applicant accused from same vicinity but they
could not recover any other thing.
718. That section applied in the FIR are not attracting to the
present case as applicant have possessed good reputation in
his vicinity and is poor type he can not thing to indulge into
such criminal activities but complainant just to get him ill-
repute him has made such false story otherwise applicant
accused is innocent.
complainant hence they are well wisher of the complainant .

complainant.
721. That applicant/accused are ready to furnish solvent


arguments.
APPLICANT/ACCUSED
CERTIFICATE


Second Bail Application
IN THE COURT OF 1 ADDITIONAL SESSIONS JUDGE
ST
SHAHEED BENAZIRABAD
B. A. No: OF 2014.
Mumtaz Son of Arbab Bughio

.Applicant/accused
VS
The State ……………….……………………………..………………

Opponent
Crime No: 29/2011 P.S, Daulatpur

OFFENCE U/S 324, 353, 147, 148 PPC
BAIL APPLICATION

-: F A C T S :-
complainant, Mir Muhammad Tanwari lodged his FIR at PS
Daulatpur, On 4-4-2011 at about 18:00 hours, alleging therein
that he along with his subordinate staff left the PS to arrest the
accused required in crime No 28/2011, under section 379, 413,
407 PPC of PS Daulatpur , under entry No 13 dated 4-4-2011
at about 15:30 hours , they departed on private Suzuki when
they reached NHW Raja CNG, where the got spy information
that accused namely Zeesahn son of Zafar Iqbal Arain ,
Arshad son of Zulfiqar Arain R/O Daulatpur town , Rafique
alias Rafi son of Akram Arain R/O village Mari Taluka Kazi
Ahmed in crime No 28 of 2011 of PS Daulatpur were putting
Oil in Darmas and are
[2]
available at house of accused Zeeshan , and Oil is available

there in house in Darams, the police party by getting such
information they departed towards pointed place, when they
reached house of Zeeshan Arain where they saw one person
was standing there, the PC Hakim Ali identified him that this
accused is Zesshan Arain and is required in crime No 28 of
2014, the police stopped their vehicle and they tried to capture
them by surrounding them, meantime police party saw the
five accused persons emerged from house, they were
identified by PC Hakim Ali that they are required in above
mentioned crime, out of the Arshad was armed with pistol,
Rafique alias Rafi having hatchet, Barkat having lathi and two
unknown persons were armed with lathies, who will be
identified if seen again, meantime accused Arshad Ali made
straight fire upon police party with intention to commit their
murder, the police party by taking shelter also made firing in
their defense such firing was continued for about 7/8 minutes
thereafter accused Arshad Arain by making fires running
towards westerns side, meantime time police party captured
the one persons who was having lathies , due to none
availability of the private mashir the PC Hakim Ali and PC
Illahi Bux were made mashirs, the police inquired abouit
parentage of the accused , who disclosed his name Barkat son
of Zulfiqar Arain R/O Daulatpur town, before the mashirs the
body search was conducted of the accused nothing was
recovered, further he disclosed that his brother Arshad and
his two unknown accused persons have laid the Oil in house
of Accused Zeshan in Darams and was stolen the same which
is lying the house of Zeeshan Arain, the police party went to
house of Zeeshan and secured 27 Darams of Oil and they
made mashirs at about 16:40 hours before the mashirs, of
stolen Oil, thereafter police by arresting the accused put them
in private Suzuki and they brought the Oil and accused at PS

applicant accused . who is in judicial custody , A Bail
application was filed by the applicant but due to none
appearing he was shown absconder and bail was rejected
thereafter applicant filed this second bail application on
following grounds .
[3]
-: G R O U N D S :-

committed the alleged offence , but he has been falsely

by the complainant, just to show his efficiency otherwise, no
such incident was ever took place .
725. That no oil as foisted has been recovered from the

applicant just there are allegation against the applicant
accused just to make a false story.

verified form the facts that firing made both sides continued
for about 7/8 minutes but no single firearm injury sustained
by either or not damaged to police vehicle nor single scratch
was indicated by complainant party and it is worth to
mention that during and after the firing no empty was
recovered by police thus-far which indicated that
complainant has managed the above story which is creating
highly doubt and is not free from doubt.

his subordinate there is no substances on the record which
connect the applicant/accused with the alleged offence.
728. That none of the applied section are applicable to the

case of the applicant as per the facts and its ingredeince and
as such the case against the applicant/accused is that of
further inquiry.
729. That there is ineffective firing no specific role , part,

overt act is assigned to the applicant/accused mere there are
general allegation against the applicant/ accused otherwise
applicant/ accused have no concerned with the alleged
offence.
730. That no recovery has been affected from personal

possession of the applicant/ accused
[4]
731. That there is no name of the applicant accused in the FIR

he has been implicated in further statement which is not
admissible.

evidence.


arguments.

APPLICANTS/ACCUSED
CERTIFICATE

ADVOCATE FOR APPLICANT/ ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
1. Zeeshan son of Ayoob Qureshi

2. Qadeer son of Muhammad Ramzan Rajput
Both Presently confined in District Jail
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION
-: F A C T S :-

complainant, ASI Shahzad Khan Memon lodged FIR at PS
Airport. On 3-8-2014 at about 2:000 hours alleging therein
that, he along with his subordinate staff, containing the
government ammunition, On government vehicle Number SP
3512 alongwith deriver Inayat Hussain udner Roznamacha
entry Number 20, dated 3-8-2014 at about 17:15 hours, within
their beat departed for patrolling, various palces of city when
they reached Faiz patrol Pump , wehre they got spy
information that accused wanted namely Qadeer Qu8rehsi ,
Zeeshan Qureshi, Saleem Rajput in crime Number 48/2014
and 149/2014 under section 398, 401 PPC of PS airport , were
standing at Jara Wah for commiting the offence, the police
party rushed towards pointed place , where they saw three
persons were standing at Jara Wah, identified which to be
Zeshan Qureshi armed with pistol, Qadeer armed with pistol,
Saleem Rajput armed with lathi, the police party immidaitely
got down and raised Hakkal, tried to capture them, they made
straight firing from upon police party with intention to
commit murder, the police also made firing in their denfense ,
meantime accused by made hands up and became ready to
hand over themselves to police party, meantime police
commanded to give their weapons and for arrest and police
arrested them, the firing made continued for about 10
minutes, the police party tried to prepare but due to none
avaiablity of the private mashir, the HC Ghulam Mustafa and
Wali Muhammad were acted for mashir, the police inquired
the name parantge to captured persons who disclosed their
name to be Qadeer son of Muhammad Ramzan Rjaput resient
near Tayaba Masjid Ghulam Rasool Shah Colony Nawabshah,
to whom police recovered pistol of 30-Bore which was
unloaded , meantime police opned the magazine and secured
two live bullets and pistol was in running condition , second
person dislcsoed his name to be Zeeshan son of Ayoob
Qureshi resident of Ameer Shah Colony-11 Nawabshah to
whom poice recovered pistol of 30-bore, the police open the
magazine in which 4 live bullets were secured which was
unloaded same was in running condition, third person
disclosed his name to be Saleem son of Youisif Rajput resident
near Tayaba Masjid, Ghulam Rasool Shah colony to whom
police recovered lathi which was of BANS type, the
complainant party smilled the weapons in which smilling was
scattered of gunpowder, the complainant party conducted
body search of above three persons but nothing was
recovered which only were worn the cloths, meantime
complainant party arrested them under section 324, 353, PPC
and 23-A , 25-SAA and in crime number 48/ 2014, 49/ 2014
under section 401, 398 PPC of PS Airport, the complainant
party sealed separately pistols and made mashir before the
mashirs and brought the accused and recovered property to
PS and lodged present FIR.

applicant accused . The applicants/accused are in judicial
custody hence this first bail application before this
-: G R O U N D S :-
736. That the applicants/accused are innocent and had not
committed the alleged offence , but they have been falsely

738. That falsehood of the case can bee verified from the facts
that, the alleged incident is said to have been taken place at
Jara Wah, it is admitted that the applicants/ accused duly
armed with lethal weapons were standing at the Jara Wah
but complainant has no disclosed that for what and why
accused persons were standing with lethal wpeaons which
creates doubt whereas there is seriouis doubt in prosecution
story which is put forth.

for about 10 minutes but no single firearm injury sustained by
either or not damaged to police vehicle nor single scratch was
indacited by complainant party and it is worth to mention
that during and after the firing no empty was recovered by
police thus-far which indicated that complainant has
managed the above story which is creating highly doubt and
is not free from doubt.

connect the applicants/accused with the alleged offence.

as such the case against the applicants/accused is that of
further inquiry.

overt act is assigned to the applicants/accused mere there are
general allegation against the applicants accused otherwise
applicants accused have no concerned with the alleged
offence.
743. That the crime weapons as alleged has been foisted

upon the applicants /accused just to establish the case against
them which has been malafidly foisted upon otherwise
nothing has been secured from the applicants.
744. That complainant have shown the series of the case

againt the applicants accused just to drag them and get ill-
repute in their vicinity so that they may come in their temrs
otherwise applicants accused are innocent.

evidence.
747. That applicants/accused are ready to furnish solvent


arguments.
AYAZ ALI GOPANG
APPLICANTS/ACCUSED
CERTIFICATE

behalf of the applicants/accused before this Honourable Court,
prior to this no any bail application has been filed by the
applicants/accused before this Honourable Court or before any
ADVOCATE FOR APPLICANTS ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
1. Dhani Bux alias Dhano son of Shah Baig chandio

R/O Nangar Khan Chandio Taluka Sakrand
2. Akhtiar Ali son of Sanjar chandio
R/O Village Jalal Chandio Taluka Saeedabad
District Matiyari ….. …………………………………
Applicants/Accused
VERSUS
The State ………………………… ……………………………………

Opponents
Crime No: 202/2014, PS Sakrand

U/S 337L(ii), 381, 215 PPC
BAIL APPLICATION
It is prayed on behalf of the applicant/accused named

above that this Honourable Court may be pleased to release them
on bail, on bail in the above case/crime on consideration of the
following facts and ground.
-: F A C T S :-
The facts of the case are that the complainant, Muhammad Yousif
son of Faqeer Muhammad lodged his FIR at PS Sakrand, On 14-9-
2014 at about 2:000 hours, alleging therein that, he has motorcycle
for his personal use at bellow detailed, some 1, ½ months back
complainant seated his motorcycle and departed to Sahito Jokhio
road near Shahbaz Minor he parked his motorcycle, and he started
fresh in minor at about 2:00 PM he came at Mori where he saw the
his motorcycle was not available there, which was stolen away,
thereafter complainant kept
[2]
himself on searching, whereas one namely Dhani Bux alias dino son
of Shah Baig Chandio met with complainant and he demanded
ransom amount of Rs 13000/- for returning the motorcycle
thereafter complainant along with his brother Ali alias Arif and his
relative Bashir Ahmed son of Muhammad Yaqoob Rajput went to
dhani Bux chandio to retuning the motorcycle and gave amount of
Rs 13000/- for returning their motorcycle but he only kept the
complainant party on false hopes, whereas neither he returned the
motorcycle nor return the ransom amount, today complainant
alongwith above witnesses went to Dhani Bux alias Dino chandio
where they saw accused Akhtiar Ali sonof Sanjar Chandio resident
of Jalal Chandio near Bhali Dino Kaka Taluka Saeedabad and one
unknown accused persons who shall be identified if seen again,
where complainant party met with Dhani Bux Chandio and
demanded for their amount, on which they annoyed and caused
lathies on his back and on deferent part of the bodies, and Dhani
Bux alias Dino Chandio caused lathi blows to accused Akhtiar Ali
Chandio and blood was oozing thereafter complainant alongwith
his witnesses came at PS and lodged present FIR.
After registering of the FIR, the police of PS Sakrand

arrested the applicants/ accused, since their arrest , who are in
judicial custody hence , hence this bail application on the following
grounds
-: G R O U N D S :-
1. That the case registered against the applicants/ accused is false

and fabricated, they have falsely been implicated in present case
otherwise they have no committed offence as alleged .
2. That there is delay in lodging the FIR for about more then one
and half months without any plausibly explanation which goes
to show that the same FIR has been lodged after deliberation and
core consultation of complainant and his sweet obligor otherwise
applicants is innocent and is not concerned with the alleged
offence.
3. That in fact no such incident whatsoever stated in the FIR has

ever taken place but complainant just by applying his sharp
mind has managed a false story otherwise applicants/accused
have no concerned with the alleged offence.
[3]
4. That malafide on the part of the complainant can be verified

from the facts that how it can be possible that in his presence
motorcycle has been stolen away and he could not see accused
and at time of incident he did not try to track foot prints but only
he by showing malafide has kept search , therefore such story is
discontented one and applicants accused are not concerned with
alleged offence.

from the facts that there is no medical certificate and if the
injuries sustained by the complainant party, then why not
approach to police station to get letter for medical treatment but
there is no malafide on the part of the complainant therefore
applicants accused are not concerned with the alleged offence.
6. That in fact no such incident as alleged in the FIR has ever been
taken place there is no specific role, injury, overt act assigned to
the applicants accused mere there are general allegation ,
whereas such case is managed one and is not free from doubt.
7. That case has been challaned and applicants accused are no more
8. That applicants accused have possessed good reputation but

complainant by managing a false story has implicated them in
false case otherwise they have no concerned with alleged offence.
9. That amount has been foisted upon the applicants party just to
manage a false story otherwise applicants accused are
respectable persons and they can not think to indulge into such
criminal activities.
10.That the applicant/accused is neither disparate criminals,
habitual offenders, or previous convicted as per instructions.
11.That PWs cited in the FIR are setup and well wisher of the
12.That there is no apprehension of the tempering with the evidence
[4]
as all the PWs cited in the FIR are interested and ill-wisher of
the applicant party.
13.That applicants/ accused are ready to furnish their solvent

surety to the satisfaction of this Honourable Court
14.That the other ground will be urged at the time of arguments

with permission of this Honourable Court.

APPLICANTS/ACCUSED
CERTIFICATE

ADVOCATE
FOR THE APPLICANTS/
ACCUSED

Special case No. of 2014.
Muhab Ali Haji Muhab Ali son of Haji Muhammad Arib

Chandio Muslim Adult R/O Village Nanagar Khan
Chandio Taluka Kazi Ahmed District Shaheed
Benazirabad Presently confined in District Jail
Shaheed Benazirabad ………….………………………
Applicant/accused
VS
The State………………………..……………………….
………….Opponent

BAIL APPLICATION

applicant/accused , named above, that this Honourable
Court may be pleased to release him, on bail in the above
grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant SIP

Muhammad Rahim Gopang SHO of PS Jam Dattar lodged his
Fir at PS Jam Dattar, on 1-9-2014 at about 9:40 hours, alleging
therein that today complainant alongwith his subordinate
staff, containing the government ammunition and on
government vehicle SP No. 224 along with driver under entry
No 4 dated 1-9-2014, at about 08:30 hours, departed for
patrolling within beat, various places when they reached
Khosa Patrol Pump , where they got spy information that
Muhab Ali chandio, is selling the chars in Cricket ground at
[2]
Nawabshah stadium, when at about 9:00 hours, the police

after getting such information departed towards place of
incident, they saw one person was standing towards gate of
stadium containing one shopper of black color, who by seeing
the police vehicle and tried to skip away, the police party very
skillfully encircled him and captured, and secured one plastic
shopper, they saw 10 piece of chars alongwith knife, the police
party inquired about name parentage, which he disclosed his
name to be Muhab Ali son of Haji Muhammad Arib by caste
Chandio Muslim Adult R/O Nangar Khan chandio Taluka
kazi Ahmed, due to none availability of the private Mashir PC
Illahi Bux Chutto and PC Muhammad Ali Solangi were made
mashirs, the police party secured Rs 200 from right side of
pocket of the accused, the Chars was weighed which became
4050 grams, in which police separated 300 grams for chemical
analyzer and remaining sealed separately, police further
inquired about chars, on which he disclosed he used to sale as
professionally, the police brought the accused with recovered
property at PS where they lodged present FIR.
After usual investigation, the challan was submitted before

competent court of law, accused was brought in judicial
custody. , hence the applicant accused got filed present bail
application before this Honourable Court with following
ground.
-: G R O U N D S :-
201. That the applicant is innocent and had not committed

the alleged offence and he has falsely been implicated in
present case with malafide intention for the ulterior reasons.

FIR has ever taken place but complainant by showing his
has foisted huge quantity of narcotics substance upon the
applicant just to oblige him so that he come in his illegal terms
[3]
203. That the recovery foisted upon the applicant is

gratuitousness such case facts narrated in the FIR are
discontented one.

thickly populated and there is in huge number population is
heart of the city such area but complainant by showing wrong
place of incident has shown his tactically mind.




APPLICANT/ACCUSED
CERTIFICATE

applicant, prior to this no bail has been filed before this or

Muhab Ali Haji Muhab Ali son of Haji Muhammad Arib

Chandio Muslim Adult R/O Village Nanagar Khan
Chandio Taluka Kazi Ahmed District Shaheed
Benazirabad Presently confined in District Jail
Shaheed Benazirabad ………….………………………
Applicant/accused
VS
The State………………………..……………………….
………….Opponent
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that Complainant SIP

Muhammad Rahim Gopang SHO of PS Jam Dattar lodged his
Fir at PS Jam Dattar, on 1-9-2014 at about 9:40 hours, alleging
therein that today complainant alongwith his subordinate
staff, containing the government ammunition and on
government vehicle SP No. 224 along with driver under entry
No 4 dated 1-9-2014, at about 08:30 hours, departed for
patrolling within beat, various places when they reached
Khosa Patrol Pump , where they got spy information that
Muhab Ali chandio, is selling the chars in Cricket ground at
[2]
Nawabshah stadium, when at about 9:00 hours, the police

after getting such information departed towards place of
incident, they saw one person was standing towards gate of
stadium containing one shopper of black color, who by seeing
the police vehicle and tried to skip away, the police party very
skillfully encircled him and captured, and secured one plastic
shopper, they saw 10 piece of chars alongwith knife, the police
party inquired about name parentage, which he disclosed his
name to be Muhab Ali son of Haji Muhammad Arib by caste
Chandio Muslim Adult R/O Nangar Khan chandio Taluka
kazi Ahmed, due to none availability of the private Mashir PC
Illahi Bux Chutto and PC Muhammad Ali Solangi were made
mashirs, the police party secured Rs 200 from right side of
pocket of the accused, the Chars was weighed which became
4050 grams, in which police separated 300 grams for chemical
analyzer and remaining sealed separately, police further
inquired about chars, on which he disclosed he used to sale as
professionally, the police brought the accused with recovered
property at PS where they lodged present FIR.

ground.
-: G R O U N D S :-
209. That the applicant is innocent and had not committed

the alleged offence and he has falsely been implicated in
present case with malafide intention for the ulterior reasons.

FIR has ever taken place but complainant by showing his
has foisted huge quantity of narcotics substance upon the
applicant just to oblige him so that he come in his illegal terms
[3]
211. That the recovery foisted upon the applicant is
gratuitousness such case facts narrated in the FIR are
discontented one.

thickly populated and there is in huge number population is
heart of the city such area but complainant by showing wrong
place of incident has shown his tactically mind.





APPLICANT/ACCUSED
CERTIFICATE

IN THE COURT OF 3rd ADDITIONAL SESSIONS JUDGE

SHAHEED BENAZIRABAD
B. A. No: OF 2014.
The State
VS
Akbar alias Anda Bacha and others
Crime No: 76/2012, PS Airport

Nawabshah
U/S 302 , Q 148 PPC
BAIL APPLICATION
It is prayed on behalf of the applicant/accused namely

Muhammad Akbar alias Anda Bacha son of Ali Muhammad , that
this Honourable Court may be pleased to release him, on bail in the
above case/crime on consideration of the following facts and
ground.
-: F A C T S :-
The facts of the case are that the complainant, Muhammad Ashraf
son of Muhammad Aslam Qureshi, lodged present FIR at PS
Airport Nawabshah, on 13-10-2012 at about 23:30 hours. Alleging
therein that, complainant runs business of fruit , Imran alias Bhooro
is younger brother of the complainant, t hey both mutually used to
reside in and same house, whereas Tarique alias Bablu son of
AKbar Fouji is residing in same village, who has friendly cordial
relations with brother of the complainant, yesterday, yesterday
there hot words have been extent in between Tarique alias Bablu
and Imran Bhooro, on that account Tarique and his friends used to
say that they will not spare the Imran alias Bhooro and they will kill
him, tonight complainant and his brother Imran alias Bhooro aged
about 27/28 years Hussain Tarique, were going to city
[2]
at about 8:00Pm they reached at Sonara Street near Tayaba Masjid,

they saw on the street’s light of Bulbs, and identified each to be
Ratique alias Babloo, armed with pistol, Akbar alias Fouji son of not
known armed with pistol, Akbar alias Anda Bacha son of Ali
Muhammad armed with pistol , Zeeshan son of Yaseen Malak
Biriyani wala having dagger, Shah son of knot known, were
standing there, they all extend abusive language to brother of
complainant namely Imran Alias Bhooro, and saying that they will
kill to Imran alias Bhooro, whereas accused armed with pistol made
straight fires upon complainant party, with intention to commit
murder, meantime Tarique alias Bablu made straight fire upon
brother’s of complainant who fallen down on earth, meanwhile
Shan caught hold to Imran alias Bhooro and Zeeshan caused
Dagger blows to him which hit him on his back side and issued
threats to complainant party not to come near them, otherwise they
would be murdered after that on the fire arm reports complainant’s
cousin Muhammad Farooq Qureshi and other Mohalla peoples
arrived by running, due to fear complainant party could not went to
near them all the accuse persons escaped well in the street
complainant party then saw that his brother sustained firearm
injury on his left shoulder and fire was hit through and through and
was also injury on his back and blood was oozing, within seeing of
the complainant the, the blood was pouring from injured, thereafter
complainant brought him at Civil Hospital with the help of above
named PWs, where injured expired and complainant then informed
such facts to the police of PS Airport Nawabshah and after
conducting postmortem at Civil Hospital complainant came at PS
and lodged present FIR
After registering of the FIR, the police of PS Airport

Nawabshah arrested the applicant/ accused, since his arrest, who is
behind the bar in judicial custody, hence this bail application on the
following grounds
-: G R O U N D S :-
15.That the case registered against the applicant/ accused is false

and fabricated, he has falsely been implicated in present case
otherwise he has committed no offence as alleged.
16.That there is delay in lodging the FIR for about more then 4
hours
[3]
Without any plausibly explanation which goes to show that the

same FIR has been lodged after deliberation and core
consultation of complainant and his sweet obligor otherwise
applicant is innocent and is not concerned with the alleged
offence.

ever taken place but complainant just to applying his sharp mind
has managed a false story and plausibly he has suppressed and
concealed the actual facts, where as fact pertinent to the matter
and it is worth to mention that there is no still plausibly
explanation of confliction if any raised in between deceased
Imran alias Bhooro and Tarique and there is no mention of any
petty dispute if any raised ever in between the Imran alias
Bhooro and Traique alias Bablu, but complainant only has
indicated that hot words extended in between deceased Imran
alias Bhooro and Tarique alias Bablu thus-far there is unjustified,
unclear, implausible and is unworthily in eye of law therefore
case of the complainant is false and fabricated one , furthermore
applicant/accused has no utter concerned with the alleged
offence.
18.That malafide on the part of the complainant can be verified

from the facts , as per facts of the FIR complainant stated that
persons armed with deadly weapons and they in together made
straight fires upon complainant and his deceased brother with
intention to commit murder of complainant party, but no single
firearm injury or scratch sustained by complainant or Hassan
Tarique during, whereas incident has been shown on same day
at about 10:15 hours but which was continued for about 15
minutes but during that time no single firearm, single scratch or
other serious hurt sustained by the complainant and Hassan
Tarique and they remained safely without cause of harm on their
person, thus-far story narrated in the FIR clearly is not believable
and is discontented one.

from the facts as per contents of the FIR that he has shown place
of incident in Sonara Street near Tayaba Masjid , whereas
diffidently such place is highly populated and is part of heart
city but there is no single empty
[4]
recovered by complainant party which fired in commission of

the offence nor single person has been shown as independent or
private witness having the superior population but complainant
without corroborating the version of the FIR has only implicated
the applicant and others by taking inequities , thus-far there is
clearly violation of section 103 Cr PC which makes the
applicant/accused entitle for the concession of bail.

from the facts as per facts of the case he alleged that he
alongwith his deceased brother and Hassan Tarique were going
to city by leaving their house but there is highly contradiction in
story that he could not disclosed that for what he was going and
which work they had to do thus-far there is malafide on the part
of the complainant and such malafide which goes in favour of
the applicant /accused to give him benefit at bail stage.

from the facts as per contents of the FIR complainant disclosed
that accused Tarique made fire upon Imran alias Bhooro and
who fallen down on earth, meanwhile he further disclosed role
of Zeeshan and Shan that shan caught hold from back side of
neck and Zeeshan caused dagger blows to him then how it can
be possible that persons has already sustained firearm injury and
who was in serious contradiction and was fallen down then in
meanwhile they caught hold him which creates clearly doubt in
prosecution story which makes the case of the complainant false
with unsupportable facts which makes the applicant entitle for
concession of bail.
22.That as per facts of the FIR complainant disclosed that applicant

accused party fired upon complainant party with intention to
commit murder but they could not succeeded to apply section
324 Cr PC and directly they by taking ineffectual facts and
leveling the allegation has applied section 302 PPC which
unattractive to the present case as per facts of the FIR.
23.That there is no direct or specific role , or injury as overt act of

the applicant/accused mere there is only presence of the
applicant with
[5]
in-effective firing which is un-specifically narrated by the

complainant, thus-far applicant is innocent he has no committed
offence and his implication has been shown with malafide
24.That the applicant/accused is neither disparate criminals,

25.That in fact no such incident as alleged in the FIR has ever taken
place whereas applicant without any plausibility has been
booked in present case by the complainant whereas complainant
by engineering false case by taking the advantage of his deceased
brother and by using sharp mind has implicated the applicant
and just narration of the complainant in FIR are concocted,
fabricated and are understandable and it is worth to mention
that complainant only to take undue and unjustifiable
advantage has implicated the applicant and others so that they
may come in his terms, otherwise applicant has unconcerned
26.That PWs cited in the FIR are setup and well wisher of the
27.That applicant accused was arrested on 20-10-2012 and since

then he is behind the bar and during such long period
prosecution has failed to examine a single witness which shows
that prosecution has no interest whatsoever in the proceeding of
case and without any fault applicant accused is facing hardship,
as case will take much more time and further detention of
applicant accused in jail would ruin his future as well as life
28.That case against the applicant/accused is of such a nature

which can only be established after leading evidence on record,
hence at this stage applicant accused is entitle for concession of
bail.
29.That case has been challaned and no incriminating has been

secured from the applicant accused and he is in jail since his
arrest hence he is no more requires to police for further
investigation purpose.
[6]

as all the PWs cited in the FIR are interested and ill-wisher of the
applicant party.
31.That applicant accused is ready to furnish their solvent surety

to the satisfaction of this Honourable Court
32.That the case of the applicant/accused is pendent before this

Honourable Court and case of the applicant accused is of further
inquiry
33.That the other ground will be urged at the time of arguments
with permission of this Honourable Court.
34.That the Copy of the FIR of present case is attached herewith

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
FOR THE APPLICANT
ACCUSED
BENAZIRABAD
B. A. No: OF 2014.

.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

Airport. On 30-7-2014, at about 23:00 hours, alleging therein
their beat departed for patrolling, various places when at
about 19:30 hours they reached Sbazi Makret Road, they saw 4
accused persons armed with pistols were standing which
identified each to be Saleem son of Yousif on the head light of
the mobile and identified each Qadeer son of Muhammad
Ramzan, Saleem Son of Yousif Rajput Both R/O Tayyaba
Masjid Ghulam Rasool Shah Colony, Zeeshan son of Ayoob
Qureshi R/O Ameer Shah Colony Nawabshah Disrict SBA,
who by sensing the private vehicle also signaled to stop, the
police by alarming them of police got dwon and tried to
capture them but they by taking advantage of darkness
skipped away to eastern side, the complainant party also went
behind the accused persons to capture them but they
succeeded to run away thereafter complainant party came at
PS and lodged present FIR .

-: G R O U N D S :-


Ghulam Rasool Shah Colony Link Road near Madrsa which is
city area, and hwo it can be possible that accused with
without weapons were standing with intention to commit
offence or stopped to vehicle which creates highly doubt
whereas there is serious doubt in prosecution story which is
put forth otherwise applicants accused are innocent.

verified form the facts as per contents of the FIR how it can be
possible that accused persons skipped away although
accused were standing in close range which indicated from
malafide on the part of the complainant that such story has
been foisted upon the applicants accused just to pressurize
and blackmail them otherwise applicants accused have no
concerned with the alleged offence .

754. That there are general allegation no any overt act is

assigned or attributing the applicants accused.

further inquiry.


evidence.


arguments.
AYAZ ALI GOPANG

APPLICANTS/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2014.

.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

Airport. On 26-7-2014, at about 20-30 hours, alleging therein
their beat departed for patrolling, various places when at
about 19:30 hours they reached Ghulam Rasool Shah Colony
which lead through link Road near Madrsa, they saw on the
head light of the mobile and identified each Qadeer son of
Muhammad Ramzan, Saleem Son of Yousif Rajput Both R/O
Tayyaba Masjid Ghulam Rasool Shah Colony, Zeeshan son of
Ayoob Qureshi R/O Ameer Shah Colony Nawabshah Disrict
SBA, who by sensing the private vehicle also signaled to stop,
the police by alarming them of police got dwon and tried to
capture them but they by taking advantage of darkness
skipped away to eastern side, the complainant party also went
behind the accused persons to capture them but they
succeeded to run away thereafter complainant party came at
PS and lodged present FIR .

-: G R O U N D S :-


Ghulam Rasool Shah Colony Link Road near Madrsa which is
city area, and hwo it can be possible that accused with
without weapons were standing with intention to commit
offence or stopped to vehicle which creates highly doubt
whereas there is serious doubt in prosecution story which is
put forth otherwise applicants accused are innocent.

verified form the facts as per contents of the FIR how it can be
possible that accused persons skipped away although
accused were standing in close range which indicated from
malafide on the part of the complainant that such story has
been foisted upon the applicants accused just to pressurize
and blackmail them otherwise applicants accused have no
concerned with the alleged offence .

766. That there are general allegation no any overt act is

assigned or attributing the applicants accused.

further inquiry.


evidence.


arguments.
AYAZ ALI GOPANG

APPLICANTS/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2014.

.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

Airport. On 3-8-2014 at about 2:000 hours alleging therein
their beat departed for patrolling, various palces of city when
they reached Faiz patrol Pump , wehre they got spy
information that accused wanted namely Qadeer Qu8rehsi ,
Zeeshan Qureshi, Saleem Rajput in crime Number 48/2014
and 149/2014 under section 398, 401 PPC of PS airport , were
standing at Jara Wah for commiting the offence, the police
party rushed towards pointed place , where they saw three
persons were standing at Jara Wah, identified which to be
Zeshan Qureshi armed with pistol, Qadeer armed with pistol,
Saleem Rajput armed with lathi, the police party immidaitely
got down and raised Hakkal, tried to capture them, they made
straight firing from upon police party with intention to
commit murder, the police also made firing in their denfense ,
meantime accused by made hands up and became ready to
hand over themselves to police party, meantime police
commanded to give their weapons and for arrest and police
arrested them, the firing made continued for about 10
minutes, the police party tried to prepare but due to none
avaiablity of the private mashir, the HC Ghulam Mustafa and
Wali Muhammad were acted for mashir, the police inquired
the name parantge to captured persons who disclosed their
name to be Qadeer son of Muhammad Ramzan Rjaput resient
near Tayaba Masjid Ghulam Rasool Shah Colony Nawabshah,
to whom police recovered pistol of 30-Bore which was
unloaded , meantime police opned the magazine and secured
two live bullets and pistol was in running condition , second
person dislcsoed his name to be Zeeshan son of Ayoob
Qureshi resident of Ameer Shah Colony-11 Nawabshah to
whom poice recovered pistol of 30-bore, the police open the
magazine in which 4 live bullets were secured which was
unloaded same was in running condition, third person
disclosed his name to be Saleem son of Youisif Rajput resident
near Tayaba Masjid, Ghulam Rasool Shah colony to whom
police recovered lathi which was of BANS type, the
complainant party smilled the weapons in which smilling was
scattered of gunpowder, the complainant party conducted
body search of above three persons but nothing was
recovered which only were worn the cloths, meantime
complainant party arrested them under section 324, 353, PPC
and 23-A , 25-SAA and in crime number 48/ 2014, 49/ 2014
under section 401, 398 PPC of PS Airport, the complainant
party sealed separately pistols and made mashir before the
mashirs and brought the accused and recovered property to

-: G R O U N D S :-


Jara Wah, it is admitted that the applicants/ accused duly
armed with lethal weapons were standing at the Jara Wah
but complainant has no disclosed that for what and why
accused persons were standing with lethal wpeaons which
creates doubt whereas there is seriouis doubt in prosecution
story which is put forth.

for about 10 minutes but no single firearm injury sustained by
either or not damaged to police vehicle nor single scratch was
indacited by complainant party and it is worth to mention
that during and after the firing no empty was recovered by
police thus-far which indicated that complainant has
managed the above story which is creating highly doubt and
is not free from doubt.


further inquiry.

overt act is assigned to the applicants/accused mere there are
general allegation against the applicants accused otherwise
applicants accused have no concerned with the alleged
offence.


evidence.


arguments.
AYAZ ALI GOPANG

APPLICANTS/ACCUSED
CERTIFICATE


BENAZIRABAD
B. A. No: OF 2014.

10.Qadeer son of Muhammad Ramzan Rajput
Shaheed Benazirabad ………………….. ………
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 23-A, 25-SAA
BAIL APPLICATION

-: F A C T S :-

Airport . On 3-8-2014 at about 21:00 hours, arrested accused
Zeeshan son f Ayoob Qureshi R/O Ameer Shah Colony
Nawabshah from his possession handed over Pistol of 30-bore
containing the bullets, has committed offence udner section
23-A and 25-SAA, therefore case has been registered against
him and a separate case registers upon applicant. Hence this
present FIR.

applicants accused , the applicants/accused are in judicial
custody hence applicants/accused got filed present bail
grounds.
-: G R O U N D S :-


otherwise applicants accused have no concerned with the
alleged offence.
788. That the pistols in-question have been foisted upon the
applicants/accused and applicants have no concerned with
the alleged weapons, but complainant just to drag the
applicants/accused before the competent court of law has
lodged present FIR by leveling allegations otherwise there is
no any substance and substantial record which connect with
the applicants/accused

which connect the applicants/accused with the alleged
offence merely there are general allegation just to bow down
the applicants otherwise alleged story is made out and is
implausibly .

verified from the facts that under the one and same
Mashirnama of the arrest and recovery of two separate FIRs
have been registered against the applicants/accused and
complainant by managing false case has implicated the
applicants accused otherwise applicants/accused have no

792. That the present case is nothing but complainant by

showing his effieciency just to ill-repute the
applicants/accused has lodged present FIR which is
discontented one .
794. That applicants/accused have already been granted on

bail in main case


evidence as applicants/accused they are to furnish solvent

arguments.

APPLICANTS/ACCUSED
CERTIFICATE
This is to certify that this is connected case

with main case on behalf of the applicants/accused before this
Honourable Court.

Aslam son fo Muhammad Hassan Chandio

Shaheed Benazirabad ………….………………Applicant/accused
VS
The State………………………..…………………………….Opponent

Offence, 6/ 9/C, CNSO ,
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that SIP Ghulam Qadir jatoi
SHO of PS Sakrand lodged his FIR at PS Sakrand . on 20-7-
2014 at about 19:00 hours, alleging therein that, today
complainant alongwith his subordinate staff containing the
government ammunition, on government vehicle Number SP
3504 along with driver Mujahid Hussain, under the entry
Number 18 dated 20-7-2014 at about 17:20 hours, left the PS
for patrolling various places wheh they reached at Shalimar
Adda, they got spy information that one persons is selling out
Chars openly at Fital Railway
[2]
Station Sakrand who already is involved in crime Number

157/2014 under sections 324, 353 398 , 402 PPC of PS Sakrand,
the complainant by receiving such information rushed
towards the pointed place, the police party saw the one
person by seeing the police mobile tried to run away, the
police party by getting down from their vehivle they encircled
very skillfully, and captured the above person, to whom
police party inquired about his name parentage, he disclosed
his name to be Aslam son of Muhammad Hussain Chandio
R/O Sharif Chandio near Paghrio Mori Taluka Sakrand, due
to none availability of the private mashir , the PC Raj
Muhammad Palli and Muhammad Yaseen Lund were acted
for mashirs, meantime police party conducted body searched
to captured person, to whom police secured one plastic
shopper from his Shalwar, which police party kept in their
possession, and opened the same, in which to big pieces of
chars were available, the total chars weighted 1500 grams, in
which 100 grams sealed separately for chemical examiner and
remaining chars sealed separately, from his body search
police secured five currency note of 100/100 total Rs 500/-
which police kept in their possession further they inquired
about chars which recovered from accused, which he
disclosed that he used to sale the same on money as
professionally on deferent places thereafter police party
brought the accused containing the recovered property to PS

ground.
-: G R O U N D S :-
217. That the applicant is innocent and had not committed the
alleged offence and he has falsely been implicated in present case
with malafide intention for the ulterior reasons.
218. That in fact no such incident whatsoever stated in the FIR has
ever taken place but complainant by showing his efficiency just
to falsely
[3]
implicate the applicant in present case has foisted huge quantity

of narcotics substance upon the applicant just to oblige him so
that he come in his illegal terms otherwise applicant/accused is
innocent he has no concerned with the alleged offence.
219. That the recovery foisted upon the applicant is gratuitousness

such case facts narrated in the FIR are discontented one.

from the facts that place of incident is not unpopulated, it is
worth to mention that such place cited in the FIR is thickly
populated and there is in huge number population and is city
which was called in pass period as Fital Railway station now that
place is to be called as Citizen area but complainant by showing
wrong place of incident has shown his tactically mind.

superior population the complainant could not perform his duty
honestly to act for independent witness whereas all the PWs
cited in the FIR are Chandia by caste and are hostile towards the
applicant as well as they are well wisher of the complainant and
they are sweet obligor of the complainant.
222. That PLD there is delay of 4 days in sending the sample to

chemical analyzer though , which creates doubt in the
prosecution story which makes the applicant entitle for the
concession of the bail .
223. That the case of the applicant falls in second category of
section 497 Cr PC, where the grant of the bail in cases punishable
is 4 years as per recent case law of Gulzar VS the state, therefore
this case doesn’t fall within the prohibitory clause of section 497
Cr PC.
224. That applicant/accused has already been granted on bail in

main case/crime number 157/2014 of PS Sakrand, crime
Number 159/2014 of PS Sakrand but complainant just to drag
the applicant in false case has managed present case otherwise it
is shown clearly in story put forth in the FIR that applicant is
innocent and he has no concerned with the alleged offence.
[4]
225. That the applicant/accused has possessed good reputation in

lack to show his efficiency just to blackmail and pressurize him.

227. That other ground will be urged at the time of hearing when
Dt__________ ADVOCATE FOR APPLICANT/ACCUSED
CERTIFICATE
IN THE COURT OF SESSIONS JUDGE NAUSHAHRO FEROZE
B. A. No: OF 2014.
Zafar Son of Muhammad Saffar by caste Soomro

R/O Original Daulatpur Town Taluka Daulatpur
District Shaheed Benazirabad at present Malak
Colony Moro Taluka Moro District N-Feroze
….....Applicant/accused
VS
The State .………….………………………………………………….……

Opponent
Crime No: 179/2014, PS, Moro

U/S 380, 457 PPC
BAIL APPLICATION
It is prayed on behalf of the applicant/accused above
named, that this Honourable Court may be pleased to release him,
on bail in the above case/crime on consideration of the following
facts and ground.
-: F A C T S :-
The facts of the case are that the complainant Mir Sahib son of
Dadan Khan Lund, R/O village Azeem Shah Deh 16 Dad, Taluka
Nawabshah, District Shaheed Benazirabad lodged his FIR at PS
Taluka on 21-3-2014 at about 12:00 hours, the lands 50/60 Acres of
the Syed Janib Shah is consisted in Deh 16 Dad Taluka Nawabshah,
in which complainant cultivated 12 Acres on Harap harp basis, in
which 6 Acres are Sarsoon crop and 2 Acres are Banana crops and
wheat crops is cultivated in 4 acres, the complainant heaped 6 Acres
Sarsoon for harvest purpose at the land, on 17-3-2014 complainant
was present at his land, alongwith changal khan and Riaz Hussain
at about 3:00 hours they saw the one car ALTO white Color came
there in which Zahid Shah, Sajjad, Faheem,
[2]
R/O Bhangwar Colony all having hatchets, they by seeing the

complainant told that our dispute is going with Janib Shah and they
shall not leave to complainant to take the crops, by saying so the
Zahid Shah took out Match-Box from his pocket and set the fire
upon heap of Sarsoon meantime Faheem Shah took out Match Box
and who set fire upon an other heap of Sarsoon crop, and made ash
both heaps of Sarsoon and they were cutting the standing crop of
the banana, meantime on the flames of the fire and cries of the
complainant , other villager rushed towards there, who by seeing
the persons run away by issuing threats that if the complainant did
not give them share from the crops then they shall not let to take out
the crops to Janib Shah, the accused persons by cutting the crops of
the banana run away thereafter complainant approached at
residential place of Syed Janib shah but who was not present there
thereafter complainant on next day met with Syed Janib Shah and
narrated whole facts with who advised to lodge the FIR against the
accused persons hence this FIR
After registering of the FIR, during the course of

investigation the applicant was arrested, hence he is in judicial
custody, two bail application were filed by the applicant accused
same were rejected, recently complainant party have patched up
with Syed Zahid Hussain Shah and their grievances have been
resolved parties have no more grudge against each other therefore
applicant filed this 3rd bail application before this Honourable Court
on the fresh following grounds
-: G R O U N D S :-

and fabricated one .
36.That there is delay in lodging of the FIR for more then 4 days
without any explanation which goes to show that the same has
been lodged after deliberation and consultation and as such false
implication of the applicant accused in the present case can not
be ruled out .
37.That the accused Zahid Shah have compromised with the

[3]
complainant party out side of court intervened their neckmard

now complainant has pardoned to the Syed Zahid Shah and their
grievances has been resolved whereas complainant is ready to
swear his affidavit of no objection of granting the bail to the
applicant accused.
38.That there is no apprehension of tampering with the evidence of

the applicant/accused as he is ready to furnish his solvent
39.That the other ground will be urged at the time of arguments.

APPLICANT/ACCUSED
IN THE COURT OF SFAMILY JUDGE AND JUDICIAL
MAGISTRATE NAWABSHAH
B. A. No: OF 2014.
Zahid Hussain Shah Son of Syed Ghulam Rasool Shah

Benazirabad
…………………………...................Applicant/accused
VS
The State .………….………………………………………………….……

Opponent
Crime No: 31/2014, PS, Taluka

U/S 435, 427 PPC
BAIL APPLICATION

facts and ground.
-: F A C T S :-
[2]


-: G R O U N D S :-

be ruled out .

[3]

applicant accused.


APPLICANT/ACCUSED
BENAZIRABAD
Bail Application No. OF 2014.
Akeel Ahmed son of Muhammad Anwar Malak

Presently confined in Central Jail
Hyderabad ………………………………………..
…….Applicant/accused
VS
The State ………………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 395 PPC
BAIL APPLICATION
It is prayed on behalf of the applicant/accused , that this

Honorable Court may be pleased to release him on bail in the
above case/crime on the consideration of the fallowing facts
and grounds:-
-: F A C T S :-

Rajab Ali son of Ali Khan Machhi resident of Tharoo Mal
Daur Taluka Daur District Shaheed Benazirabad lodged his
FIR at PS B Section Nawabshah, on 24-6-2014 at about 22:30
hours, alleging therein that he resides at above mentioned
address, today night complainant along with his friend Altaf
Hussain so of Khursheed Muhammad Rajput resident
Mehmood Abad Colony Line Par Nawabshah, Sikandar Ali
son of Sher Muhammad resident of near Talpur Phatic Line
Par Nawabshah, they were going afoot from Phatic Link
Road, the bulbs were alighted from roadside, at about 9:30
hours, they saw the two motorcycles out of which five persons
[2]
encircled the complainant party, the complainant seen clearly
on the light of Bulbs which identified each to be Sheraz son of
Ashraf Kabil Khan Awan R/O Jamsheed Colony Line Par
Nawabshah, Ghulam Mustafa son of Habibullah Jamali
resident of Manik Jamali Taluka Shahdadpur District
Sanghar , Akeel son of not known Malak resident of Hashim
town Line Par Nawabshah Awais son of Rasheed Malak
resident of Manuabad Nawabshah, Zafar son of not known
Makrani Bloch resident Mariam road Line Par Nawabshah,
who-all were armed with pistols, they straight their pistols
upon complainant party , due to fear of the pistols the
complainant party remained quit, meanwhile accused Sheraz
snatched mobile phone from pocket of the complainant of
nokia company, accused Ghulam Mustafa Jamali took out Rs.
5000/- from his left side pocket of shirt, accused Akeel Malak
snatched mobile phone from Altaf Hussain from his front side
pocket of shirt , accused Awais snatched Mobile phone of
China company from Sikandar Ali, they by boarding their
motorcycle skipped away towards northern link road
thereafter complainant party made hue and cries, on the cries
of the complainant party the persons of locality gathered
there , they saw the accused persons were going towards their
houses, thereafter complainant party came at PS and lodged
present FIR.
After usual investigation the police of PS B-Section

Nawabshah arrested the applicant/accused, who is in judicial
custody, hence applicant/accused filed present bail
application, on the following grounds.
-: G R O U N D S :-
1. That the applicant/accused are innocent and had no

committed the alleged offence, he has falsely been implicated
in present case with malafide intention for the ulterior
reasons, otherwise applicant accused is innocent.
2. That, admittedly no such incident whosoever stated in the FIR

is ever taken, but whole drama has been staged by the
complainant, just to pressurize and blackmailing the
applicant/accused and
[3]
others, so that they may come in his terms otherwise applicant

accused has no concerned with the alleged story.
3. That malafide on the part of the complainant can be judged

from the facts that how it can be possible the
applicant/accused was identify by the complainant on the
spot even that there is no previous identification parade or
relations shown by the complainant with applicant accused.
4. That the accused / applicant until has no attend age of

majority and case of the applicant accused which comes in the
provision of juvenile justice therefore applicant accused is
entitle for the concession of bail .
5. That applicant/accused is neither disparate nor previous

convicted as per instructions.
6. That no any guilty was admitted by the complainant nor he is

concerning with the same alleged offence but complainant
has find out technical method to implicate the
applicant/accused and other in this case to drag before this
Honourable just to pressurize and implicate him for the
ulterior motive .
7. That the section applied in the FIR is neither punishable more
then 10 years nor less then 4 years, whereas story narrated by
the complainant is ineffectual and discontented.

evidence.
9. That applicant is prepared to furnish solvent surety to the

Advocate for accused / applicant
[4]
CERTIFICATE
This is certify that this is first bail application on behalf of

the applicant before this Honourable Court, prior to this no any bail
or other case has been filed before this Honourable or other
competent court of law.

APPLICANT/ACCUSED
MAGISTRATE-1 SAKRAND
B. A. No: OF 2014.
Suleman chachar son of Khabar Khan Chachar

Muslim Adult R/O Saeedabad now confined
At Central Prison Hyderabad ….
VS
The State ………………….…………………………..………………

Opponent

OFFENCE U/S 392 PPC
BAIL APPLICATION

-: F A C T S :-

complainant, Raja Shahid Nadeem lodged his FIR at PS
Sakrand. On 18-12-2013 complainant alongwith his brother
Ahsan Ul Murtaza on their motorcycle were coming from
Hyderabad to their house at Daur when at about 3:00PM,
complainant party reached NHW road five start they saw the
five accused persons armed with weapons were standing
towards the road side and one motorcycle was parked there,
the complainant saw them and identified which to be
Sulleman son of Khabar Khan R/O Saeedabad armed with
pistol, Mehboob Ali Keerio armed with pistol, khalid Keerio
armed with pistol, both R/o Majeed Keerio, Taluka Sakrand,
out of which one unknown persons who was armed with
pistol who shall be identified if seen again, who by seeing the
complainant party on
[2]
close range straighten their weapons and signaled to stop the

motorcycle, the complainant party stopped their motorcycles
and who with force of their weapons got down he
complainant party from their motorcycles and snatched Rs
750/-from the complainant, and robbed from brother of the
complainant such property is mentioned bellows and by
snatching the motorcycle from the complainant party, they by
boarding the motorcycle of the complainant and on their
motorcycle they went away, thereafter complainant alongwith
his brother came at PS Sakrand and lodged FIR.
DESCRIPTION OF ROBBED PROPERTY

1. One Motorcycle Number Nil Engine No 6731671, chassis
Number AK-791365, Model 2012, read Colored worth of Rs

55000/-
2. Cash amount Rs 750/- robbed from complainant and
snatched ATM card number 2066701,cheque Book Number

2695301 and army DRV card and two mobiles Nokia
Company in one Sim Number 0306-5819912 second
Number 0301-3277084 snatched Domicile and Educational
certificate from primary to intermediate and CNICs from
complainant and his brother.
After usual investigation the police of PS- Sakrand

arrested the applicant/accuse, who is confined at Central
Prison Hyderabad , hence applicant filed present bail
application before this Honourable Court on the following
grounds .
-: G R O U N D S :-

the ulterior reasons
10. That in fact back ground of false involvement of the applicant
accused is that there was exchange of hot words in between

the applicant accused and Wadero Saleem Bughio of Village
Rano Bughio and he maltreated the applicant accused and
confined in
[3]
him and then called the SHO Tharo khan of police station
Halla, SHO Ghulam Ali Zardari of Polcie Station Saeedabad,
ASI Muhammad Bux Lakho , and then said Wadero handed
over the applicant accused to police of Halla and Saeedabad
then complainant demanded Rs 100000/- from son and wife
of the applicant accused and since they are poor persons they
could not fulfill demand of the complainant and managed a
false encounter made straight firing by SHO Tharo Khan
Bhatti and ASI Muhammad Bux Lakho upon the applicant
accused with intention to kill him to which he received severe
injury on his leg and after operation his leg has been cut off
and he become disable for whole life, even no single case was
registered against the applicant accused prior to this case and
due to influence of complainant party no case of applicant
accused was registered against the police officials.
11. That there is delay in lodging the FIR more then 2 months

the same has been lodged after deliberation and consultation
and as such false implication of the applicant accused can not
be ruled out.
12. That, the applicant /accused captured by SHO of PS
Saeedabad in crime No 13/2014 under section 324, 353, 34

PPC On 1-2-2014 and in crime No 14/2014 under section 23-A
(i) Sindh Arms act dated 1-2-2014 since then applicant accused
was remained in custody of SHO Of PS Saieedabad whereas
Honourable High Court Hyderabad has pleased to grant bail
application of the present accused namely Sulleman and now
this case is nothing but same has been foisted upon the
applicant accused with malafide intention for the ulterior
motive mentioned above.
13. That the date of incident and involvement of the applicant
accused is creates highly doubt of involvement of the

applicant accused in this case though the complainant has
knowledge of whereabouts of the accused persons and lodged
FIR after two months which creates highly doubt therefore
case of the applicant is fit for further inquiry .
[4]
14. That in fact there is no any direct role attributing to the

the applicant accused.
15. That the offences as alleged doesn’t fall within the prohibitory
16. That all the PWs are setup person hence they are interested
witnesses of the complainant.
evidence as all the PWS are interested witnesses of the

complainant .

APPLICANT/ACCUSED
CERTIFICATE

of law.
ABDUL GHAFOOR RIND

ADVOCATE
For the applicant accused
NAWABSHAH
B. A. No: OF 2014.
Hameer khan son of Muhamad AKbar Gopang

R/O Housing Society Nawabshah
Presently confined at Lock Up of Police Station Airport
Nawabshah ……………………….
VS
The State ……………….…………………………..………………

Opponent
Crime No: 36/2014, P.S, Aiport

OFFENCE U/S 506/2, 34 PPC
BAIL APPLICATION

-: F A C T S :-

complainant, Muhammad Siddique Arain lodged his FIR at
PS Airport. On 20-6-2014 at about 20:00 hours alleging therein
that Khalid Hussain Arain the son of complainant who was
employee in police department, On 2-6-2014 when he was
presented at his duty accused Hameer Khan and Aftab
Ahmed Channar intentionally hit their motorcycle to Khalid
Hussain and seriously injured him, for which such FIR
bearing crime No 99/2014 under section 324, 336 PPC was
lodged at PS A Section Nawabshah, thereafter on 7-6-2014
Khalid Hussain the son of the complainant was under
treatment and he expired away during the treatment . on the
day of lodging of the FIR the complainant along with his
relative
[2]
Muhammad Nazim and Maqbool Ahmed were going towards

New Nakka Sakrand Road Nawabshah on their motorcycle
with their personal work, when at about 4:00 PM they reached
near Showroom of the Mukhtiar Zardari, there arrived one
black colored 125 Motorcycle, on which Hameer Khan
Gopang and one unknown accused were boarded who
signaled the complainant party to stop their motorcycle on
that account the complainant party stopped their motorcycle
in the meanwhile Hameer Khan Gopang asked the
complainant that since he has got registered the FIR against
the complainant and he may withdraw from that case else,
they would kill him and would sustain loss to him as well as
his family members, the complainant replied that he would
not withdraw from the case , on which both the accused
persons took out their pistol from fold of shalwar respectively
and aimed the same towards the complainant party and asked
that today they would kill him on which the complainant
party raised hue and cries which attracted the passerby, who
gathered on seeing them the accused persons decamped on
their motorcycles towards the new Nakka, the complainant
then returned to his house where they consulted with their
relatives. The complainant then went and lodged present FIR.
After usual investigation the police of PS- Airport

arrested the applicant/accuse, who is in police lockup at PS
Airport , hence applicant filed present bail application before
this Honourable Court on the following grounds .
-: G R O U N D S :-

the ulterior reasons
21. That in fact no such incident whatsoever stated in the FIR by
the complainant has ever taken place and the present FIR is
nothing but actual facts are that the complainant who is
retired assistant sub inspector of the police, who have close
contracts with the local police
[3]
and by taking the advantage of being retired police officer he has

managed a false story and with the collusion of police he has
lodged present false FIR on false and concocted facts just to
pressurize and blackmail the applicant accused, who is student
of intermediate , as the applicant has got interim pre arrest in
crime No 99 of 2014 under section 324, 336 , 34 PPC of letter-on it
was converted into 302 PPC due to death of Khalid Hussain, the
son of the complainant and the applicant along with his father
Muhammad Akbar had come to attend his date of hearing in
crime No 99/2014, before the court of learned Session Judge
SBA. On 20-6-2014 but the Honourable court was pleased to
transfer the ABA of the applicant/accused to the court of learned
2nd Additional Session Judge SBA and due to leave of the
vacation by the P.O the date of hearing was given to the
applicant and the applicant after getting the date viz 9-7-2014 he
was returning back to his house at housing society Nawabshah
in company of his father Muhammad Akbar Gopang the retired
C.O,C, when at about 11:15AM they were crossing excise Office
Nawabshah the complainant along with some other police
officials in ordinary dress caught hold the applicant and his
father and forcibly put them into private vehicle and then put
them into police lock at PS A Section Nawabshah, where the
applicant and his father were compelled to compensate the
complainant without negotiating and on refusal the police of PS
airport release the father of the applicant and by managing a
false story lodged a FIR against the applicant for the ulterior
reasons.
22. That the story narrated in the FIR is neither believable nor
plausibly nor appeal the judicious mind and requires further

inquiry.
23. That the offences as alleged doesn’t fall within the prohibitory
24. That the applicant is person of tender age and his case comes
within the definition of juvenile justice ordinance of 2000 and

as such in view of the above ordinance he is entitle for the
concession of bail.
[4]
25. That the applicant is neither hardened criminal nor previous
convicted and is student and incase the applicant is not

granted bail, his carrier will be frustrate.
26. That all the PWs are kith and kin of the complainant and are
hostile towards the applicant hence they are interested

witnesses.


APPLICANT/ACCUSED
CERTIFICATE

of law.
AYAZ ALI GOPANG

ADVOCATE
For the applicant accused

BENAZIRABAD
B. A. No: OF 2014.
Murad Son of Punhoon Dayo

Muslim, Adult Confined in
Sub-Jail Sakrand ……………….
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 402, 399, 398 PPC
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Ghulam Shabir Siyal of CIA Center
Nawabshah, by producing the Mashirnama of arrest and
recovery of revolver and its bullet at police station Sakrand
lodged his report. On 14-2-2014, at about 23:00hours
according to mashirnama alleging therein that with the
signatures of mashirs complainant along with his other staff
namely PC Ali Hassan PC Tarique Hussain, PC Muhammad
Afzal were left CIA center Under entry No. 08 dated 14-2-2014
at about 18:00 hours, in government mobile SP-3519 driven by
PC Khadim Hussain for patrolling in the area and after
patrolling from different places, when at about 22:00 hours
they reached Sakrand towards Khadhar road near Esso Keerio
village where complainant party saw on the light of
government Mobile that six armed persons were present at
the road and they gave signaled to Mobile of complainant
sensing to be private vehicle, then
Hajjan son of Muhammad Ihsaque Bughio, lodged his FIR at

PS BS section Nawabshah, On 10-5-2014 at about 13:30 hours,
alleging therein that, complainant alognwiht his subordinate
staff, with government ammunition, on government vehicle
No SP 6575 alongwith driver Zubair Ali, under the entry No
15 dated 10-5-2014 at about 12:00 hurs left the PS for
patrolling to arrest the accused in crime No 48/2014 , Under
section 392-A of PS B Section, various places when they
reached Kalhora Mori they got
[2]
spy information that three accused persons above-mentioned
which has already been robbed rickshaw and one motorcycle
they are sitting at the Otaq of Inayat Rahujo, the police party
rushed towards the pointed place, when at about 13:30 the
police party reached at village Allah Dino Rahujo , Deh 29
Nusrat Taluka Nawabshah at Otaq of Inayat Rahujo, where
they saw one rickshaw and motorcycle were parked, who by
seeing the police party in uniform, the complainant very
skillfully tried to capture and the accused persons and
captured one accused persons and other run away towards
the sugarcane crop, the police party tried to capture them but
they could not succeeded, the meantime police acted for
Mashirs PC Dur Muhammad and PC Nisar made mashirs,
and inquired the name and parentage of the accused who
disclosed his name to be the Mubeen alias Aijaz , and
conducted body search from which police secured one Pistol
of 12 Bore, and they checked the rickshaw of which
registration NO Nil, Engine No 27636 chassis No 76675
Suhrab Company and one Motorcycle of red color,
registration Number Nil, engine Number 464841 , chassis No
MAF-519969, Superstar, the police inquired about the licenses
of the pistol and documents of the motorcycle and rickshaw,
the accused disclosed same to be unlicensed and did not
produced documents of the motorcycle and rickshaw and
further he disclosed that above accused persons have robbed
the same rickshaw from Muhammad Hajjan on 20-3-2014
from 60th Mile near Mal Piri Nawabshah , in which absconder
each to be Inayat Son of Muhammad Hassan Rahujo , Ghulam
Ali son of Khamiso Khan Machi, have robbed the same with
force of their weapons, the police party sealed the pistol of 12
bore and brought the stolen property came at PS and lodged
present FIR.
After usual investigation the police of PS B Section

Nawabshah arrested the applicant/accuse, who is in judicial
custody , hence applicant filed present bail application before
-: G R O U N D S :-

implicated by the complainant
[3]
with the malafide intention and noting has been recovered from
the possession of the applicant accused but same has been foisted
upon the applicant accused with malafide intention and ulterior
motive.
31. That it is amazing to note accused persons were allegedly
were sitting at Otaq at above-mentioned place with deadly

encounter one out of above arrested by the complainant party
which aspect of the case cuts very roots of the prosecution
story and it is out of understand of the prudent mind to
believe or rely upon the story setup by the complainant party
and their false implication could not be rule doubt all to
gather there case of the accused persons become of further
inquiry .
been shown associated by the complainant party in

completing of all alleged formalities and all the witness are
same police personal , therefore in-spite of fact that alleged
place of incident thickly populated and residential area
therefore the false implication could not be ruled out all to
gather and case of the applicant accused become of further
inquiry there is clearly violation of section 103 Cr PC.
33. That alleged recovery shown by the complainant party from
the present accused is looking to be false and that recovery

has only shown by the complainant party in order to made
out the strong case against the applicant accused otherwise
nothing has been recovered from his possession .
34. That applicant accused is respectable persons and he can not
think into such criminal activities and he has been falsely

implicated in this false and ineffectual case with malafide
intention for the ulterior motive .
[4]


APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MUHAMMAD AWAIS
BUGHIO
MAGISRATE-II NAWABSHAH
B. A. No: OF 2014.
Mubeen alias Ajiaz Son of Wirnd Bughio

Shaheed Benazirabad ……………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 392-A PPC.
BAIL APPLICATION
-: F A C T S :-

complainant, Hajjan son of Muhammad Ihsaque Bughio,
lodged his FIR at PS BS section Nawabshah, On 5-5-2014 at
about 13:30 hours, alleging therein that, complainant is resides
at above mentioned address, he has own Rickshaw, VIII,
Engine No 27636, Chases No 76675, White Color Model 2011,
Suhram Company, which he used to run on hire in city. On
20-3-2014 at night time complainant alongwith his relative,
namely Azam son of Muhammad Moosa Bughio and
neighboror Ghulam Raza son of Zahid Chandio R/O near
[2]
Khaskheli Colony 60th Mile Road Mal Pirri were gathered with
complainant, when at about 9:30 hours the complainant party
reached road 60th Mile Parri at Line Par Nawabshah, they saw
the search lights towards the road side were alighted , where
the complainant party saw the Mubeen alias Aijaz son of
Wirand Bughio , R/O Khairo Diro Taluka , Moro District N-
Feroze, and three unknown accused persons, all armed with
pistols , the unknown accused were un-muffled faces, the
complainant them clearly and would be identified if seen
again, they suddenly come in front of the complainant party
and straight their weapons, the complainant party due to fear
of the weapons stopped their Rickshaw, the accused Mubeen
alias Aijaz Bughio robbed key of rickshaw of the complainant
and other accused persons with force of their weapons got
down the complainant and other from rickshaw and robbed
the same, the accused Mubeen alias Aijaz driver the rickshaw
and they skipped away towards the 60th Mile road, thereafter
aforementioned witnesses of eh complainant and
complainant met with Mubeen alias Aijaz, who admitted his
guilt and further stated that he will return the rickshaw and
give the faisla to the complainant party, ultimately refused to
return the robbed property and give the faisla, the accused
have robbed the abovementioned rickshaw form the
complainant therefore complainant came at PS and lodged
present FIR.

Nawabshah arrested the applicant/accused who is in judicial
custody , hence applicant filed present bail application before
-: G R O U N D S :-
11.That the applicant/accused is innocent and had not

committed the alleged offence.
12.That the applicant/accused is innocent and has not

committed the alleged offence and has falsely been implicated
in this false case by the complainant.
[3]
13.That there is inordinate delay of more then 1 month 15 days

without any plausible explanation and such a delay has not
been explained at all which goes to show that every thing has
been managed and as such the false implication of the
applicant/accused can not be ruled out.
14.That no such incident whatsoever stated in the FIR has ever
taken place but whole drama has been staged by the
complainant with malafide intention for the ulterior reasons
just to pressurize and drag the applicant accused in present
case, otherwise applicant accused has no concerned with
alleged offence, actual facts are that there is dispute of the
complainant party with applicant/accused due to such family
affairs the complainant has shown false implication of the
applicant accused so that he may come in his terms otherwise
applicant accused is innocent.
15.That applicant /accused is neighboror of the complainant and

is respectable he can not think into such criminal activities but
complainant just to get ill-repute has implicate the applicant
16.That applicant party was shown armed with pistols but no

any single firearm hit or sustained by applicant party to the
complainant at the time of robbery, which creates clearly
doubt in above story that all and every things have been
managed with core connivance of his sweet wishers.
17.That the story narrated in the FIR is absurd as the same is

neither possible nor believable.
18.That the incident as alleged has taken place 60 th Mile Road

Nawabshah Near Mall Pirri which is quite a big area but in-
spite of that non from the vicinity came forward to support
the version put forth by the complainant.
19.That section applied in the FIR which doesn’t fall within the
prohibitory clause of section 497 Cr PC .
[4]
20. That the applicant/accused is in judicial custody and no more
21. That there is no apprehension of the tempering with the

evidence as is ready to furnish solvent surety to the
22. That the applicant/accused is not previous convicted.
23. That the other grounds will be argued at the time of hearing

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MUHAMMAD AWAIS
BUGHIO
BENAZIRABAD
B. A. No: OF 2014.
Rehmatullah son of Muhammad Saddique Zardari

Benazirabad
…………………………………………………..Applicant/accused
VS
The State ………………………………………………………………

Opponent
Crime No: 52/2014, P.S, Taluka

OFFENCE U/S 302, Q Ordinance
BAIL APPLICATION

-: F A C T S :-
complainant; Shoukat Ali lodged his FIR at PS Taluka
Nawabshah. On 18-5-2014 at about 09:30 hours, alleging
therein that, he owns agricultural land and he himself look
after the same. It is alleged that complainant having 7
brothers out of them, Rehmatullah is third in number and
Mehboob Ali is second in number, who both are residing in
Sumaira Colony Nawabshah town , and complainant alogn
with his younger brother Asif Ali and other younger brothers
used to reside in one and same house in village mitho khan
Zardari. On the day of lodging the FIR in the early morning
complainant along with his brother Asif Ali and Asgahr
Hussain, the maternal cousin of the complainant and
Mehboob Ali
[2]
went to the house of Rehmatullah, in Smaira Colony

Nawabshah where Rehmatullah met with them and then they
started debate over the matrimonial affairs, when at about
6:15 AM Rehmatullah exchange hot words with Asif Ali on
which complainant and others intervened and refrained him, ,
on which within the seeing of complainant party,
Rehmatullah took out the pistol from his fold of shalwar and
fired straight with the intention to commit the murder of Asif
Ali , who fell down by raising cries on the cot while
Rehmatullah by giving hackles to the complainant party that
no one should go near him, due to fear of weapon, the
complainant party did not go near him and within eh seeing
of the complainant Rehmatullah went away outside the house
towards the northern side, the complainant then went over
Asif Ali and found that he was having fire arm injuries on his
forehead , which was passed through and through and was
bleeding and was in unctuous condition , the complainant
party then shifted the Asif Ali to PMCH Nawabshah Hospital
for treatment , who succumbed to his injuries, the
complainant then by leaving the witnesses house the dead
body , went to PS and lodged present FIR.
After registering of the present FIR, the police of PS Tlauka

Nawabshah arrested the applicant accused and after usual
investigation submitted challaned, before the competent court
of law, the applicant is in judicial custody , hence the present
-: G R O U N D S :-

799. That admittedly the offences as alleged is

compoundable one and deceased was unmarried and
issueless, while Muhammad Saddique the father of the
deceased as well as the accused and complainant has been
expired much before alleged incident and only the mother is
sole legal heir and is competent to compound the offence as
per the
[3]
Muhammadan law and the mother of the deceased and all the
brothers and sisters of the deceased have patched up with the
accused, therefore the mother of the deceased has sworn her
affidavit before this Honourable Court, in which she has
categorically stated that she has patched up with the accused
persons and have waived her right of Qisas and Diyat and she
has no objection if the applicant is granted bail in the present
case. In view of the affidavit filed by the mother of the deceased
in favour of the applicant has make the case is that of further
inquiry.
800. That the case has been challaned and the applicant
accused is rotting in jail though the parties have patched up
and are willing to file compromise application before this
Honourable Court after releasing of the accused on bail.
801. That the applicant is neither hardened criminal nor

disparate nor involved in such like criminal activities and he
is first offender and he is not previous convicted.
802. That case has been challaned and the applicant accused
is no more required to the police for further investigation.
803. That there is no apprehension of the tampering with

the evience., as applicant accused is ready to furnish his
solvent surety to the satisfaction of this Honourable Court.

arguments.

APPLICANT/ACCUSED
CERTIFICATE

AYAZ ALI GOPANG

BENAZIRABAD
B. A. No: OF 2014.
Rehmatullah
VS
The State ………………………………………………………………

Opponent

AFFIDAVIT
I, Mst Rani wife of Muhammad Saddique Zardari

Muslim Adult R/O Village Mitha Khan Zardari, P.O Allah
Rakhio Kanio, Taluka Nawabshah, District Shaheed
1. That I am the real mother of deceased Asif Ali and so also the
complainant and accused Rehmatullah.
2. That my husband Muhammad Saddique has been expired much

before the alleged incident, while the deceased was unmarried
hence I am sole legal heir of the deceased and as per the
Mohammedan Law I am competent to compound the offence
with the applicant accused in the present case .
3. That after the incident I have compounded and patched with the
applicant accused and I have forgiven him in the name of
Almighty of Allah and being mother I have waived my right of
Qisas and Diyat to the applicant and now I have no more grudge
4. That I am swearing this affidavit of no objection to grant the bail

to the applicant accused in present case on the basis of
compromise with my own accord and free will without any
pressure or inducement.
5. That since the applicant/accused is in judicial custody hence I

am filling this affidavit so that the applicant is granted on bail
and after the release of the applicant accused I am intending to
file the proper application of compromise before this Honourable
Court .
knowledge and belief
Advocate

BENAZIRABAD
B. A. No: OF 2014.
Rehmatullah
VS
The State ………………………………………..…………………………

Opponent

AFFIDAVIT
I, Shoukat Ali son of Muhammad Saddique

Zardari , Muslim Adult R/O Village Mitha Khan Zardari, P.O
Allah Rakhio Kanio, Taluka Nawabshah, District Shaheed
1. That I am the real brother of deceased Asif Ali and so also I am

the complainant in the above case .
2. That our father Muhammad Saddique has been expired much

before the alleged incident, while the deceased.
3. That after the incident we have compounded and patched with

the applicant accused and I have forgiven him in the name of
Almighty of Allah.
4. That I am swearing this affidavit of no objection to grant the bail

to the applicant accused in present case on the basis of
compromise with my own accord and free will without any
pressure or inducement.
5. That since the applicant/accused is in judicial custody hence I

am filling this affidavit, so that the applicant is granted bail and
after the release of the applicant accused, I am intending to file
the proper application of compromise before this Honourable
Court.

knowledge and belief
Advocate
IN THE COURT OF CIVIL JUDGE AND JM-II
NAWABSHAH
B. A. No: OF 2014.
The State
VS
Abdul Razzak

Nawabshah
BAIL APPLICATION
-: F A C T S :-

complainant, ASI Mian Bux Mari lodged his FIR . on 21=-5-
2014 at about 13:30 hours, he alleged therein that he along
with his subordinate staff, each one PC Dur Muhammad PC
Muhammad Bux, officials arms and ammunition on
government vehivle NO SP 7575 with driver PC Ali Khan,
vide entry No 16 dated 21-5-2014. at about 11:15 hours, left the
PS for patrolling in his beat after patrolling deferent places ,
when police party reached near Mehmood Ali Shah turn, at
60th Mile Road there they received spy information that one
persons openly selling a chars on 60th Mile road after receiving
such information the complainant along with above staff,
moved towards the pointed place, when at about 12:30 hours
the complainant party reached there , at 60th Mile Phatic in
Deh 86 Nusrat, Taluka Nawabshah and saw one persons
having black shopper in his right side hand who seeing the
police party and government vehicle, tried to run away, then
complainant party stopped their mobile deboarded the same
and made a circle with tactfully and
[2]
apprehended the accused due to non availability of the

private masher each one PC Dur Muhammad Bhangwar PC
Muhammad Bux appointed act as mashirs, and inquired
about the apprehended persons and then the phatic shopper
which was in right handed same was possessed the police,
thereafter inquired about name and caste and residence of the
accused who disclosed his name to be applicant accused
Abdul Razzak thereafter complainant party opened the black
shopper and found one big piece of charas, lying in and
weight of the same to be 240 grams, out of which little piece of
chars 40 grams Weight of the same separately sealed and
remaining Charas of 200 Grams sealed in back shopper,
further body search found Rs 70/o from right side of shirt,
detail of the same is below from home further inquired, about
the charas and cash amount who disclosed that charas is my
own same is being sale for passing life and amount of the
same is a selling of the charas, then complainant party
arrested the accused persons under section 3/4 PEHO, such
mashirnama was prepared with signature of the mashers,
thereafter arrested accused recovered property and cash
amount brought at PS under the custody of the complainant
party therefore arrested the accused keeping the possession
illegal charas for purpose of selling has committed and
offence u/s 3/4 Manshiyat due to that on behalf of the state
the present case has been registered.
DETAIL OF RECOVERED CHARAS AND CASH

AMOUNT
3. One big Piece of Chars weight 240 Grams out of which one
little piece of charas weight 40 grams sealed the same for
chemical examination and remaining chars 200 separately
sealed in black plastic.
4. Cash amount of one Currency Note of Rs 50 and tow
currency note of 10 Rupees total Rs 70/- hence the present
-: G R O U N D S :-
applicant/accused.
807. that on 21-5-2014 the accused was coming from his

village to Nawabshah for labouring as he is mason at that
time he has a cash
[3]
amount Rs 4000/- which were taken by the police party then it

was are foisted upon the accused demanded back due to that
motive in order to usurp the cash amount of Rs 4000/- of the
accused due to that false case has been registered against the
accused.
808. That the section/ offence mentioned in the FIR do not

fall within the prohibitory clause of section 497 Cr PC .
809. That the section 4 is bailable while section 3 which too

doesn’t fall within the prohibitory clause, it is yet to be
determined at the time of evidence whether the alleged
property recovered are foisted upon the applicant/accused ,
hence false implication can not be ruled out.
810. That the witnesses are police officials and subordinate of

the complainant and they are interested hence there is no
apprehension of the tampering with the evidence.
811. That the case makes the one of further inquiry.

812. That the applicant accused previous not convicted ( as
per instruction)

arguments.

APPLICANT/ACCUSED
CERTIFICATE

BAHADUR ALI MAHESAR

BENAZIRABAD
B. A. No: OF 2014.
Gulsher son of Noor Muhammad alias Paiwar Zardari

.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S – 402, 398 , 399, 353
PPC , 324 Q.
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Ibrar Hussain Shah lodged his FIR at PS
Taluka . on 22-7-2012 at bout 7:30 hours, alleging therein that
he alongwith his subordinate staff left the PS containing
government ammunition, on government vehicle NO SP 7039
alongwith driver, under the entry No 15 dated 22-7-2012 at
about 2:00 hours, departed for patrolling various places when
they crossed landhi from Sakrand Road, at about 3:30 hours,
police saw on the light of mobile that 6 persons were standing
on road and were committing robbery from vehicle passerby,
the police party stopped their vehicle and saw identified each
to be Javed Ali son of Sahito Zardari, R/O Village Mureed
Khan Zardari armd with Gun, Ismail son of Muhammad
Qasim armed with R/O 18 Dad Taluka Nawasbshah armed
with Gun, Naeem son of not
[2]
known Sahito R/O Buchehri Taluka Daur armed with pistol,

Glsher son f Papu Zardari R/O Village Raza Muhammad
Zardari armed with rifle, Ashraf son of not known Jalbani
armed with rifle, and one unknown accused persons, they by
sensing the private vehicle signaled to police mobile, the
police party immediately by stopping the vehicle tried to
capture the accused persons, meantime accused persons by
seeing the police also fired straight upon them with intention
to commit murder, the police party also made fires in their
defense upon accused persons such firing continued for about
10/15 minutes thereafter accused persons by taking the
advantage of the darkness skipped away northwards, the
police party tracked foot prints of the accused persons with
help of PC Muhammad Hussain Khoso which lead through
Mubrak Wah to Khabar Lakhmir and Kaimi-visko fiber Mill,
and police party saw the accused by climbing on any vehicle
decamped away , thereafter police party returned back and
registered FIR against the accused persons hence this present
FIR.
After usual investigation the police of PS Sakrand
Taluka arrested the applicant accused in present case. The
applicant/accused is in judicial custody hence
applicant/accused got filed present bail application, before
this Honourable court on the following grounds.
-: G R O U N D S :-

815. That there is delay in lodging the FIR of 4 hours such

delay has been not been explained by the complainant.
816. That the accused persons had allegedly made an

ineffective firing and no firearm or other injury was
attributed to the complainant party during the occurrence
and during the firing which continues 15/10 minutes, case
against the accused therefore needed to further inquiry, it is
further ground pertinent to matter that no overt act is
allegedly ascribed to the accused persons except ineffective
firing which also stood disapproved because no empty was
recovered from the spot and the question of vicarious liability
of accused could be determined at the trial case against the
accused thus requires to further inquiry
[3]
implausibly .
ever taken place but complainant just to drag the applicant in
false case has falsely implicated in false case otherwise
applicant/accused is not concerned with the alleged story.




arguments.
ABDUL GHAFOOR RIND

APPLICANT/ACCUSED
CERTIFICATE

ABDUL GHAFOOR RIND

Reg-HC-No 518 /NWS
BENAZIRABAD
B. A. No: OF 2014.
Gulsher Son of Papu Zardari

Prsently confined in in District Jail
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 23-Sindh Arms Act
2013
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Sajid Hussain Arain lodged his FIR at PS
Sakrand. On 7-3-2014 at about 15:45 hours, alleging therein
that, complainant along with his subordinate staff, containing
the government ammunition in police uniform, they departed
to arrest the accused Main Bux son of Haji Sanwan Khan in
crime No of bearing crime No 41/2014 of PS Sakrand, and
arrest the accused Mian Bux son of Haji Sanwan Khoso,
Zulfiqar alias Bhutto son of Ibrahim Jlabani, Allah Warayo
son of Muhammad Moosa Mallah
[2]
R/O Village Mari Jlabani involved in crime No. 42/2014 of PS

Sakrand, police introgate3d the accused persons, meantime
accused Mian Bux during the interrogation disclosed that on
6-3-2014 at the time of occurrence, due to defend from the
police the accused secured their weapons in Qabaristan of
Ladho Lal, which used in above crime, thereafter police party
after interrogation they by boarding the accused persons in
their police mobile under the entry No 13 dated 7-3-2014 they
departed from Police station to Qabristan and they reached
there the accused Mian Bux by moving ahead about some
distance he dig one handbag and handed over to police party,
meantime police opened the same they saw three pistols of 30-
Bores were available in handbag, the police unloaded the
same which were empty, the police party inquired about the
licenses which they disclosed unlicensed, so-far accused were
arrested by police, the police by taking the recovered property
and accused returned back at PS and where FIR was lodged
against the accused persons hence this FIR.

arrested the applicants/accused in present case. The
applicants/accused are in judicial custody hence
applicants/accused got filed present bail application before
this Honourable court on the following grounds.
-: G R O U N D S :-


otherwise applicants accused have no concerned with the
alleged offence.
826. That the pistols in-question have been foisted upon the
applicants/accused and applicants have no concerned with
the alleged weapons, but complainant just to drag the
applicants/accused before the competent court of law has
no any substance and substantial record which connect with
the applicants/accused

which connect the applicants/accused with the alleged
offence merely there are general allegation just to bow down
the applicants otherwise alleged story is made out and is
implausibly .

Mashirnama of the arrest and recovery of two separate FIRs
have been registered against the applicants/accused
otherwise complainant is standing for political influential
persons and such FIR is managed one and of-shoot of other
cases.
829. That the present case is nothing but complainant has

shown his official power by joining the hands with political
figures due to ill-repute the applicants/accused and present
case is connected case with main crime.
831. That the case has been challaned and

applicants/accused is no more required to police for further
investigation.
832. That applicants/accused have already been granted on

bail in main case



arguments.
MUHAMMAD HANIF SHAR

APPLICANTS/ACCUSED
CERTIFICATE

with main case on behalf of the applicants/accused before this
Honourable Court.
MUHAMMAD HANIF SHAR
Reg-LC-No /NWS
BENAZIRABAD
B. A. No: OF 2014.
Allah Warayo son of Muahmmad Moosa

R/O Mari Jalbani Taluka Sakrand
Sanghar ……………………………………………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

that, accused namely Allah Warayo son of Muhammad Moosa
R/O Mari Jalbani Taluka Sakrand, Presently confined in
District Jail Sanghar, was arrested in bearing crime No
42/2014, offence under section 411 PPC, of PS Sakrand, to
whom police secured one unlicensed pistol containing the
magazine, who has used the same weapon in crime, therefore
police secured the same and lodged present FIR.
[2]

arrested the applicant accused in present case . The
applicant/accused is in judicial custody hence applicant got
filed present bail application before this Honourable court on
the following grounds .
-: G R O U N D S :-
1. That the applicant/accused is innocent and had not committed
the alleged offence, but he has been falsely implicated by the

complainant with the malafide intention.
complainant, just to show his efficiency otherwise, no such
incident was ever taken place.
3. That the pistol has been foisted upon the applicant/accused and
applicant has no concerned with the alleged weapon, but

complainant just to drag the applicant/accused before the
competent court of law has lodged present FIR by leveling
allegations otherwise there is no any substance which connect
with the applicant.
4. That except the solitary words of the complainant and his
subordinate staff there is no substances on the record which

from the facts that under the one and same Mashirnama of the
arrest and recovery two separate FIRs have been registered
against the applicant/accused otherwise complainant is standing
for political influential persons.
6. That the present case is nothing but complainant has shown his
official power by joining the hands with political figures due to

ill-repute the applicant/accused and present case is connected
case with main crime.
[3]
more required to police for further investigation.
9. That applicant has already been granted on bail in main case
evidence.


MUHAMMAD HANIF SHAR
APPLICANT/ACCUSED
CERTIFICATE

with main case on behalf of the applicant/accused before this
Honourable Court.
MUHAMMAD HANIF SHAR

Reg-LC-No /NWS

BENAZIRABAD
B. A. No: OF 2014.
Zulfiqar alias Bhutto son of Ibrahim Jalbani

Sanghar ………………………………………...…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

complainant, Sajid Hussain Arain lodged his FIR at PS
that, accused namely Zulfiqar Ali alias Bhutto son of Ibrahim
Jalbani was arrested, who was under the remand, in bearing
crime No 42/2014, offence under section 411 PPC, of PS
Sakrand, to whom police secured one unlicensed pistol
containing the magazine, who has used the same weapon in
crime, therefore police secured the same and arrested the
applicant/accused and lodged present FIR.
[2]

-: G R O U N D S :-


such incident was ever taken place.
838. That the pistol has been foisted upon the

applicant/accused before the competent court of law has
no any substance which connect with the applicant.

his subordinate staff there is no substances on the record
which connect the applicant/accused with the alleged
offence.

Mashirnama of the arrest and recovery two separate FIRs
have been registered against the applicant/accused otherwise
complainant is standing for political influential persons.

figures due to ill-repute the applicant/accused and present
[3]
843. That the applicant is respectable person and he can not

thing into such criminal activities such offence is nothing but
he has been implicated by the complainant .
844. That applicant has already been granted on bail in main

case

evidence.


arguments.
MUHAMMAD HANIF SHAR

APPLICANT/ACCUSED
CERTIFICATE
Honourable Court.
MUHAMMAD HANIF SHAR

Reg-LC-No /NWS

BENAZIRABAD
B. A. No: OF 2014.

Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

that, complainant along with his subordinate staff, containing
the government amminution in police uniform, they departed
to arrest the accused of bearing crime No 41/2014 of PS
Skarand, crime NO 42/2014 of PS Sakrand, on government
vehivle Noaccused aforesaid, Presently confined in District
Jail Shaheed Benazirabad, was arrested in bearing crime No
42/2014, offence under section 411 PPC, of PS Sakrand, to
whom police secured one unlicensed pistol containing the
magazine, who has used the same weapon in crime, therefore
police secured the same and lodged present FIR.
[2]

-: G R O U N D S :-



offence.


[3]


case

evidence.


arguments.
MUHAMMAD HANIF SHAR

APPLICANT/ACCUSED
CERTIFICATE

Honourable Court.
MUHAMMAD HANIF SHAR
Reg-LC-No /NWS

BENAZIRABAD
B. A. No: OF 2014.
Allah Warayo son of Muahmmad Moosa

R/O Mari Jalbani Taluka Sakrand
Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

that, accused namely Allah Warayo son of Muhammad Moosa
R/O Mari Jalbani Taluka Sakrand, Presently confined in
District Jail Shaheed Benazirabad, was arrested in bearing
crime, therefore police secured the same and lodged present
FIR.
[2]

-: G R O U N D S :-



offence.


[3]

case

evidence.


arguments.
MUHAMMAD HANIF SHAR

APPLICANT/ACCUSED
CERTIFICATE

Honourable Court.
MUHAMMAD HANIF SHAR

Reg-LC-No /NWS
BENAZIRABAD
B. A. No: OF 2014.

Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

complainant, Sajid Hussain Arain lodged his FIR at PS
that, accused namely Zulfiqar Ali alias Bhutto son of Ibrahim
Jalbani was arrested, who was under the remand, in bearing
crime, therefore police secured the same and arrested the
applicant/accused and lodged present FIR.
[2]

-: G R O U N D S :-


such incident was ever takne place.


offence.


[3]
879. That the applicant is respectable person and he can not

thing into such criminal activities such offence is nothing but
he has been implicated by the complainant .

case

evidence.


arguments.
MUHAMMAD HANIF SHAR
APPLICANT/ACCUSED
CERTIFICATE

Honourable Court.
MUHAMMAD HANIF SHAR

Reg-LC-No /NWS
3RD BAIL APPLICATION
IN THE COURT OF FAMILY JUDGE AND JUDICIAL
B. A. No: OF 2014.
Zahid Hussain Shah Son of Syed Ghulam Rasool Shah

Benazirabad
VS
The State .………….………………………………………………….……

Opponent

U/S 435, 427 PPC
BAIL APPLICATION

facts and ground.
-: F A C T S :-
[2]


-: G R O U N D S :-

be ruled out .

[3]

applicant accused.


APPLICANT/ACCUSED
3RD BAIL APPLICATION

IN THE COURT OF FAMILY JUDGE AND JUDICIAL
B. A. No: OF 2014.
Zahid Hussain Shah ...

…………………...................Applicant/accused
VS
The State .………….………………………………………………….……

Opponent

U/S 435, 427 PPC
AFFIDAVIT
I Mir Sahib son of Dadan Khan Lund, R/O village Azeem

Shah Deh 16 Dad, Taluka Nawabshah, District Shaheed
Benazirabad , do hereby state on oath as under:-
1. That I am the complainant in the above case hence fully

conversant with the facts of the present case
2. That after registering the FIR our faisla has been held with the
accused Zahid Hussain Shah son of Ghulam Rasool Shah on
Holy Quran by our neckmard, as accused Zahid Hussain Shah
paid compensation of loss of the crop which burnt by the
accused persons
3. That now complainant has no more grudge against the Syed

Zahid Hussain Shah their grievances has been resolved
intervened their neckmard , I have no more grudge if the accused
Zahid Hussain Shah released on bail in present case by this
Honourable Court.
4. That I am swearing this affidavit before this Honorable Court

without any pressure, inducement or force but the same is of my
free will and accord.

Advocate
BENAZIRABAD
B. A. No: OF 2014.
Ali khan and others ….…..

……………...................Applicants/accused
VS
The State .………….………………….………………………….……

Opponent

Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT
I Mst Bhooran wife of Ali Khan Muslim Adult R/O Village

Ali Khan Zardari Taluka Nawabshah District Shaheed
1. That I am the real mother of deceased Mst Hameeda and being

mother of deceased I am one of the LRs of deceased Mst
Hameeda.
2. That our faisla has been made with the accused persons
nominated in the FIR on Holy Quran by our neckmard, as such I
have forgiven the nominated accused in the present case in the
name of Almighty Allah as our grievances has been resolved
in a private faisla outside the court on Holy Quran and now I
have no more grudge against the applicants/ accused or against
the co-accused if they are released on bail by this Honourable
Court in present case.
3. That I have waived my right Diyat to the applicants/ accused in

the above case in the name of Almighty of Allah without paying
or claiming the amount of Diyat .

Advocate
IN THE COURT OF DISTRICT JUDGE SHAHEED

BENAZIRABAD
REVISION APPLN NO OF 2014
Ghulam Murtaza son of Ghulam Rasool Arain

R/O near Muslim Commercial Bank Work Shop
Road Sanghar District Sanghar ……………………………………
Appellant
VS
I Mst Khursheeda alias Libna D/O Irshad Ahmed Arain

Muslim Adult R/O madni Baloch Colony Line Par
Nawabshah District Shaheed Benazirabad
…………………………..Respondent
REVISION UNDER SECTION 29 MUSLIM FAMILY ACT
Being agrievied and dissatisfied the order passed by the family

judge nawabshah in family suit No 269 of 2013 dated 8-2-2014 the
applicant prefer this revision with the prayer to set aside the
impugned order by calling the R&P on the consideration of the
following facts and grouidns mentioned below
FACTS
The plaintiff has already been filed suit for dissolution of marriage
maintenance and return of Jahez articles before family judge
Nawabshah and the defendant contested the matter and said suit as
decreed by the trial court thereafter the plaintiff filed appeal before
the Honourable Second Additional District Judge Shaheed
Benazirabad for enhancement of maintenance of chilled minors to
whom custody of minor was already been handed over to her
mother the Honouirbale Court of 2nd Additional Session Judge up
held the judgment of trial court later on plaitniff filed e3xecution
application No of 2012 which was allowed by the executing court
and same was sent to family judge Sanghar for execution and the
same was satisfied. The defendant according to order of the family
judge Nawabshah comply with the directions and handed over the
Jahez articles to the plaintiff and regularly paid the amount of
maintenance before the civil judge and Judicial Masgitrate-II
Nawabshah the Jahez articles were handed over to plaitniff before
the Bailiff of the court and defendant implemented the judgment
and decree. The plaintiff has filed the present suit which is liable to
be dismissed on the principle of res-judicata
IN THE COURT OF 2nd SENIOR CIVIL JUDGE NAWABSHAH
F.C Suit No of 2007
Muhammad Son of Muhammad Panah Khoso and others …….

………………Plaintiff
VS
Abdul Hameed son of Gul Muhammad Khoso ………………..

……..Respondents
Ahmed ………………………………………………………………
APPLICATION UNDER SECTION 12(2) CPC R/W 151 CPC
For reason disclosed in accompanying affidavit it is respectfully

prayed that this Honourable Court may be pleased to recall the
order passed, on __________ passed by this Honourable Court due
to which, this order has been obtained by way of fraud and
misrepresentation such relevant sub-section of section 12 is
reproduced below.
Where a person challenges the validity of a judgment decree

or order on the pleas of fraud. Misrepresentation or want of
jurisdiction, he shall seek his remedy by making an
application to the court which passed the final judgment,
decree or order and which passed the final judgment, decree
or order and not by a separate suit.
Therefore, as per order that respondents have filed joined statement
but reality is that respondents No 1 was not present at the time of
passing order before this Honourable Court and attorney of the
respondents No. 1 having no power to compromise and withdrawal
of the case for which, for passing of this order of this Honourable
uncountable loss shall take place to respondent No 1 and his son
hence this application
Prayed accordingly
Nawabshah
Dated _______________ ADVOCATE FOR THE
RESPONDENT NO 1
IN THE COURT OF 2nd SENIOR CIVIL JUDGE NAWABSHAH
F.C Suit No of 2007
Muhammad Son of Muhammad Panah Khoso and others …….

VS
Abdul Hameed son of Gul Muhammad Khoso ………………..

……..Respondents
Ahmed ………………………………………………………………
AFFIDAVIT
I Ahmed son of Muhammad Adult Muslim, having CNIC. 44204-
5035489-7 R/O House No 5/2 Sheet 19 Model Colony Karachi do
hereby state on oath as under:-
1. That I am deponent of this affidavit hence fully conversant
with the facts mentioned therein.
2. That, am real son of the respondent No 1 and new power of

attorney Inshalla will come very soon.
3. That, accompanying application under section 12 (2) CPC

R/W 15 CPC has been drafted and submitted under my
specific instruction which may be treate3d as part and parcel
of this affidavit.
4. That, applicant namely Abdul Hameed has obtained this

order passed______________ by way of misrepresentation
and fraud due to which, as per order of this Honourable
Court respondents have filed joint statement duly signed by
them but reality is that at the day of passing of this order,
respondent No 1, was not present before this Honourable
Court.
5. That, applicant namely Ahmed along with other person have

made misstatement before this Honourable Court that parties
have settled their dispute outside of the court and entered into
compromise, for which, it is a false statement due to which,
respondents No 1 resides in Qatar since long and he having
Qatar nationality and whole property of the respondent No 1
have illegally been occupied by the present respondents for
which, attorney of the respondent No 1 having also no
authority to do compromise or withdraw the case. Condition
No 3 of the power of attorney is reproduced below.
Condition 3: no to compromise, compound, withdraw

case or refers them to arbitration without our
permission/consent in writing, Condition NO 5 to
withdraw and receive documents (withdraw /receive
money, cheque or similar valuable things , it will be
applicable if obtained a prior written confirmation from
us authorizing him to do so) from any court office or
Opposite party either in execution of decree or
otherwise and to do all the acts that may be necessary
connection with any such case.
[2]
6. That, the applicant Abdul Hameed has already filed an

application under section 12 (2) CPC R/W 151 CPC before
Honourable high Court Circuit Bench Hyderabad in Civil
Revision No 185 of 2013 whereby Honourable High Court has
issued notice to the respondents and next date of hearing 30-4-
2014 has been fixed, (copy of the application 12 (2) alongwith its
affidavit and show cause notice of Honourable High Court are
attached herewith as annexure B-1 to B-3 .
7. That attorney of the plaintiff namely Abdul Sammad has also

filed constitution petition No 480 of 2014 before Honourable
High Court Sindh at Karachi, wherein he has clearly mentioned
that his fake signatures has been made out and fake compromise
has also been made out on behalf of the said attorney further
more he has also mentioned in CP that he having apprehension
that the respondents will kill him therefore, he has requested to
the Honourable High Court for protection and shelter in
according to law the Copy of the CP is attached herewith as
annexure C.
8. That further more attorney of the plaintiff has also stated in

above CP filed by him as in person that he had no power to
compromise or withdraw the suit in spite of this the forge
documents has been made on his behalf.
9. That order may be pleased be set-aside otherwise; we will suffer

irreparable loss and injury.
10.Whatever stated above is true and correct to the best of my

I know the deponent

Deponent
Advocate
Prayed accordingly.
Nawabshah
Dated ___________
VERIFICATION
Sworn by the deponent above named on 12-4-2014 at

Nawabshah who was identified by Advocate Qaim Ali who is
personally known to me.
COMMISSIONER FOR TAKING OATH

BENAZIRABAD
REVISION APPLN NO OF 2014
Ghulam Murtaza son of Ghulam Rasool Arain

R/O near Muslim Commercial Bank Work Shop
Road Sanghar District Sanghar
I Mst Khursheeda alias Libna D/O Irshad Ahmed Arain
Muslim Adult R/O madni Baloch Colony Line Par
Nawabshah District Shaheed Benazirabad
IN THE COURT OF 1st SENIOR CIVIL JUDGE NAWABSHAH
F.C Suit No of 2007
Abdul Hameed son of Gul Muhammad Khoso ……………….

VS
Muhammad Son of Muhammad Panah Khoso and others
……………..Respondents

reproduced below.

Therefore, as per order that respondents have filed joined statement

but reality is that respondents No 1 was not present at the time of
passing order before this Honourable Court and attorney of the
respondents No. 1 having no power to compromise and withdrawal
of the case for which, for passing of this order of this Honourable
uncountable loss shall take place to respondent No 1 and his son
hence this application
Prayed accordingly
Nawabshah
RESPONDENT NO 1

F.C Suit No of 2007
Abdul Hameed ……………………… ……………………..

VS
AFFIDAVIT

11.That I am deponent of this affidavit hence fully conversant

12.That, am real son of the respondent No 1 and new power of

13.That, accompanying application under section 12 (2) CPC

of this affidavit.
14.That, applicant namely Abdul Hameed has obtained this

Court.
15.That, applicant namely Ahmed along with other person have


[2]
16.That, the applicant Abdul Hameed has already filed an

2014 has been fixed, (copy of the application 12 (2) alongwith its
affidavit and show cause notice of Honourable High Court are
17.That attorney of the plaintiff namely Abdul Sammad has also

annexure C.
18.That further more attorney of the plaintiff has also stated in

19.That order may be pleased be set-aside otherwise; we will suffer

irreparable loss and injury.

I know the deponent
Deponent
Advocate
Prayed accordingly.
Nawabshah
Dated ___________
VERIFICATION

F.C Suit No of 2007
Abdul Hameed son of Gul Muhammad Khoso ……………….

VS

reproduced below.

Therefore, as per order that respondents have filed joined

statement but reality is that respondents No 1 was not present at the
time of passing order before this Honourable Court and attorney of
the respondents No. 1 having no power to compromise and
withdrawal of the case for which, for passing of this order of this
Honourable uncountable loss shall take place to respondent No 1
and his son hence this application
Prayed accordingly
Nawabshah
RESPONDENT NO 1
F.C Suit No of 2007
Abdul Hameed ……………………… ……………………..

VS
AFFIDAVIT




of this affidavit.
24.That, applicant namely Abdul Hameed has obtained this
Court.
25.That, applicant namely Ahmed along with other person have


[2]
26.That, the applicant Abdul Hameed has already filed an

2014 has been fixed , ( copy of the application 12 (2) alongwith
its affidavit and show cause notice of Honourable High Court are

annexure C.
29.That order may pleased be set-aside otherwise, we will suffer

irreparable loss and injury .

I know the deponent

Deponent
Advocate
Prayed accordingly.
Nawabshah
Dated ___________
VERIFICATION


BENAZIRABAD
A.B. A. No: OF 2014.
Manzoor Zardari and others ….

…………………….....Applicants/accused
VS
The State .………….………………….………………………….……

Opponent

Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT


Hameeda.
the co-accused if they admitted on pre arrest bail in present case
by this Honourable Court.


Advocate

BENAZIRABAD
B. A. No: OF 2014.
Ali khan and others ….…..

……………...................Applicants/accused
VS
The State .………….………………….………………………….……

Opponent

Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT


Hameeda.
the co-accused if they are released on bail by this Honourable
Court in present case.



Advocate

BENAZIRABAD
B. A. No: OF 2014.
Piral alias Sikandar son of Ghulam Muhammad Gopang

Benazirabad
VS
The State .………….………………………………………………….……

Opponent
Crime No: 1/2014, PS A Section

Nawabshah
U/S 302,, 337-H(ii) , 504, 148, 149
PPC
BAIL APPLICATION

facts and ground.
-: F A C T S :-
The facts of the case are that the complainant Shamus Din Gopang
lodged his FIR at PS A Setion Nawabshah on 2-1-20-14 at about 11:
hours alleging therein that he is employ in session Court Shaheed
Benazirabad and performing his duty in the court of JM III
Nawabshah and used to go on his duty at early morning, Imtiaz
Aijaz, Khadim all the three sons of Shahan Gopang R/O Shahbaz
town Nawabshah , Roshan son of Piral alias Sikandar Gopang both
sons of Ghulam Muhammad Gopang party are on murderous
enmity with the complainant party who all used to extend threats of
dire consequences to the complainant that they would kill him in
the revenge of Ghulam Rasool Gopang on 31-12-2014 the
complainant alongwith his son Jahangir and brother Nisar
[2]
were going on his duty on motorcycle when at about 8:00 AM they

reached near Taj CNG in the meanwhile one Core Blue colored Car
bearing No AUU-281 and one motorcycle came near the
complainant party and jammed them and stopped their vehicle near
by the complainant’s motorcycle and out of the said car each Imtiaz,
Aijaz and Khadim all the three sons of Shahan Gopang all were
having pistols, Roshan son of Ghulam Muhammad Gopang having
repeater in his hand alighted from the said car and from the
motorcycle each Piral alias Sikandar son of Ghulam Muhammad
Gopang, Rustan son of Ghulam Rasool Gopang were unbourded
out of them Piral alias Sikandar was empty handed, while Rustam
was having pistol in his hand and all the accused persons by
abusing the complainant and asked him, today them would kill him
in revenge of Ghulam Rasool and by saying so roshan Gopang fired
straight with his repeater over the complainant with the intention to
commit his murder . which hit him on his chest and Imtiaz with the
intention to commit his murder made straight fires with his pistols
upon him which hit him on his muscle of left arm and he was
bleeding and other accused persons just to create harassment made
aerial firing and by firing in air all the accuse persons went in the
said car and motorcycle, after departure of the accused persons the
complainant was got shifted by Jahangir and Nisar with the help of
other peoples toward the civil Hospital Nawabshah and then the
present FIR was registered by the complainant.

investigation the applicants were arrested and during the treatment
the complainant was expired result is that the case has been
converted into murder under section 302 from section 324 PPC,
after usual investigation the main accused Doctor Roshan Ali
Gopang was let-of by the police under section 497 Cr PC by
showing his name in column tow of the challan and such report
under section 173 Cr PC was submitted before the competent court
of law and same was accepted, the applicant is rioting in the Jail
since his arrest. A bail application was moved on behalf of the
applicant accused before this Honourable and this Honourable
court was pleased to transferred the same to the court of learned 3 rd
Additional Sessions Judge SBA, and by order dated 15-2-2014 the
same was dismissed,
[3]
hence this is second Bail application before this Honourable Court
on fresh ground of compromise, on the following grounds
-: G R O U N D S :-
50.That the case registered against the applicants/ accused is false

and fabricated one he has been falsely implicated by the
being brother of the doctor Roshan Gopang otherwise the
applicant is innocent he has nothing to do with the alleged
offence .
be ruled out .
52.That specific role of firing on the person of deceased Shaman

Gopang is attributed to the co accused Roshan Gopang and only
the role assigned to the applicant/accused is mere presence with
empty handed without any overt act and it is yet to be
determined at the time of trial whether the applicant was being
member of unlawful assembly and have share any part in the
alleged commission of the offence and his vicarious liberty is to
be decided at the time of trial and as such the case against the
applicant is that of further inquiry, which makes him entitle for
the concession of bail .
53.That admittedly the preliminary investigation in the case has

been made before lodging of the FIR which is clear violation of
section 154 Cr PC and as such the case against the
applicant/accused is that of further inquiry .
54.That during the course of investigation the I.O has disbelieve the
FIR the 161 Cr PC statement of the PWs and he let off the co
accused Doctor Roshan Gopang and released him and as such
two versions in the present case has come on record and it is
settled law that the version which is favourable to the accused is
to be considered and as such under the rule of consistency the
applicant is also entitle for the same sort of relief .
[4]
55.That since the offence is compoundable one and legal heirs of the
deceased are intending to file their compromise application as a
faisla has been held in between the parties out side of court on
Holy Quran by their neckmard for which they have given their
no objection by filing affidavits before this Honourable court in
which they have categorically stated that hey have no objection if
the applicants accused is granted on bail .
56.That nothing incriminating has been secured from the applicant

accused which prima facie connected him with the commission
of the offence.
57.That neither the applicant hardened criminal nor disparate nor

previous convicted as per the instructions.
58.That case has been challaned and the applicant accused is no

more required to the police for further investigation and
remaining of the applicant in jail for indefinite period would not
serve of any purpose of prosecution .
59.That there is no apprehension of absconsion of the applicant

s/accused as he is ready to furnish his solvent surety to the
satisfaction of this Honourable Court

APPLICANT/ACCUSED
CERTIFICATE
This is to certify that this is 2nd Bail application on

behalf of the applicant/accused before this Honourable Court, on
ground of compromise .
AYAZ ALI GOPANG

ADVOCATE
BENAZIRABAD
B. A. No: OF 2014.
Piral alias Sikandar ….

………………...................Applicant/accused
VS
The State .………….…………………………………………….……

Opponent

Nawabshah
U/S 302,, 337-H(ii) , 504, 148, 149
AFFIDAVIT
I Jahangir son of Shamus Din Gopang Muslim Adult R/O

Jamali colony Nawabshah District Shaheed Benazirabad do
9. That I am the real son of the deceased Shamus Din and so also I
am one of the eye witness of case.
10.That since we have patched up with the all accused nominated in

the above case including the applicant/accused as our
grievances has been resolved in a private faisla outside the court
on Holy Quran and now I have no more grudge against the
applicant accused or against the co accused in the above case
11.That we are intending to file the compromise application before

the trial court when all the formalities of court will completed
but still case is pending in the court of civil judge JM-III
Nawabshah for the proceeding of section 87 and 88 Cr PC
against the absconder accused .
12.That I have waived m right of Qissas and Diyat to the applicant
accused and other co accused persons in the above case in the
name of almighty of Allah without paying or claiming the
amount of Diyat .
13.That I am swearing this affidavit before this Honorable Court


Advocate

BENAZIRABAD
B. A. No: OF 2014.

VS
The State .………….…………………………………………….……

Opponent
Nawabshah
U/S 302,, 337-H(ii) , 504, 148, 149
AFFIDAVIT
I Mst Mitha Widow of Shamus Din Gopang Muslim Adult

R/O Jamali colony Nawabshah District Shaheed Benazirabad do
1. That I am widow of the deceased Shamus Din and one of the

LRS of deceased.
2. That since we have patched up with the all accused nominated in

3. That we are intending to file the compromise application before

4. That I have waived m right of Qissas and Diyat to the applicant
amount of Diyat .


Advocate

BENAZIRABAD
B. A. No: OF 2014.

VS
The State .………….…………………………………………….……

Opponent

Nawabshah
U/S 302,, 337-H(ii) , 504, 148, 149
AFFIDAVIT
I Mst Shazia Daughter of deceased Shamus Din Gopang

Muslim Adult R/O Jamali colony Nawabshah District Shaheed
1. That I am daughter of the deceased Shamus Din and one of the

LRS of deceased.

3. That we are intending to file the compromise application before

4. That I have waived m right of Qissas and Diyat to the applicant
amount of Diyat .

Advocate

BENAZIRABAD
B. A. No: OF 2014.
1. Manzoor Ali son of Ali Khan

2. Gulab son of Hakim Ali
Benazirabad
…………………………...................Applicants/accused
VS
The State .………….………………………………………………….……

Opponent
Crime No: 27/2014, PS Tlauka

Nawabshah
U/S 302, 496-C,419, 34 PPC
BAIL APPLICATION
It is prayed on behalf of the applicants/accused above

named, that this Honourable Court may be pleased to release them,
facts and ground.
-: F A C T S :-
The facts of the case are that the complainant Aijaz Ali son of Ali
Gohar lodged his FIR at PS Taluka Nawabshah, on 15-3-2014 at
about 16:00 hours, alleging therein that he has contracted marriage
with Mst Hameeda daughter of Ali Khan Zardari on 6-2-2014 as per
the injunction of the Islam and after marriage his wife used to reside
with him in his house, which marriage annoyed the Manzoor Ali
son of Ali Khan , Ali Khan son of Muhammad Ali, Umaid Ali Son of
Gulab and Gulab son of Hakim Ali Zardari and they used to ask
that they would kill the complainant party. On 5-3-2014 Rais Haji
Riaz Hussain Zardari called the complainant party , where he
compelled them for faisla , on which complainant along with his
wife Mst Hameeda, his father Ali Gohar and
[2]
brother Nazeeer Ahmed went to Haji Riaz Hussain Zardari at his

bungalow situated in Ghulam Hyder Shah Colony, where they saw
that each Manzoor son of Ali Khan Zardari Ali Khan Son of
Muhammad Ali Zardari, Ameer Ali swonf Gulab and Gulab son of
Hakim Ali Zardari along with two unidentified person, who were
present at the Bungalow of Haji Riaz Hussain Zardari. Haji Riaz
Hussain Zardari asked to complainant party to return Mst
Hameeda to his father Ali Khan and Ali Khan would give the hand
of his daughter Mst Hameeda by away of Rukhsati to the
complainant after 15 days , on which complainant party asked to
Haji riaz Hussain Zardari that Ali Khan and other would kill to Mst
Hameeda, on which Haji Riaz Hussain Zardari replied gave
assurance and take responsibility that Ali Khan party would not kill
to Mst Hameeda and on such assurance made by Haji Riaz Hussain
before the complainant party, they returned Mst Hameeda to his
father Ali Khan and then all of them took away Mst Hameeda with
them. The complainant then came into knowledge that Ali Khan
[party had got contracted marriage of Mst Hameeda with Ameer
Ali Zardari , on which complainant filed such application before the
court of learned sessions Judge Shaheed Benazirabad and when Ali
Khan party came to know about the filing of the application for the
recovery of Mst Hameeda, who before reaching the police at their
village, they vacant their houses and wetn away, the complainant
party kept on searching and on the day of lodging of FIR at dawn
time the complainant alogn with his father Ali Gohar and brother
Nazeer Ahmed were going on their motorcycle towards the
Nawabshah town when they reached near village Jumo Khoso they
saw that all the above 4 accused were going towards their village
along with Mst Hameeda in Suzuki Pickup and the complainant
party were still on the way , they were inform that accused persons
have killed to Mst Hameeda. The complainant then went to PS and
informed the police about the incident and then the complainant
along with police went towards the place of occurrence and found
that dead body of Mst Hameeda was lying in the hue of Ali Khan
Zardari and she was having firearm injuries on her neck and chest
and was bleeding and expired after got conducted the postmortem
with the help of police the complainant then went and lodged the
present FIR.
After registering of the FIR, the police of PS Taluka

Nawabshah arrested the applicant accused who are in judicial
custody hence this
[3]
-: G R O U N D S :-
61.That the case registered against the applicants/ accused is false

and fabricated one on account of enmity which is even admitted
in the FIR otherwise the applicant are innocent they have no
committed the alleged offence
62.that admittedly neither the complainant nor his PWs has seen the
accused persons to commit the murder of deceased but on
hearsay evidence he has lodged the present FIR without
disclosing the source of information from whom he was
informed about the committing the murder of his wife Mst
Hameeda and as such there is no substances on the record to
connect the applicants/accused with the alleged offence of the
murder and as such the case against the applicants/accused
requires further inquiry ,.
63.that admittedly the preliminary investigation in the present case

has been conducted much before the lodging of the FIR which
itself shows that there is clear violation of mandatory provision
of section 164 Cr PC and as such the case against the
applicants/accused has become of further inquiry .
64.That since the offences as alleged is compoundable one and after

registering the FIR, Faisla was made in between the parties by
their neckmard on Holy Quran after the Faisla grievances of the
party has been resolved and now there is no ill will exist in
between the parties and they are intending to file compromise
application in the trial court after submission of the challan in
completing all the formalities of the court and even otherwise
legal heirs of the deceased have sworn their affidavits in which
they have categorically given their no objection if the applicants
are admitted on pre arrest bail .
65.That since after faisla just to maintain peace and public

tranquility in the vicinity and to maintain their brothery, parties
have patched on Holy Quran and if the applicants/accused are
admitted on pre arrest bail it would promote their good
relationship.
[4]
66.That the applicants/accused are neither disparate criminals,

as already faisla has been made in between the parties and there
is no apprehension of absconsion of the applicant s/accused as
they are ready to furnish their solvent surety to the satisfaction
of this Honourable Court

APPLICANTS/ACCUSED
CERTIFICATE

AYAZ ALI GOPANG

ADVOCATE
BENAZIRABAD
A. B. A. No: OF 2014.
Ali Khan and another

………………….......................Applicants/accused
VS
The State .………….………………………………………………….……

Opponent

Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT
I Aijaz Ali son of Ali Gohar Muslim Adult R/O Village Muhammad
Liaq Zardari Deh 6 Dad Taluka Nawabshah District Shaheed
1] That husband of the deceased Mst Hameeda and being her

husband I am one of the Wali of deceased and I am also
complainant in the above case
2] That our faisla has been made with the accused persons
nominated in the FIR on Holy Quran by our neckmard and as such
I have forgiven the nominated accused in the present case in the
name of Almighty Allah and I am also intending to file the
compromise application before the trial court but still the case is
under investigation and challaned has not yet been submitted and
as such I am filing my this affidavit in which I giving no objection if
the applicants are released on bail.
3] That in a private faisla held by our neckmard on Holy Quran
outside the court in which my grievances has been resolved and
now being Muslim I have no more grudge or any ill will against the
applicants accused as I have pardoned them in the name of
almighty Allah without claiming or paying the Diyat amount.
4] That I am swearing this affidavit with my free will and accord

without any compulsion .

Advocate

BENAZIRABAD
A. B. A. No: OF 2014.

VS
The State .………….………………………………………………….……

Opponent

Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT
I Asif Ali son of Ali Khan Zardari Muslim Adult R/O Village Mir
Muhammad Zardari, Taluka Nawabshah District Shaheed
1] That I am brother of deceased Mst Hameeda and being real
brother of deceased I am one of the LRs of deceased Mst Hameeda .



Advocate

BENAZIRABAD
A. B. A. No: OF 2014.

VS
The State .………….………………………………………………….……

Opponent
Nawabshah
U/S 302, 496-C,419, 34 PPC
AFFIDAVIT
I Farooq Ali son of Ali Khan Zardari Muslim Adult R/O Village
Mir Muhammad Zardari, Taluka Nawabshah District Shaheed
1] That I am brother of deceased Mst Hameeda and being real

brother of deceased I am one of the LRs of deceased Mst Hameeda .



Advocate
MAGISTRATE-III NAWABSHAH
B. A. No: OF 2014.
Maqsood Ali son of Allah Ditto Mithiyani by caste

Adult Muslim R/O Near Chhoti Masjid Mohalla
Gharibabad Nawabshah presently confined in District
Jail Shaheed Benazirabad ……………...……. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 452, 506/2, 354, 504,
34, 337-L(ii) PPC
BAIL APPLICATION
-: F A C T S :-
Briefly facts leading to present case are that complainant Mst

Saima Ambreen lodged present FIR with police Station Airport, on
21-3-2014 at about 10:00 hours, alleging therein that as per statement
of her detailed below, she is wife of late Fakeer Mushtaque
Mithiyani Bloch and residing in house No A -1393 Mohalla
Gharibabad, near Chhoti Masjid Nawabshah and is a teacher and
residing along with her family members mentioned above address.
At about 1, ½ years ago her husband passed away, after the death of
her husband they are living in one house and in upper portion of
the house her brother in law namely Maqsood Ali
[2]
( applicant/accused) residing alongwith his family and in presence

of husband of the complainant, the said property was partitioned,
who after the death of her husband was asking to the complainant
and her children to leave the ground portion of the property in his
favour and also asked to the complainant that said portion is his
property, on which complainant party are saying that, partitioned
already took place and such a thing is also in the knowledge of
other relatives, on which time and again were issuing the threats to
leave the house, on 28-3-2014 at about 5:00 Hours at evening time
the complainant along with her sons Saddam Hussain, Abdul
Wahab and other family members were present in her house, at that
time her brother in law Maqsood Ali along with one unidentified
person having pistol and his wife Mst Jameela forcibly entered into
her house and her brother in law straight the pistol and asked that
yet complainant party have not left the house today the
complainant shall not be spared, thereafter Mst Jameela dragged
from the hairs of the complainant and Maqsood Ali
applicant/accused and unidentified persons aimed the pistol and
issued the threats that if the complainant party would not leave the
house then her son would be killed meanwhile complainant and her
children made hue and cries , which attracted the Mohalla peoples
at that time neighboror and one Syed Hajjan Shah who came by
running and seeing to them, the accused persons issued murder
threats and run away boarded in white color car towards the city,
accused persons caused kicks and fists blows to the son of the
complainant and also used abusive language, thereafter
complainant moved such an application before the Honourable
session judge and after getting the order No. 5718 dated 14-3-2014
having presented the same register the present FIR after disclosing
the above story hence the present FIR.

arrested and presently he is confined in District jail Shaheed
Benazirabad, hence this application on the following grounds.
-: G R O U N D S :-
39. That the applicant/accused is innocent and has not

[3]
40. That the case against the applicant/accused is false and
fabricated one and same has been managed by the

complainant for ulterior motives and malafidly registered the
present FIR.
41. That there is delay of 21 days in registration of the FIR,. Which
has not bee explained plausibly, however PS is only away at

the distance of 1 Km from the place of alleged incident , which
makes the case of one further inquiry.
42. That present FIR is registered on 21-3-2014 but in the body of
FIR incident shown on 28-3-2014 in this regard 7 days prior of

alleged incident this FIR has been registered which is beyond
to understand, which also make the one of further inquiry.
43. That the section mentioned in the FIR are bailable except
section 452 and 506/2, which too do not fall within

prohibitory clause of section 497, Cr PC .
44. That the enmity has been admitted in the FIR in respect of the
mentioned property and it is yet to be determined whether

alleged incident was took place or not even matter is purely
civil nature hence falsely implication can not be ruled out,.
45. That allegation against the applicant/accuses are in general
nature and there is no any specific role attributed to the

applicant accused which requires further inquiry.
46. That in fact applicant accused registered the FIR being crime
No 11/2011, PS Airport , under section 324 , 452/2, 114, 34 PC

against the Nabi Bux Mithayni his wife Mst Rabitunisa and
his son Umair in that case after usual investigation the case
was challaned against the Nabi Bux but his wife and son were
released by police under section 169 Cr PC then applicant
/accused moved application under section 193 Cr PC for
taking the cognizance against the wife of Nabi Bux and his
son and on the said application the Honourable 3rd Additional
[4]
took cognizance and joined them as a accused , due to that

complainant of present crime registered the present FIR, because
of that she is playing in the hand of Nabi Bux and his wife
otherwise no any sincerity in the present alleged case.
47. That as per contents of the Fir non have been received any
injury neither any letter nor any medical certificate is stated in

the FIR hence section 337-L(ii) doesn’t attracted to the present
case .
48. That as per contents of the FIR, the cloths of the complainant
was not torn hence section 354 in consistence with the

definition of present case.
49. That it is impossible for every one that any person who along
with his wife went to committing an offence with unidentified

person, which is beyond to understand, as no one can take
any strange person with his wife, all the assertions of
complainant are false and fabricated one.
50. That as per the contents of the FIR complainant party was
present in her house and as per alleged allegation that,

accused persons forcibly entered into the house of
complainant in this regard, it is yet to be determined whether
the main door of complainant’s house was opened or not who
knocked the same, who opened the same, same may be
determined after recording the evidence of the case , which
also needed to further inquiry.
51. Tat the investigation of the case has been completed and he is
no more required to the further inquiry and case has been

challaned.
52. That the story of FIR is completely different from the 22-A 6(i)
Cr PC application which creates doubt that the case is

managed one.
53. That all the alleged witnesses are kith and kin of the
complainant hence they are interested witnesses of the

complainant.
evidence.
[5]

APPLICANT/ACCUSED
CERTIFICATE

BAHADUR ALI MAHESAR

ADVOCATE

B. A. No: OF 2014.
Maqsood Ali son of Allah Ditto Mithiyani by caste

Adult Muslim R/O Near Chhoti Masjid Mohalla
Gharibabad Nawabshah presently confined in District
Jail Shaheed Benazirabad ……………...……. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 452, 506/2, 354, 504,
34, 337-L(ii) PPC
BAIL APPLICATION
-: F A C T S :-

Saima Ambreen lodged present FIR with police Station Airport, on
21-3-2014 at about 10:00 hours, alleging therein that as per statement
of her detailed below, she is wife of late Fakeer Mushtaque
Mithiyani Bloch and residing in house No A -1393 Mohalla
Gharibabad, near Chhoti Masjid Nawabshah and is a teacher and
residing along with her family members mentioned above address.
At about 1, ½ years ago her husband passed away, after the death of
her husband they are living in one house and in upper portion of
the house her brother in law namely Maqsood Ali
[2]
( applicant/accused) residing alongwith his family and in presence

of husband of the complainant, the said property was partitioned,
who after the death of her husband was asking to the complainant
and her children to leave the ground portion of the property in his
favour and also asked to the complainant that said portion is his
property, on which complainant party are saying that, partitioned
already took place and such a thing is also in the knowledge of
other relatives, on which time and again were issuing the threats to
leave the house, on 28-3-2014 at about 5:00 Hours at evening time
the complainant along with her sons Saddam Hussain, Abdul
Wahab and other family members were present in her house, at that
time her brother in law Maqsood Ali along with one unidentified
person having pistol and his wife Mst Jameela forcibly entered into
her house and her brother in law straight the pistol and asked that
yet complainant party have not left the house today the
complainant shall not be spared, thereafter Mst Jameela dragged
from the hairs of the complainant and Maqsood Ali
applicant/accused and unidentified persons aimed the pistol and
issued the threats that if the complainant party would not leave the
house then her son would be killed meanwhile complainant and her
children made hue and cries , which attracted the Mohalla peoples
at that time neighboror and one Syed Hajjan Shah who came by
running and seeing to them, the accused persons issued murder
threats and run away boarded in white color car towards the city,
accused persons caused kicks and fists blows to the son of the
complainant and also used abusive language, thereafter
complainant moved such an application before the Honourable
session judge and after getting the order No. 5718 dated 14-3-2014
having presented the same register the present FIR after disclosing
the above story hence the present FIR.

arrested and presently he is confined in District jail Shaheed
Benazirabad, hence this application on the following grounds.
-: G R O U N D S :-

[3]
58. That the case against the applicant/accused is false and
fabricated one and same has been managed by the

complainant for ulterior motives and malafidly registered the
present FIR.
59. That there is delay of 21 days in registration of the FIR,. Which
has not bee explained plausibly, however PS is only away at

the distance of 1 Km from the place of alleged incident , which
makes the case of one further inquiry.
60. That present FIR is registered on 21-3-2014 but in the body of
FIR incident shown on 28-3-2014 in this regard 7 days prior of

alleged incident this FIR has been registered which is beyond
to understand, which also make the one of further inquiry.
61. That the section mentioned in the FIR are bailable except
section 452 and 506/2, which too do not fall within

prohibitory clause of section 497, Cr PC .
62. That the enmity has been admitted in the FIR in respect of the
mentioned property and it is yet to be determined whether

alleged incident was took place or not even matter is purely
civil nature hence falsely implication can not be ruled out,.
63. That allegation against the applicant/accuses are in general
nature and there is no any specific role attributed to the

applicant accused which requires further inquiry.
64. That in fact applicant accused registered the FIR being crime
No 11/2011, PS Airport , under section 324 , 452/2, 114, 34 PC

against the Nabi Bux Mithayni his wife Mst Rabitunisa and
his son Umair in that case after usual investigation the case
was challaned against the Nabi Bux but his wife and son were
released by police under section 169 Cr PC then applicant
/accused moved application under section 193 Cr PC for
taking the cognizance against the wife of Nabi Bux and his
son and on the said application the Honourable 3rd Additional
[4]
took cognizance and joined them as a accused , due to that

complainant of present crime registered the present FIR, because
of that she is playing in the hand of Nabi Bux and his wife
otherwise no any sincerity in the present alleged case.
65. That as per contents of the Fir non have been received any
injury neither any letter nor any medical certificate is stated in

the FIR hence section 337-L(ii) doesn’t attracted to the present
case .
66. That as per contents of the FIR, the cloths of the complainant
was not torn hence section 354 in consistence with the

definition of present case.
67. That it is impossible for every one that any person who along
with his wife went to committing an offence with unidentified

person, which is beyond to understand, as no one can take
any strange person with his wife, all the assertions of
complainant are false and fabricated one.
68. That as per the contents of the FIR complainant party was
present in her house and as per alleged allegation that,

accused persons forcibly entered into the house of
complainant in this regard, it is yet to be determined whether
the main door of complainant’s house was opened or not who
knocked the same, who opened the same, same may be
determined after recording the evidence of the case , which
also needed to further inquiry.
69. Tat the investigation of the case has been completed and he is
no more required to the further inquiry and case has been

challaned.
70. That the story of FIR is completely different from the 22-A 6(i)
Cr PC application which creates doubt that the case is

managed one.
71. That all the alleged witnesses are kith and kin of the
complainant hence they are interested witnesses of the

complainant.
evidence.
[5]

APPLICANT/ACCUSED
CERTIFICATE

BAHADUR ALI MAHESAR

ADVOCATE
MAGISTRATE-I NAWABSHAH
B. A. No: OF 2014.
1. Ghulam Rabani son of

2. Sher Khan Jamali .
3. Rashid Ali Jamali.
4. Ghazi Khan Jamali
All ……………………………. ..… .Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 506/2, 337-H(ii), 147,
148 PPC
BAIL APPLICATION

pleased to release them on bail in the above case/crime on
-: F A C T S :-
Briefly facts leading to present case are that complainant Yar
Muhammad Jamali lodged present FIR with police Station Bandhi,
alleging therein that, there is dispute going with namely
Muhammad Ashraf, over agricultural land, measuring 8-00 Acres
situated in Deh 66 Nusrat, due to that dispute about one month
ago , prior to the registration of FIR a faisla was held in between the
parties and matter was settled, due to such faisla complainant’s
cousin Ali Akbar Jamali was annoyed and used to ask the
complainant that they would teach lesson to the complainant today
there was water rotation and complainant and his peasants Ali
Madad and Ali Mardan were together were going towards Shah
Abad water Course for water rotation to cultivate their lands, where
at about 1:00 noon near the agricultural land reached near the house
of Ali Akbar Jamali where they saw each one Ali Akbar Jamali
armed with repeater, Muhammad Ayoob Jamali armed with
repeater, Ghulam Rabani Jamali armed with pistol, Lal Khan Jamali
armed with DBBL Gun, Sher Khan Jamali having hatchet, Haji Khan
Jamali armed with repeater, Muhammad Harif Jamali armed with
repeater, and four unidentified persons very well seen and would
be identified if seen again duly armed with guns came, accused Ali
Akbar Jamali raised Hakkal the complainant that they would teach
lesson to complainant and would not allow him to irrigate land
through water and if complainant rotated water in the land, he
would be killed, due to fear of weapons complainant remained
silent. All accused persons duly armed with weapons made aerial
firing while issuing murderous threats to the complainant party
went away towards their houses. the complainant then went to the
house of gentlemen Moula Bux Jamali, who was not present ion the
house and after meeting with whom complainant came at PS and
lodged present FIR
After registration of FIR, the applicants/accused were arrested and
presently they are confined in District Prison. Shaheed Benazirabad,
hence this application on the following grounds.
-: G R O U N D S :-

76. That the applicants/accused are not previous convicts as per
instructions.
77. That all the sections applied in the FIR are bailable, except
sections 506/2 PPC, which too doesn’t fall within the

78. That no specific role, p[art or overt act is assigned to the
applicants/accused and there are mere general allegations.
79. That there is admitted enmity over agricultural land, hence
false implication of the applicants/accused can not be ruled

out.
80. That as alleged by the complainant that nine persons duly
armed with weapons and came at the alleged land but they
did not cause any slap neither to the complainant nor his
alleged PWs and allegations against the applicants/accused is
of aerial firing, which aspect also makes the case of
applicants/accused is one of further inquiry.
81. That co accused have already been granted pre arrest bail by
the court of Honourable 1st Additional Session Judge Shaheed

Benazirabad, hence under the rule of consistency
applicant/accused are entitled for the concession of bail.
82. That all the alleged witnesses are haries and setup persons of
complainant hence they are interested.
83. That the applicants/accused are respectable citizen and if they
are arrested by the police they shall be humiliated and

disrespected at their hands.
evidence.
85. That applicants/accused are ready to furnish solvent surety

APPLICANTS/ACCUSED
CERTIFICATE

ADVOCATE

BENAZIRABAD
B. A. No: OF 2014.
Saleemullah alias Mor son of Habibullah

Adult Muslim by caste Solangi R/O Ahmed Abad
Colony Moro District N-Feroze presently confined
In District Jail Shaheed
Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 23A (i), S-.A Act .
BAIL APPLICATION

-: F A C T S :-
Briefly facts leading to present case are that complainant

ASI Shahzado lodged his FIR at PS Daur on 17-2-2014 , at
about 23:00 hours, alleging therein that he has lodged the FIR
NO 11/2014 under section 402 , 399 on behalf of the state and
arrested a accused Saleemullah alias Mor Machi and
recovered one unlicensed pistol alongwith bullets in present
of witnesses and mashirs and recovered weapons to be
disclosed unlicensed,
[2]
therefore this FIR was lodged under section 23-A (i) SA

against the accused.
DESCRIPTION OF RECOVERED LICENSE
One Mouser containing the magazine in working condition

without number , 69/2, written on it of 30Bore and 4 live
Bullets sealed.
After usual investigation the challan has been

submitted and accused is behind the Bar. Hence this
-: G R O U N D S :-

and noting has been recovered from the possession of the
motive.
88. That actually the present applicant accused illegally and
unlawfully arrested from his house in presence of inmates

resultantly CD-70 motorcycle newly purchased by the present
applicant accused was also took away by the complainant at
the behest of one local Wadera of community of the accused
persons and he was booked in false case in order to usurp CD-
70 Motorcycle cash amount and so also pleased to said local
Wadera therefore case of the present applicant accused is
become for further inquiry .
89. That it is amazing to note accused persons were allegedly
were standing at stated place alongwith deadly weapons and

complainant party was also having government arms and
ammunition and they were on patrolling purpose in order to
stop the crimes but without any resistance and encounter
three of the accused out of 6 accused whereas arrested by the
complainant party which aspect of the case cuts very roots of
the prosecution story and it is out of understand of the
prudent mind to believe or rely upon the story setup by the
complainant party and their false implication could not be
rule doubt
[3]
all to gather there case of the accused persons become of further

inquiry .
90. That no any allegation of committing robbery from the
complainant party ,or any other vehicle has been allegedly in

the FIR therefore section applied by the police are totally
misapplied therefore case of the present accused is fit for
further inquiry .
been shown associated by the complainant [party in

same police personal , therefore inspite of fact that alleged
place of incident was road leading from eastern to western
inquiry.
92. That alleged recovery shown by the complainant party from
the present accused is looking to be false and that recovery

has only shown by the complainant party in order to made
out the strong case against the applicant accused otherwise
nothing has been recovered from his possession and all the
recoveries shown by the complainant party allegedly from the
possession of the applicant accused would be attentively
amount of Rs 5000 to Rs 10,000 /- which can be easily
arranged by the police in order to give the color to true nature
to be the false story therefore case became for further inquiry .
93. That applicant accused is respectable persons and government
employees and rendering his service with education

department and he has been falsely implicated in this false
and bogus case with malafide intention for the ulterior motive
.
evidence.
[4]

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MEER NAWAZ KALHORO
Reg-HC No 164/N-Feroze

MAGSITRATE-III NAWABSHAH
B. A. No: OF 2014.
Ali Gul son of Allah Jurio Mashori

Shaheed Benazirabad ……………….………...…
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 56/2014 P.S, A Section

Nawabshah
OFFENCE U/S 337-L(ii), 337-F(i), 337-
A(ii), 504, 34 PPC .
BAIL APPLICATION

-: F A C T S :-

Muhammad Bux Son of Allam Khan Mashori, R/O Village
Nawab Murad Ali, Deh 85 Nusrat Taluka Daur District
Shaheed Benazirabad, lodged his FIR at PS A Section
Nawabshah. On 18-3-2014 at about 18:00 hours , alleging
therein that complainant is running Harap, about one month
back accused Allah Jurio and complainant fought due to
family matter , and they are not in talking terms, the relative
of the complainant Ali Gul used to issue threats that he will
take revenge, today at morning time, complainant and his son
Ashraf Ali and Uncle Tooh departed to Taj Colony
Nawabshah for their personal work, when they were
[2]
returning back and they reached near Murtaza Patrol Pump

and they were awaiting for vehicle to go their house, at about
2:00 PM the they saw the one red Color Motorcycle thereupon
three persons were available each Ali Gul armed with hatchet,
Dilsher armed with lathee and one unknown accused person,
they stopped their motorcycle near of complainant and by
getting down from their motorcycle they started abusive
language and also threatened that they are come to take
revenge from complainant and meantime Ali Gul caused
hatchet blow to the uncle of the complainant on head, Dilsher
caused lathee blows to the uncle of the complainant on arm
and hands, and other accused persons caused kicks and fists
blows to the complainant and his son, the complainant gave
them name of Almighty fo Allah and rescued themselves ,
meantime accused by issuing threats went away, thereafter
complainant brought to his uncle at PS and received letter for
treatment , thereafter he shifted his uncle at Hospital and then
he came and lodged present FIR.
After usual investigation the police of PS A Section

Nawabshah arrested the applicants/accused who is in
judicial custody hence applicant/accused filed present bail
application, before this Honourable Court, on the following
grounds .
-: G R O U N D S :-
25.That there is delay in lodging of the FIR about 6 hours

and by managing each and every thing, as such false
implication of the applicant/accused can not be ruled out .
26.That no such incident whatsoever stated in the FIR is ever

took place but complainant with malafide intention has
managed this false story, just to implicate the applicant in
present case otherwise applicant accused is not concerned
with alleged story.
[3]
27.That the complainant admitted his disputed which is running

both parties facts pertinent to the matter that firstly FIR was
lodged by applicant alleged accused party against the
complainant party in crime No 5/2014 at PS Balu Ja Kuba,
thereafter complainant time to time used to threat that they
will kill the applicant party and falsely implicate the
applicants accused in false cases , thereupon the
applicant/accused moved an application for legal protection
against te complainant party before Honourable Session Judge
Shaheed Benazirabad, thereafter complainant party annoyed
with the applicant party and by joining the hand with police
party he lodged present false FIR, otherwise no such
incitement has ever taken place, whereas the place of incident
is populated area which is busy 24 hours and such incident
has taken place near Murtaza Patrol Pump which is thickly
populated area and transport and passerby used to run round
the clock otherwise applicant accused has no concerned with
the alleged story.
28.That the complainant party admitted in their FIR that they

have received letter from PS A Section for treatment, which is
without any entry, without provincial certificate the
complainant lodged present FIR which is clearly false and
managed one.
29.That all the sections are bailable except the section 337-A(ii)
which too doesn’t fall with the prohibitory clause of section
497 Cr PC.
30.That all the PWs cited in the FIR are sweet obligor and
relative of the complainant hence they are interested
witnesses of the complainant

complainant
[4]


APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
IN THE HIGH COURT SINDH CIRCUIT BENCH
HYDERABAD
Mehboob Zardari son of Ali Hassan Zardari

Muslim, Adult, presently confined in District
Jail Shaheed Benazirabad ……………………Applicant/accused
VS
The State………………………..…………………………….Opponent

Nawabshah Offence, 9/C, CNS Act,
BAIL APPLICATION

grounds:-
-: F A C T S :-
Brief facts of the case are that SIP Muhammad Iqbal

Wassan, SHO of PS A Section Nawabshah lodged his FIR at
PS A Section Nawabshah, on 16-2-2014 at about 2:15 hours.
Alleging therein that he alongwith his subordinate staff was
on [patrolling in Govt: Mobile No SP 6951, vide entry No. 12
dated 16-2-2014 at about 3:00- PM when have reached at Taj
Colony Railway crossing he received spy information that the
applicant/accused Mehboob Zardari, Abid Magsi, Saleem
Gopang and Ghulam Abbas Arain are selling Chars at dirty
waster disposal Machine in public openly, on which he
reached at pointed place at about 4:00PM and found four
persons having black Colour Plastic Bags in their hands, who
on seeing police tried to run away, but were apprehended by
police. It is stated in FIR that due to non availability of private
Mshirs the ASI Manzoor Ali Bhangwar and HC Darban Ali
acted as Mashirs, the police secured plastic Bags from them,
one person told him name Mehboob son of Ali Hassan
Zardari and from his Bag 08 pieces small and big pieces of
Chars were secured along with Rs. 200/- Cash the Charas was
weighed which become 1200 grams out of which 200 grams
were separated and sealed for sample, the an other person
told the name as Abid Hussain Magsi son of Ali Gul, the
police secured 7 small and big of Charas, which was weighed
as 1100 grams, the police separated 100 grams for sample and
cash Rs 300/- cash was also secured from him and likewise
from Saleem Gopang 10 pieces small and big and cash Rs
400/- the Charas was weighed which become 1300 Grams ,
out of which 200 Grams were separated and sealed so also
from 4 the persons Ghulam Abbas Arain the police secured 12
pieces of Charas and cash Rs 500/- the Charas was weighed
which become 1250 grams the police separated and sealed 200
grams as sample the police prepared Mashirnama for jointly
recovered property and brought them at police station and
registered the case accordingly.

custody. A bail application was filed by the applicant accused
before Honourable Sessions Court Shaheed Benazirabad,
which was dismissed, hence the applicant accused got filed
present bail application before this Honourable Court with
following fresh ground.
-: G R O U N D S :-
alleged offence and is suffering from ailment.
229. That the case is fabricated which is apparent from very face of
FIR.
230. That the recovery of Charas has been shown jointly under one
and same Mashirnama.
231. That the pieces of chars have not been weighted separately in
order to know the ight of piece, so also the sample has been
separated from each piece which the Mashirnama and FIR
doesn’t show the weight of sample from each piece.
232. That the place of recovery of Narcotic is very much busy place
in city there are at least 2000 peoples engaged in business every
time but no independent witnesses has been shown to have
witnessed the incident and raid by the police conducted.
233. That the police have left the actual culprits and poor innocent
person have been involved to show their efficiency.
234. That the applicant/accused is not pervious convicted as per

instructions.
235. That there is no apprehension of absconsion of the

236. That other ground will be urged at the time of hearing when
ED__________ ADVOCATE FOR
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2013.
Abdul Razzak Fatha Muhammad Babhan

Presently confined in District prison
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 392, 215 PPC.
BAIL APPLICATION

-: F A C T S :-

Kareem Bux son of Hassan Ali Shar R/O Village Naseer Khan
Shar Deh 28 Nusrat Taluka Daur District Shaheed
Benazirabad, lodged his FIR at PS Jam Dattar. On 18-11-2011,
at about 18:15 hours, alleging therein that, complainant is
Zamindar, he has own motorbike bearing registration No
NHC 4218 CD-70 Model 2011, for his person works. On 18-9-
2011, the complainant was going to village of Porho Khan
Zardari on his motorcycle, when he reached near Musfar
Khan where he saw the two persons were standing there, they
signaled to stop the motorcycle, complainant stopped his
motorcycle, and saw each Gul Baig alias Talib son of Mendro
Shar. Ali Jan son of Ranjhan Shar, R/O village Naseer Khan
Shar all armed with pistols, meantime Gul Baig robbed key of
motorcycle from complainant, and Jan Muhammad robbed
amount of Rs 2000/- and mobile phone from the complainant
meanwhile both accused by snatching the motorcycle they
went away thereafter complainant went house where he
narrated facts with Noor Din son of Hameer Shar, Abdul Aziz
son of Dhani Bux Shar and they conjointly went to Habibullah
shar and narrated whole facts with him who advised that you
may keep the search, thereafter complainant met with uncle of
the accused namely Abdul Hameed son of Abdul kareem
Shar who told that complainant should pay amount of Rs
15,000/- then he shall get return the motorcycle to the
complainant party, the Abdul Hameed uncle of the accused
persons also by receiving the aforementioned amount,
returned the motorcycle then complainant got informed to
Haji Nazeer Shar and who kept faisla of the both parties
ultimately on 3-11-2011 accused refused to give the faisla
thereafter complainant came at PS and lodged present FIR.
After usual investigation the police of PS Jam Dattar

arrested the applicant/accused who are rotting the jail since
their arrest, hence applicant filed present fresh bail
application before this Honourable Court with fresh grounds .
-: G R O U N D S :-

35.That the applicant/accused is innocent and has not

in this false case by the police.
36.That there is inordinate delay of more then 2 months in

lodging the first report and such a delay has not been
explained at all which goes to show that every thing has been
managed and as such the false implication of the
37.That no such incident whatsoever stated in the FIR has ever

taken place but whole drama has been staged by the
just to pressurize and drag the applicant accused in present
case, otherwise applicant accused has no concerned with
alleged offence.
38.That applicant accused was shown armed with pistol but no
any single firearm hit or sustained by the complainant at the
time of robbery, which creates clearly doubt in above story
that all and every things have been managed with core
connivance of his sweet wishers.
39.That there is no any eye witness but complainant by showing

his influential power has managed false story and lodged
present false FIR against the applicant accused.
40.That the story narrated in the FIR is absurd as the same is

41.That the incident as alleged has taken place near Musafar

Khan which is quite a big area but in-spite of that non from
the vicinity came forward to support the version put forth by
the complainant.
42.That the minimum punishment of section 392 PPC is three

years and at bail stage minimum punishment would be taken
into consideration and as such section applied in the First
report doesn’t fall within the prohibitory clause of section 497
Cr PC .
43. That the applicant/accused is in judicial custody and no more


applicant/accused who is ready to furnish solvent surety to

46. That the other grounds will be argued at the time of hearing

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MEER NAWAZ KALHORO
BENAZIRABAD
B. A. No: OF 2014.

Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

[2]


Bullets sealed.

-: G R O U N D S :-

motive.

100. That it is amazing to note accused persons were

allegedly were standing at stated place alongwith deadly
encounter three of the accused out of 6 accused whereas
arrested by the complainant party which aspect of the case
cuts very roots of the prosecution story and it is out of
understand of the prudent mind to believe or rely upon the
story setup by the complainant party and their false
implication could not be rule doubt
[3]

inquiry .

further inquiry .
102. That no any private witness, Mashir or person of locality

has been shown associated by the complainant [party in
inquiry.
103. That alleged recovery shown by the complainant party

from the present accused is looking to be false and that
recovery has only shown by the complainant party in order to
made out the strong case against the applicant accused
otherwise nothing has been recovered from his possession
and all the recoveries shown by the complainant party
allegedly from the possession of the applicant accused would
be attentively amount of Rs 5000 to Rs 10,000 /- which can be
easily arranged by the police in order to give the color to true
nature to be the false story therefore case became for further
inquiry .
104. That applicant accused is respectable persons and

government employees and rendering his service with
education department and he has been falsely implicated in
this false and bogus case with malafide intention for the
ulterior motive .

is no more required to police.

evidence.
[4]

arguments.

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MEER NAWAZ KALHORO
BENAZIRABAD
B. A. No: OF 2014.

Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 12/2014, P.S, Daur

BAIL APPLICATION

-: F A C T S :-

[2]


Bullets sealed.

-: G R O U N D S :-

motive.

implication could not be rule doubt
[3]

inquiry .

further inquiry .
inquiry.

inquiry .

ulterior motive .


evidence.
[4]


arguments.

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MEER NAWAZ KALHORO
BENAZIRABAD
B. A. No: OF 2014.

Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 399. 402 PPC
BAIL APPLICATION

that this Honorable Court may be pleased to release him, on bail in
the above case/crime on the consideration of the fallowing facts
and grounds:-
-: F A C T S :-

ASI Shahzado Khan of CIA Center Nawabshah lodged his Fir on 17-
2-2014 at about 22:30 hours alleging therein that, on same date
complainant along with his subordinate staff under Roznamcha
entry No 8 dated 17-2-2014 proceeded for patrolling purpose,
within jurisdiction on vehicle No SDP 3519, thereafter visiting
different places when they reached at link road from eastern to
western Bhurgari stop at about 21:00 hours where they noticed on
light of vehicle that 6 persons along wit weapons were
[2]
standing there, who signaled for stopping the vehicle of the

complainant presumed to be private vehicle in order to robbed
them , meantime complainant stopped the vehicle alighted from the
vehicle resultantly accused saw the complainant party in police
dress and tried to escape away, meantime complainant very with
strategy encircled the accused persons out of which three accused
persons were caught hold out of which two were having arms and
one having hatchet and due to non availability of private mashirs
the ASI made the mashir to PC No 2308 Shahnawaz and PC 1340
Abdul Sattar and searched the accused and inquired from him
about the parentage , police inquired about the name who disclosed
their name Saleemullah alias Mor son of Habibullah R/O Moro,
and one Mouser was recovered from his possession and he was
further bodily searched but nothing was recovered, same weapons
were checked by the police party, 4 bullets of 30-Bore were
allegedly lying in it, which were unloaded by the complainant
party, second accused disclosed his name to be the Muhammad
Murad son of Punho Dayo R/O Batto Taluka Sakrand, and one rifle
of 7MM was recovered from his possession which was unloaded, in
which one bullet of 7MM was lying and accused was further bodily
searched resultantly two bullets of 7MM were recovered from his
pocket , third accused persons disclosed his name to be the Sarwar
son of Mazan Chandio, R/O Raju Dairo near Seeta Road District
Dadu and one hatchet was recovered from his possession and
nothing other thing was recovered from him during bodily
searched , thereafter accused were asked for the licensed of the
weapons and ammunition who disclosed to be the unlicensed, and
further disclosed about the skipped away accused to be each Akbar
son of Muhammad Siddique Gabol R/O Magazine Mori having
rifle, Ahmed son of Muhammad Machi R/O N-Feroze , Asghar son
of Rasool Bux Keerio R/O New Bato Sakrand, having repeaters and
further accused disclosed that they were standing there in order to
commit robbery and resultantly police party came there to whom
they signaled for stop in order to commit robbery , thereafter al
accused persons along with weapons were allegedly brought at PS
where present FIR was lodged as well as FIR under arms Act was
separately lodged by the complainant party.
After usual investigation the police of PS Daur submitted the

challan before the concerned magistrate as per law . hence this
application on the following ground
[3]
-: G R O U N D S :-


persons and he was booked in false case in order to usurp
CD-70 Motorcycle cash amount and so also pleased to said
local Wadera therefore case of the present applicant accused
is become for further inquiry .

arms and ammunition and they were on patrolling purpose
in order to stop the crimes but without any resistance and
implication could not be rule doubt all to gather there case of
the accused persons become of further inquiry .

further inquiry .

inquiry.
[4]
inquiry .

ulterior motive .


evidence.


arguments.

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
MEER NAWAZ KALHORO
SECOND BAIL APPLICATION

IN THE COURT OF 3rd ADDITIONAL SESSIONS JUDGE
SHAHEED BENAZIRABAD
B. A. In S,C No: OF 2010.
The State
VS
Liaqat Ali Leghari and others

OFFENCE U/S 324, 504, 147, 148, 149
PPC
BAIL APPLICATION

applicants/accused namely Zulfiqar Ali son of Fazal
Muhammad Leghari , Liaqat Ali Son of Fazal Muhammad
Leghari , Shoukat Ali Son of Fazal Muhammad , Sain Bux son
of Muhammad Uris Leghari, all confined in District Jail
Shaheed Benazirabad, that this Honorable Court may be
-: F A C T S :-
the facts leading to the present application are that

complainant Abdul Sattar Leghari lodged his FIR at on 21-1-
2010 at about 18:15 hours , at PS Sakrand which reads as
under:-
“compliant is that Mushtaque Ahmed aged about 30 years is

my younger brother who resides in Saudi Arabia, who
someone month back come to us in our village, Liaqat Ali son
of Fazal Muhammad Leghari and others are not on good
terms with us and from time to time remained on dragger
drawn terms with us, today I alongwith
[2]
my brother Mushtaque Ahmed and nephew Masjid Ali son of
Manzoor Ahmed Leghari were sitting in the common street of
the village in our Ota, when at about 3:45 PM there arrived
accused Zulfiqar Ali son of Fazal Muhammad by caste
Leghari having gun in his hand, Liaqat Ali son of Fazal
Muhammad Leghari having gun in his hand, Shoukat Ali son
of Fazal Muhammad Leghari having pistol in his hand,
Farman Ali son of Fazal Muhammad Leghari having hatchet
in his hand, Sain Bux son of Muhammad Uris Leghari having
gun in his hand, Sohrab son of Abdullah Leghari having
hatchet in his hand, Ameer Hyder son of Haji Allam Leghari
having hatchet in his hand, Shoukat Ali son of Sohrab Leghari
having hatchet in his hand, immediately on arrival they
abused us and asked us that they would not spare us and by
saying so the persons having guns and pistols with the
intention to commit the murder the fired straight upon, which
fire hit to my brother Mushtaque Ahmed who fell down by
raising cries, and after his falling on ground all the accused
persons while abusing went away alongwith their weapons I
then saw y brother Mushtaque Ahmed who was having fire
arm injuries on the mu8scles of his right leg near the knee and
he was bleeding, I then managed transport and brought my
injured brother at Taluka hospital Sakrand from where for
getting treatment I left him at PMC Hospital Nawabshah I
now presented and lodged my report investigation be done
the police after registering the FIR was malafidly

hunting for the applicant/accused have raided their houses
and finding them not there have left the threats to come
again , which compelled the applicants/accused to file ABA
No of 2010 in the court of learned sessions Judge SBA, who
granted interim pre arrest bail to the applicants accused but
letter on by order date 2-7-2010 he did not confirm their
interim pre arrest bail and dismissed the same the applicants
accused filed the criminal bail application No S-565 of 2010, in
the Honourable High Court Sindh Circuit Court Hyderabad
and the applicants accused were granted on interim pre arrest
bail by Honourable High Court Sindh and by order dated 21-
10-2011 directed the applicants accused to appeared before the
learned trial court and the learned trial court was directed to
decided the bail application of the applicants/accused on
merits however the learned sessions Judge Shaheed
[3]
Benazirabad by order dated 10-11-2011 dismissed the ABA of

the applicants accused the applicants/accused then again
preferred ABA in the Honourable High Court Sindh who
granted interim pre arrest bail to the applicants accused by
order dated 2-3-2012 , but latter on the said ABA of the
applicant accused was declined while the other were granted
the concession of the ABA the applicant accused then filed
ABA in the Honourable Supreme Court Pakistan and were
granted pre arrest bail by order dated 13-8-2012 and
ultimately the said order was recalled by order dated 8-10-
2012 the applicants then on 8-12-2012 voluntary surrendered
themselves before this Honourable Court and they were
remanded into judicial custody. The applicant then filed Bail
after arrest before this Honourable Court, but the same was
dismissed and then the applicants/accused filed their bail
before the Honourable High Court Sindh Circuit Court
Hyderabad which is still pending. Since the applicant who
are neither criminal nor disparate criminals and or educated
persons and are governmental officials and they are rotting in
jail since 8-12-2012 without any fault on their part and even
repeated process issued by this court upon the complainant,
injured PWs and other PWs, but no progress in the case could
be made however the applicants are facing agony since long
time . it is therefore this bail application on statuary
grounds/hardship grounds.
-: G R O U N D S :-

committed the alleged offence, but they have been falsely
896. That there is in ordinate delay in lodging the FIR and

such long delay has not be plausibly explained which shows
that after the deliberation and consultation present FIR was
registered and as such false implication of the
applicants/accused who all are coming one and same family
can not be ruled out .
897. That in fact no such incident as alleged in the FIR has

ever taken place, but the whole drama has been staged by the
complainant by
[4]
concocting a false story in league wit the police just to pressurize

and blackmail the applicants accused party who are victim and
injured PWs by the hands of the complainant party and the
applicants party have got registered such FIR earlier registered
before the present case in which applicants/accused Shoukat Ali
is the complainant and said FIR is bearing No 10 of 2010, under
section 324, 337-H(ii), 147, 148, 149 PPC, in which the injured PW
Mushtaque Ahmed and others are the accused and the
applicants accused Shoukat Ali and another co-accused Shoukat
Ali son of Sohrab Leghari are the injured PWs and present FIR is
nothing but the counter blast of earlier FIR lodged by the
applicant and it is yet to be determined at the time of trial as
which of the party is aggressor and which is the aggrieved one,
which requires further inquiry.
898. That in fact the complainant Abdul Sattar who is

practicing advocate at Karachi who very cleverly in
connivance of the police managed a false story and thrown
net over the whole male members of the applicants/accused
party including the two too old and inform persons who is
not even in to position to move freely what to talk about
taking part in the fight .
899. That medical certificate is managed one which can be

verified from the evidence of the medical officer before the
trial court.
900. That no specific role , part , or any overt act is assigned

to either of the applicants/accused and the allegations are
general in nature and the injures as alleged on the person of
the injured are shown on his leg which is non vital part of the
body and as such it is yet to be determined at the time of trial
whether the section 324 PPC is applicable to the case of the
applicant or not and it is also ye tot be determined at the time
of trial that out of the applicants and co accused who is the
responsible for the injuries sustained on the person of the
injured as the injuries opined by the doctor in the medical
certificate is of the palate injury, which requires further
inquiry .
901. That malafide on the part of the complainant and

injured Mushtaque Ahmed can be verified from the facts that
since framing the charge they did not appeared to adduce
their evidence inspite of repeated
[5]
process issued by this Honourable Court and very tactfully they
are trying to prolong the case to drag the applicants, who are
rotting in jail.
902. That constitution of Pakistan article 10-A says that each

and every accused reserved the right of expeditious trail,
however the applicant has been prejudice from the right
given to them by the constitution and as such the applicants
are entitle for the concession of the bail on hardship ground.
903. That this is counter case and two Firs has been
registered from the both side in one and same incident and as
such this case is that of further inquiry.
904. That nothing incriminating has been secured from the

applicants/accused which connected them wit the
commission of the offence.
905. That the case has been challaned and the

applicants/accused are no more required to the police for

evidence.


arguments.
AYAZ ALI GOPANG
APPLICANTS/ACCUSED
CERTIFICATE
This is to certify that this is second bail application

on behalf of the applicants/accused before this Honourable Court,
on statuary grounds.
ADVOCATE
AYAZ ALI GOPANG
Reg- No. HC 462/NWS

BENAZIRABAD
B. A. No: OF 2014.
Muneer alias Imdad son of Ali Hassan alias Allah

Bachayo Khoso confined in District Jail Shaheed
Benazirabad ………………………………. ..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

2014
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Muhammad Javed Iqbal lodged his FIR at
PS Bandhi on 7-2-2014 at about 04:45 hours, alleging therein
that the applicant/accused was arrested in crime NO 9/2014
under section 324, 353, 398, 399, 402, 427 PPC of PS Bandhi
and police secured one DBBL gun which was unlicensed then
he was arrested in crime No 9/2014 as well as in the present
case and such FIR was registered at Police station at PS
Bandhi .

challaned the case. The applicant/accused is in judicial
[2]
-: G R O U N D S :-

committed the alleged offence , but he has been falsely

that, the alleged incident is said to have taken place at the
road and it is admitted that the applicant/ accused along with
others duly armed with lethal weapons were standing at the
road with the intention to commit offence, but no such
incident of robbing on the alleged time has ever been
reported by any of the individual at PS and it is also strange
that all the accused have been shown armed with lethal
weapons and said to have made straight fires upon the police
party from very close range and the police has also made
firing upon the accused persons in their defense but non from
either side sustained single shot injury nor the mobile has
sustained any bullet which was parked near by the
complainant as alleged which itself creates doubt in the
prosecution case and the case against the applicant/accused
has become of further inquiry.

913. That the alleged gun has been foisted upon the
applicant /accused just to establish the case against him,
which has been malafidly foisted upon otherwise nothing has
been secured from the applicant/accused.
[4]

Mashirnama of the arrest and recovery two separate FIR have
been registered.


evidence.


arguments.
AYAZ ALI GOPANG

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
AYAZ ALI GOPANG
Reg- No. HC 462/NWS
BENAZIRABAD
B. A. No: OF 2014.
1. Zameer alias Jameel son of Hadi Bux Khoso

2. Muneer alias Imdad son of Ali Hassan alias Allah
Bachayo Khoso Both confined in District Jail Shaheed
Benazirabad ………………………………. ..…
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 324, 353, , 398, 399, 402,
427, PPC
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Muhammad Javed Iqbal lodged his FIR at
PS Bandhi on 7-2-2014 at about 04:00 hours, alleging therein
that he alongwith his subordinate staff left the PS vide Entry
No 15 dated 7-2-2014 at about 00:15 and went for patrolling
duty, after patrolling various places when they reached at Dur
Muhammad Phatic, they saw on the head light of the mobile
that 7 persons were standing duly armed with lethal weapons
from both sides of road who were identified to be the Zameer
alias Jameel son of Hadi Bux Khoso with KK, Imdad alias
Muneer alis Badar son of Ali Hasan alias Allah Bachayo
Khoso having DBBL gun, Ali Gul Khoso, Ali Shafa alias
Fakeer Khoso, Ranjho Khoso having KKs , Asghar Jamali ,
Nabi Bux Khokhar having DBBLs Guns and two
[2]
motorcycles were parked near by their side and they were

standing with the intention to commit robbery from the
vehicles passing through the road, the complainant party then
stopped their mobile and alighted from it, on seeing the police
party and police uniform the accused persons by taking the
shelter by the side of the road they made straight fire upon the
police party with intention to commit their murder, the police
party also by taking the position made firing in their defense
on the commotion of the firearm report the police of Abdul
Haq Railway Phatic namely HC Muhammad Asfhaf PC
Abdul Qayoom and PC Sher Muhammad also arrived at the
place of encounter, and he accused persons also made firing
upon them with intention to commit their murder they also
made firing in their defense and such firing was continue for
about 15 minutes in the meantime the police arrested the
applicants/accused and recovered crime weapons from them
while the remaining accused persons succeeded to run away
by taking the advantage of darkness , the police checked the
recovered weapons and inquired about its licensed but
accused persons could not produced the licenses and
disclosed same to be the unlicensed one , during the inquiry
the apprehended accused admitted that on 22-1-2014 they had
used the same weapons in the commission of the offence and
then such Mashirnama of arrest in presence of the mashirs HC
Muhammad Ashraf and PC Muhammad Ahsaque and
arrested the accused persons and prepared such Mashirnama
of the arrest and recovery so also the Police secured two
motorcycles of accused persons and then brought the accused
alongwith with recovered article were present FIR was
registered

challaned the case. The applicants/accused are in judicial
-: G R O U N D S :-

[3]

922. That very identity of the applicants/accused on the

head light of the mobile in the field at odd hours of the night
with their names and parentage is not free from doubt, which
is very week type evidence which requires corroboration but
the same is lacking which requires further inquiry .
road and it is admitted that the applicants/ accused along
with others duly armed with lethal weapons were standing at
the road with the intention to commit offence, but no such
reported by any of the individual at PS and it is also strange
that all the accused have been shown armed with lethal
prosecution case and the case against the applicants/accused

925. That non of the applied section are applicable to the case
of the applicant as per the facts and its ingredeince and as
such the case against the applicants/accused is that of further
inquiry.

[4]

evidence.

arguments.
AYAZ ALI GOPANG

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
AYAZ ALI GOPANG
Reg- No. HC 462/NWS
BENAZIRABAD
B. A. No: OF 2013.

4. Muneer alias Imdad son of Ali Hassan alias Allah
Bachayo Khoso Both confined in District Jail Shaheed
Benazirabad ………………………………. ..…
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 5/2013, P.S, 60th-Mile

OFFENCE U/S 324, 353, , 398, 399, 402,
PPC
BAIL APPLICATION

-: F A C T S :-

complainant, ASI Lal Bux Mari lodged his FIR at PS 60 th Mile
on 3-2-2014 , at about 2145 hours , alleging therein that he
along with his subordinate staff left the PS vide entry No 13
dated 3-2-2014 at about 18:30 hours , went for patrolling duty
within his beat after patrolling various places when they
reached at 60th Mile road leading to Chak No 3 Suhialo near
Haot Fakeer Mor Deh Chak No 10 Suhialo at about 20:30
hours, they saw on head light of the mobile , that 6 armed
persons were standing on the road , who were identified on
the head light of the mobile to be the Zameer alias Jameel son
of Hadi Bux Khoso Resident of Sadu Ja having KK, Ranjho
son of Khamiso having K Ali Gul Son of Muhammad
[2]
alias Nango , Ali Shafa alias Fakeer son of Nango, all Khoso
by caste all resident of Sadu Ja District N-Feroze ,. Imdad alias
Muneer alias Badur son of Ali Bux alias Allah Bachayo Khoso
originally R/O Sadu Ja District N-Feroze presently village
Padr near Kazi Ahmed and Asghar son of Ali Hassan Jamali
R/O Massar Jee Wah District N-Feroze who were having
DBBL Guns , who all signaled the complainant party to stop
by sensing the vehicle to be the private one, on which
complainant party stopped the mobile and alighted from it
and very tactfully encircled them by taking positions, on
which all the accused persons made sprite fires with the
intention to commit the murder of the complainant party and
police party also made firing in their defense and such firing
was continued for about 10 minutes but the accused persons
succeeded to run away by taking the advantage of the
darkness, the police party could not track the foot prints of the
accused due to darkness and then complainant came at PS
and where present FIR was registered.
After usual investigation the police of PS 60th Mile

challaned the case. The applicants/accused were arrested who
are in judicial custody hence the present first bail application
before this Honourable court on the following grounds .
-: G R O U N D S :-


933. That very identity of the applicants/accused on the

torch light in the
[3]
field at odd hours with their names and parentage is not free
from doubt, which is very week type evidence which requires
corroboration but the same is lacking which requires further
inquiry .
road and it is admitted that the applicants/ accused along
with others duly armed with lethal weapons were standing at
the road with the intention to commit offence, but no such
reported by any of the individual at PS and it is also strained
that all the accused have been shown armed wit lethal
prosecution case and the case against the applicants/accused

connected the applicant with the alleged offence.
936. That non of the applied section are applicable to the case
of the applicant as per the facts and its ingredeince and as
such the case against the applicants accused is that ,of further
inquiry.
937. That nothing incriminating has been secured from the

applicant which connected them with the commission of the
offence.
938. That All the PWs are police officials and are sub
ordinate of the complainant hence they are interested
witnesses.
evidence.
[4]


arguments.
AYAZ ALI GOPANG

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
AYAZ ALI GOPANG
Reg- No. HC 462/NWS

BENAZIRABAD
B. A. No: OF 2013.

6. Muneer alias Imdad son of Ali Hassan alias
Allah Bachayo Khoso Both confined in
District Jail Shaheed Benazirabad ……. ..…
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 398, 402, 324, 353, PPC
BAIL APPLICATION
-: F A C T S :-

complainant, AZSI Muhammad Javed Iqbal Rajput lodged his
FIR at PS Bandhi on behalf of the state on 26-1-2014 at about
02:30 hours, alleging therein that he along with his
subordinate staff left the PS vide entry No 16 dated 26-1-2014
at about 2415 hours , went for patrolling duty within his beat
after patrolling various places when they reached at Malak
Mehmood Mor, when at about 0115 hours they saw on head
light of the mobile , that five armed persons were standing on
the road with the intention to rob the vehicles passing on the
road , who were identified by PC Khalid
[2]
Hussain to be the Zameer alias Jameel son of Hadi Bux Khoso

Resident of Sadu Ja having KK, Muneer alias Imdad alias
Badur son of Ali Hassan alias Allah Bachayo Khosko Resident
of Sadu Ja, presently near Kazi Ahmed having DBBL gun ,
Ranjho son of Khamiso Khoso resident of Sadu Ja District N
Feroze having KK who all were involved inc rime NO 2 of
2014 under section 324, 353, 398 , 148, 149 PPC of PS Bandhi
and were required, Rab Nawaz alias Lalu son of Muhammad
Bux Dahri R/O Gulab Dahri Taluka Daur having repeater,
and Umar Hayat son of Mukhtiar Jatt R/O Village Ali
Muhammad Jatt Taluka Fiaz Gang District Khairpur having
pistol, who on seeing the government vehicle by sensing to be
the private vehicle, with the intention to rob them, they
signaled t o stop on which the complainant party very
tactfully stopped the vehicle and alighted from it and asked
them to stop on which all the accused persons on seeing the
police and Mobile, they decamped in Banana garden near by
the road by taking advantage of darkness. The complainant
party then tracked the foot prints of run away accused
persons, on the light of vehicle and torch and the police party
went behind them in Banana Garden to arrest the accused
persons but the foot prints of the culprits were missed in
Banana garden. The complainant then came at PS alongwith
staff and lodged present FIR.
After usual investigation the police of PS Bandhi ,

submitted the challan before the competent court the
applicant were arrested , in some other crime, who are in
judicial custody , hence this first bail application on behalf of
the applicants /accused before this Honourable Court on the
following grounds .
-: G R O U N D S :-
47.That the applicant/accused are innocent and had not

48.That in fact no such incident whatsoever stated in the FIR

was
[3]
complainant, just to show his efficiency otherwise, no such
incident was ever took place .
49.That very identity of the applicants/accused on the torch light

in the field at odd hours with their names and parentage is
not free from doubt, which is very week type evidence which
requires corroboration but the same is lacking which requires
further inquiry .
50.That falsehood of the case can bee verified from the facts that,
the alleged incident is said to have taken place at the road and
it is admitted that the applicant accused along with others
duly armed with lethal weapons were standing at the road
with the intention to rob the vehicles, which were passing on
the road, but no such incident ,of robbing on the alleged day
and time was ever reported and even otherwise no any
independent person has come forward to complain about the
robbery committed from him and it is also unbelievable that
the police had identified them, with respective weapons but
neither the police made any fire upon them nor from the side
of applicants/accused and others any fire was made upon the
police which itself creates doubt in prosecution case which
cuts the roots of the prosecution case and as such the case
against the applicants/accused has become of further
inquiry .
51.That no evidence in connection of applied sections 399 and

402 PPC has come on record which supports the FIR and as
such both the sections have been misapplied which requires
further inquiry .
52.That nothing incriminating has been secured from the
applicant which connected them with the commission of the
offence.
53.That All the PWs are police officials and are sub ordinate of
the complainant hence they are interested witnesses.

evidence.
[4]
55.That applicants/accused are ready to furnish solvent surety

AYAZ ALI GOPANG

APPLICANT/ACCUSED
CERTIFICATE

ADVOCATE
AYAZ ALI GOPANG
Reg- No. HC 462/NWS

BENAZIRABAD
B. A. No: OF 2013.
Abdul Hameed alias Shakti son of Ali Nawaz Brohi
Presently confined at District Jail Shaheed
Benazirabad ……………………………………...…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 395 PPC
BAIL APPLICATION

-: F A C T S :-

complainant Muhammad Ali son of Ahmed Ali R/O Village
Muhammad Hussain Brohi, lodged his FIR at PS Daur on 13-
12-2013 at about 17:30 hours, alleging therein that he is
residing at above mentioned address, and has held Kamdari
of Rais Pervez Dahri at his lands, the sons of the complainant
namely Shahzad, Imtiaz Ahmed, Neeman, are used to read in
Khadar School at Daur. On 28-11-2013 complainant came
there to take back to his house when they were coming from
Daur to their village , where the villager of the complainant
each Shahnawaz son of Muhammad Solangi, Ali Gohar son of
Chanyal Brohi arrived Daur city for their personal work and
they were coming to their village, the complainant was
driving the motorcycle and above villager were
[2]
coming behind of the complainant when complainant crossed

Daur road which runs through 60:Mile link road he reached at
land of choudhary Muhammad Afzal at about 2:00 PM the
complainant saw the five persons were standing at road
containing one motorcycle, to whom complainant identified
to three persons each namely Abdul Hameed alias Shakti son
of Ali Nawaz Brohi R/O village Walidad Brohi, Rahim Khan
son of Behram, Sikandar son of Behram, both by caste Brohi,
both R/O village Azam Burghari and two unknown accused
persons who were un-muffled faces, who can be identified if
seen again, all accused were armed with pistol who signaled
the complainant to stop the motorcycle, due to fear of the
weapons the complainant stopped the motorcycle, meantime
Abdul Hameed alias Shakti Brohi got down the applicant
from his motorcycle and he by boarding the motorcycle with
two unknown accused persons and Raheem Khan and
Sikandar they by boarding their motorcycle run away
towards western side, thereafter complainant narrated whole
facts with Shahnawaz and also narrated facts with Abdul
Qadir Dahri they went to father of the accused Raheem khan
and Sikandar Ali they narrated whole facts with him, who
admitted their guilty by stating that motorcycle was robbed
by persons of the Behram and they shall return the same but
they kept the complainant party on hollow hopes and dud
not return the motorcycle
After usual investigation the police of PS Daur arrested

the applicant/accused who is in judicial custody, hence
applicant/accused filed present bail application on the
following grounds .
-: G R O U N D S :-
57.That the applicant/accused are innocent and had not

58.That there is delay in lodging of the FIR for about 15 days,

as such false implication of the applicant/accused can not be
ruled out .
[3]

took place but complainant with malafide intention has
managed this false story, just to implicate the applicant and
other in this case, otherwise applicant accused is not
concerned with alleged story.

from the facts that when the complainant admitted that some
villagers named above were coming behind and they were
behind of some distances but having the such incident they
did not support the version of the case of the complainant,
which creates doubt in above story which makes the case of
the applicant for concession grant of bail .

taken place and place of Wardhat shown by the complainant
which is thickly populated place and superior number of the
passerby are running from Daur to Link Road 60 th Mile but
despite of that no such eye witnesses was made by the
complainant which is too clearly false story which makes on
the basis of concoction.

from the facts that three robbery were identified by the
complainant and two were unidentified by the complainants
such facts came on the record and indicates that complainant
was already in knowledge and he by taking benefit of unseen
area has shown identification parade of the applicant and
other just to implicated the applicant/accused in this case
otherwise applicant is not concerned with the alleged offence.
63.That further malafide on the part of the complainant can be

verified from the facts that complainant shown the five
robbery persons, they robbed the motorcycle and all were
armed with pistols and they were standing there without any
fear and at the time of robbery no any single firearm injury,
any single scratch, butt, sustained by the complainant party
from applicant accused which makes the whole case doubtful
un-understandable and implausible.
64.That the applicant/accused is respectable persons has

possessed good reputation his vicinity but complainant with
intention to disrepute his fame and reverence has implicated
him in this false case just to show his influence power.
[4]
65.That applicant accused is neither disparate nor previous

66.That no any guilty was admitted by the complainant nor they

are concerning with the same alleged offence but
complainant has find out technical method to implicate the
applicant and other in this case to drag before this
Honourable just to pressurize and implicate him.
67.That the section applied in the FIR is neither punishable more

then 10 years nor less then 4 years, whereas story narrated by
the complainant is ineffectual and discontented.

evidence.
69.That applicant is prepared to furnish solvent surety to the

ALI ASGHAR JAMALI

APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Asghar Ali son of Abdul Majeed Keerio

R/O village Esso Keerio Taluka Sakrand
District Shaheed Benazirabad presently
Confined in Sakrand Jail …………………………
Applicant/accused
VS
The state …………………………………………………………

Opponent

OFFENCE U/S 23 (i), A S-.A Act .
BAIL APPLICATION

-: F A C T S :-

ASI Sajid Hussain Arain lodged his FIR at PS Sakrand on 4-2-
2014 at about 10:00 hours, alleging therein that complainant
alongwith his subordinate PC Raj Muhammad Pali , PC Ayaz
Ali Soomro , during dressed armed with officials arms and
ammunitions started to interrogation of the applicant/
accused, who was arrested and under remand in police
custody, in crime No 15/2014 under section 398, 399, 402 , 324
PPC about the weapon which was used by the
applicant/accused in above offence, during the interrogation
who admitted the offence and ready to prepare to give the
pistol which was used in the said offence at the same time ,
complainant alongwith same staff in government vehicle
[2]
SP No 6870 driver PC Wajid Mahmood and alongwith
investigation Bag and applicant accused left the PS vide entry
No 05 dated 4-2-2014 at about 8:45 hours when at about 9:00
hours, reached at the Parlor of applicant/accused at village
Esso Keerio, where applicant/accused de-boarded and lead
the complainant party applicant/accused presented the pistol
of 30-bore before the complainant party, as same was lying in
the Big Iron Box and stated that at the time of offence it was
used by him and same is unlicensed, having possessed pistol
by the complainant party at that time same was unloaded and
found empty at that time pistol and magazine were sealed
there after applicant was arrested U/S 23-(i)A and came at PS
and registered present FIR hence this FIR.
After his arrest usual investigation was carried of the,

applicant/accused was arrested, who is in police custody
-: G R O U N D S :-

72.That the property has been foisted upon the

applicant/accused by the complainant party nothing but
showing efficiency .
73.That the at the time of recovery no independent person has

been shown as per FIR, even no any Mashirnama was
prepared at there as per contents of the FIR, which also make
one of further inquiry.
74.That the witnesses are subordinate of the complainant and
they are interested, hence there is no apprehension of
tampering with the evidence.
75.That there is delay of one hour in registration of FIR which

has not been explained plausibly by the complainant,
however the PS is only 5 KM away from the place of alleged
incident.
76.That the applicant accused is also granted the bail by this

Honourable Court in crime No 15/2014 dated 11-2-2014.
[3]
77.That there is violation of law without making the Mashirnama

alleged property has been sealed.

complainant
79.That nothing is to be recovered from the possession of

accused.
80.That the applicant/accused is not previous convict as per

instructions.
81.That the applicant accused is ready to submit surety if the

Honourable Court granted the Bail.
82.That the other grounds shall be urged at the time of

arguments.
APPLICANT/ACCUSED
CERTIFICATE
This is to certify that no bail application prior to this has

been filed on behalf of applicant/accused before this
Honourable Court or any other court in present case/crime.
Advocate for the applicant

BAHADUR ALI
MAHESA
R
Reg, No. 635/NWS

BENAZIRABAD
B. A. No: OF 2014.
Asghar Ali
VS
The State

Dadu
OFFENCE U/S 25-S.A Act .
BAIL APPLICATION

-: F A C T S :-

ASI Muhammad Umar lodged his FIR at PS A Section Dadu
on 5-2-2014 at about 2015 hours, alleging therein that
complainant is ASI at PS A Section Dadu, whereas in crime
No 22/2014 , under section 324, 353, 402, 399 PPC, of PS A
Section arrested the applicant/accused namely Kalu Lund,
due to unlicensed repeater by showing under section 25-SAA
in present of PW by making the Mashirnama also lodged the
present FIR.
After usual investigation applicant/accused was

arrested who is in police lockup at PS A Section Dadu, hence
[2]
-: G R O U N D S :-

84.That the repeater has been foisted upon the applicant/accused

whereas applicant is not concerned same alleged place of
incident and with the pistol which false story narrated by the
complainant is unbelievable and implausible.
taken place but complainant with malafide intention for the
ulterior reasons by showing his efficiency involved the
applicant/accused in this present case.
86.That no such incident whatsoever stated is taken place the

place of Wardaht is thickly populated area the passerby
superior number of the persons and vehicles runs round the
clock but complainant just to get help of falsification has
shown involvement of the applicant/accused in this present
case there is clearly contradiction of section 103 Cr PC.
87.That all the PWs cited in the FIR are police officials as well as
they are sweet obligor of the complainant hence they are
interested witness of the complainant
88.That no such incident whatsoever stated is ever took place but

actual facts are that applicant was unaware about the above
story which was made by the complainant whereas on 2-2-
2014 at about 3:00AM applicant was available at his house,
where police of PS A Section with SHO namely Akbar Channa
on two Police Mobiles and with one private Car they forcibly
entered house of the applicant/accused and they by seeing
the applicant severally beaten him and complainant with help
of police officials also beaten the ladies of the applicant and
dragged them meantime complainant by breaking the Iron
Box which was available in room of the applicant they took
out Rs 40,000/- cash and one Golden Leelam and two Mobile
Phones, Two torch Light and
[3]
they severally beaten the applicant and put into Mobile and
brought at PS
89.That no such incident whatsoever stated in FIR has ever taken

place but complainant with malafide intention has managed
false story, whereas.
90.That the complainant has falsely implicated the applicant by

foisting the repeater upon the applicant whereas the applicant
accused is falsely implicated with instance of Rias Naban
Khan Lund who is Big Zmaidnar of his locality and relating
with political parties as who was Ex-MPA in Dadu otherwise
no any incident whatsoever has ever been taken place whole
drama has been staged by the complainant with malafide
intention.

his vicinity but the altercation of landed property the
complainant and his Zamidar by joining hand with police has
implicated the applicant in false cases otherwise applicant is
innocent and is not pertaining with alleged offence.

complainant

APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2014.
Kalu Son of Nazar Muhammad Lund

R/O Village Qadir Dad Jamali Taluka Dadu
District Dadu now confined in police custody
At PS A Section Dadu ……………………………..…
.Applicant/accused
VS
The State ……………….……………………………..………………

Opponent

Dadu
OFFENCE U/S 25-S.A Act .
BAIL APPLICATION

-: F A C T S :-
ASI Muhammad Umar lodged his FIR at PS A Section Dadu
on 5-2-2014 at about 2015 hours, alleging therein that
complainant is ASI at PS A Section Dadu, whereas in crime
No 22/2014 , under section 324, 353, 402, 399 PPC, of PS A
Section arrested the applicant/accused namely Kalu Lund,
due to unlicensed repeater by showing under section 25-SAA
in present of PW by making the Mashirnama also lodged the
present FIR.

arrested who is in police lockup at PS A Section Dadu, hence
[2]
-: G R O U N D S :-

96.That the repeater has been foisted upon the applicant/accused


taken place but complainant with malafide intention for the
ulterior reasons by showing his efficiency involved the
98.That no such incident whatsoever stated is taken place the

place of Wardaht is thickly populated area the passerby
superior number of the persons and vehicles runs round the
clock but complainant just to get help of falsification has
shown involvement of the applicant/accused in this present
case there is clearly contradiction of section 103 Cr PC.
99.That all the PWs cited in the FIR are police officials as well as
100. That no such incident whatsoever stated is ever took

place but actual facts are that applicant was unaware about
the above story which was made by the complainant whereas
on 2-2-2014 at about 3:00AM applicant was available at his
house, where police of PS A Section with SHO namely Akbar
Channa on two Police Mobiles and with one private Car they
forcibly entered house of the applicant/accused and they by
seeing the applicant severally beaten him and complainant
with help of police officials also beaten the ladies of the
applicant and dragged them meantime complainant by
breaking the Iron Box which was available in room of the
applicant they took out Rs 40,000/- cash and one Golden
Leelam and two Mobile Phones, Two torch Light and
[3]
brought at PS
101. That no such incident whatsoever stated in FIR has ever

taken place but complainant with malafide intention has
managed false story, whereas.
102. That the complainant has falsely implicated the

applicant by foisting the repeater upon the applicant whereas
the applicant accused is falsely implicated with instance of
Rias Naban Khan Lund who is Big Zmaidnar of his locality
and relating with political parties as who was Ex-MPA in
Dadu otherwise no any incident whatsoever has ever been
taken place whole drama has been staged by the complainant

reputation in his vicinity but the altercation of landed
property the complainant and his Zamidar by joining hand
with police has implicated the applicant in false cases
otherwise applicant is innocent and is not pertaining with
alleged offence.

complainant

arguments.
106. That applicant is prepared to furnish solvent surety to


APPLICANT/ACCUSED
IN THE COURT OF SESSIONS JUDGE DADU
B. A. No: OF 2013.
Kalu Son of Nazar Muhammad Lund

R/O Village Qadir Dad Jamali Taluka Dadu
District Dadu now confined in police custody
At PS A Section Dadu ……………………………..…
.Applicant/accused
VS
The State ……………….……………………………..………………

Opponent
Crime No: 22/2014 , PS A Section

DADU
OFFENCE U/S 353, , 402, 399, 324,
PPC
BAIL APPLICATION

that this Honorable Court may be pleased to release him on bail in
and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant ASI

Muhammad Umar lodged his FIR at PS A Section Dadu on 5-2-2014
at about 2;000 hours , alleging therein that complainant alongwith
his subordinate staff left the PS with government ammunition on
government Mobile No SP 3590 alongwith driver HC Ghulam
Muhammad, for patrolling, under the entry No 25 dated 5-2-2014 at
about 18:00 hours, various places when they reached Mondar Link
Road Near OPF colony Dadu at about 19:00 hours the complainant
party saw on the light of Mobile that five persons containing the
weapons were present at OPF colony with intention to commit the
offence, the complainant got informed about police, the accused by
seeing he made straight fires upon the complainant party with
intent to commit their murder, the complainant party by taking
shelter they made straight fire in their defense, at about 19:05 hours
after closing the fires the complainant party very tactfully captured
to the two persons and three
[2]
persons who were identified each Zahid Solangi armed with

repeater, Talib, Ali Khan Mallah both armed with guns they run
away, the police recovered the weapon from the captured persons
the person containing repeater who disclosed his name Kalu Lund
and they unloaded the repeater which was empty, and person
armed with pistol who disclosed his name Shahnawaz the police
unloaded the pistol which was without magazine the after securing
the weapons the complainant inquired about the license of the
weapons they disclosed that same are unlicensed, and they
disclosed that absconder were same which were identified by the
complainant and further disclosed that they were standing there
with intention to commit the offence, due to not availability of the
private mashirs the PC Ali Bux and PC Abdul Hakeem were made
Mashirs of the place of incident, the police by securing the above
property and accused brought at PS and lodged present FIR
After usual investigation the Police of PS A Section Dadu arrested

the applicant/accused , who is in police lockup at PS A Section
Dadu, hence this Bail application on the following grounds
-: G R O U N D S :-
35.That the case against the applicant/ accused is false and
fabricated one he has been falsely implicated by the complainant
with malafide intention for the ulterior reason otherwise the
applicant is innocent .
36. That no such incident whatsoever stated is ever took place but
actual facts are that applicant was unaware about the above story
which was made by the complainant whereas on 2-2-2014 at
about 3:00AM applicant was available at his house, where police
of PS A Section with SHO namely Akbar Channa on two Police
Mobiles and with one private Car they forcibly entered house of
the applicant/accused and they by seeing the applicant severally
beaten him and complainant with help of police officials also
beaten the ladies of the applicant and dragged them meantime
complainant by breaking the Iron Box which was available in
room of the applicant they took out Rs 40,000/- cash and one
Golden Leelam and two Mobile Phones, Two torch Light and
brought at PS
[3]
37. That no such incident whatsoever stated in FIR has ever taken
place but complainant with malafide intention has managed false
story, whereas.
38.That on the malafide part of the complainant can be verified that

during the encounter no any empty recovered by the
complainant now they shown figures of the empty and it is
worth to mention that when firing made by the both sides where
no any bullets or firearm injury sustained by either side nor the
mobile of the police damaged, whereas whole facts are false and
fabricated one, which are unreasonable and implausible.
39.That all the PWs are police official hence they are interested
40.That the applicant accused is falsely implicated with instance of

Rias Naban Khan Lund who is Big Zmaidnar of his locality and
relating with political parties as who was Ex-MPA in Dadu
otherwise no any incident whatsoever has ever been taken place
whole drama has been staged by the complainant with malafide
intention.
41.That the applicant/accused has possessed good reputation in his

vicinity but the altercation of landed property the complainant
and his Zamidar by joining hand with police has implicated the
applicant in false cases otherwise applicant is innocent and is not
pertaining with alleged offence.
42.That the place of incident is thickly populated are and place of

incident busy one about 24 hours but the complainant has no left
lack to making false story .
43.That no any overt act, injury, part or assigned to the applicant

whereas whole drama has been staged by the complainant
otherwise applicant is innocent
44.That the applicant has possessed good reputation in their vicinity
[4]
but complainant with malafide intention to down their fame

reverence has implicated him in this false case otherwise no
any sort of incident was ever took place.
as all the witnesses cited in the FIR are police official as they are
interested witnesses.
46.That there is no apprehension of absconsion of the applicant as

he is ready to furnish his solvent surety to the satisfaction to this
Honourable court.

APPLICANT/ACCUSED
IN THE COURT CIVIL JUDGE JUDICIAL MAGISTRATE-III
NAWABSHAH
B. A. No: OF 2014
1. Inayatullah son Gul Hassan Zahari

2. Gul Hassan son of Allah Rakhio Zahari
Both confined in District Jail Shaheed
Benazirabad ………………………….
……………...Applicants/accused
VS
The State ………………………..………………….……………

Opponent
Crime No: 104/2013 , P.S Taluka

Nawabshah
OFFENCE U/S 506/2, 504 PPC.
BAIL APPLICATION
It is prayed on behalf of the applicants/accused ,

that this Honorable Court may be pleased to release them on bail
in the above case/crime on the consideration of the fallowing facts
and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant Irfan

lodged his FIR at PS Taluka Nawabshah, on 20-11-2013 at about
20:30 hours, alleging therein that he is labourer and his dispute is
going on with his nephew Allah Bux over a plot and such case is
pending in court, his nephew Allah Bux and his friends Inayatullah
Brohi, Noor Hassan Brohi, Ashique Solangi from time to time used
to say to the complainant to with draw from the said case otherwise
they would kill him the complainant approached to the Neckmard
of Inayatullah Brohi and his own Neckmard. On 3-11-2013 in the
evening the complainant was standing in front of his house when at
5:00 PM he saw , Inayatullah
[2]
Brohi, Noor Hassan Brohi, Ashique Solangi and two unknown

persons having pistols came there and on arrival abused the
complainant and asked him that they have repeatedly asked him to
withdraw from the case but the complainant was not listening and
have even complained to their neckmards and today they would
not spare the complainant and would kill him, they raised cries
their weapons and extended murderous threats to the complainant
and caused kicks and fists blows to the complainant and made him
to fell on the ground and in the meanwhile on the cries of the
complainant Ali Raza Solangi, Tanwakal Ali Mangsi came running
while raising alarms, who beseeched the accused persons and
rescued the complainant all the accused asked that today he has
been saved and incase he did not withdraw from the case he would
be killed and they went away while extending murderous threats ,
the complainant then narrated such facts to his elders who asked
that they would get faisla for him but ultimately the accused
refused and threatened that they would not spare the complainant
the complainant then went and lodged his FIR.
The police during the course of investigation, the applicants

were arrested they are in judicial custody hence this application for
bail on the following grounds.
-: G R O U N D S :-
1. That the case against the applicants/accused is false and

fabricated and arranged one.
2. That the story narrated ion the FIR is false fabricated one and is
neither plausible nor believebale.
3. That there is inordinate delay of more then 17 days in lodging
the FIR and such a long delay has not been explained at all which
goes to show that the case has been lodged after deliberation.
4. That no specific role, part, overt act or specific role has been
attributed to the applicants accused and others, the allegations

are general in nature.
[3]
place but whole drama has been staged by the complainant, by

suppressing the actual facts, the actual facts of the case that
complainant wants to dispossess from the land to the
applicants/accused by leveling allegation and also with dint of
force has roped the applicants/accused on the false assertions
just to occupy the land by pressuring the applicants/accused
otherwise no any activities has been raised by the
applicants/accused as they are not pertaining with the above
case.
6. That the complainant of this case is political for which applicant
got ordered for legal protection such copy of Protection

application is attached herewith
7. That in fact no such incident has ever taken place and the whole
drama has been staged by the complainant for ulterior reasons

due to grudge and enmity over land and the present FIR is
nothing but an attempt to black mail and harass the
applicants/accused to compel him to come to the unwarranted
demands of the complainant and concerned facts by the
complainant pertinent to the case just to pressurize the
applicants while he can vacant his land premises.
8. That the locality where the alleged incident is said to have taken
place is densely populated where peoples of different caste live

move about round the clock but strangely none has been cited as
a witness.
9. That the dispute if any between the parties is of civil nature but
complainant malafidly converted the same into present FIR just

to achieve his ill designed aims.
10. That except the solitary words of the complainant and his kith
and kin there is absolutely nothing to connect the

applicants/accused or to show that the incident as alleged has
ever taken place.
11. That the sections applied in the FIR doesn’t fall within
12. That all the PWs are set up persons of the complainant and are
closely related and connected with the complainant.

[4]

applicants/accused or tampering with the evidence.
14. That the applicants/accused are ready to furnish their solvent
surety to satisfaction of this Honourable court.
15. That other ground will be urged at the time of hearing with
permission of this Honourable.
[ZULFIQAR ALI DAHRI ]

APPLICANTS/ACCUSED
IN THE COURT CIVIL JUDGE JUDICIAL MAGISTRATE-II
NAWABSHAH
B. A. No: OF 2014
Luqman alias Qurban son of Lal Bux alias Wahid Bux

Presently confined in Central Prison
Hyderabad …………..
……………………………....Applicant/accused
VS
The State ………………………..………………….……………

Opponent
Crime No: 189 /2012, P.S A Section

Nawabshah
OFFENCE U/S 13-DAO.
BAIL APPLICATION

and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant SIP

Muhammad Iqbal Wassan of PS A Section Nawabshah lodged his
FIR at PS A Section Nawabshah on 15-9-2012 at about 10:15 hours,
alleging therein that , he alongwith his subordinate staff containing
the government ammunition on government vehicle No SP 6305
alongwith driver Abdul Razaque, under the entry No 39 dated 15-9-
2012 departed for patrolling various places when they reached Kazi
Ahmed Mor, wherefrom they got spy information that one required
accused person in crime No 179/2012 and 173/2012, of PS A
Section, that who is standing near Link Road Kazi Ahmed near the
stadium containing the Chars and unlicensed pistol, at about 8:00
hours complainant party reached towards the pointed place and
saw the persons was standing near the
[2]
stadium who by seeing the police mobile tried to run away, but
complainant party with tactfully by getting down their vehicle
captured him due to non availability of the private masher the PC
Muhammad Juman and Habibullah were made Mashir of the place
e of Wardhat, the police also inquired about his name to be the
Luqman alias Qurban son of Lal Bux alias Wahid Bux Machi R/O
Keerio 75 Mori Taluka Daur, on the body searching the police
secured little and big piece of Chars and one pistol which was
recovered from his side of Shalwar and secured Rs 100/- from front
pocket of the accused, the pieces of chars were calculated which
were 1130 Grams, to which two pieces of Chars were sealed for
chemical analysis, and 1000 pieces of chars were sealed separately
the police party unloaded the pistol from its magazine the police
secured 3 live bullets, whereas above accused disclosed that he used
to sell out chars by professionally therefore police arrested him in
above case crime and brought the accused and recovered property
at PS where FIR was lodged.
The after registering of the FIR the applicant was arrested,

hence the applicant/accused is in judicial custody , hence the
applicant filed present bail application before this Honourable
Court on the following grounds.
-: G R O U N D S :-
16. That the applicant/accused is innocent he has committed no
offence as alleged and he has been falsely implicated in the

present case, with malafide intention for the ulterior reasons,
otherwise he has nothing to do with the alleged offence.
ever took place but the complainant of this case with malafide
intention just to show his efficiency has managed a false case by
managing a false story, the reality related with applicant that he
is not linked with liquid which has been foisted upon the
applicant by police , due to drag the applicant and to get defame
him in his vicinity and factual point of the case is that place of
Wardaht is thickly populated and round the clock peoples and
transport are running there, such road is in running condition
and superior number of the peoples are round
[3]
the clock, how it can also be possible to sale out the liquid within
heart portion of the city despite of illegal method used in the
commission of the offence of the complainant that no any
independence witnesses has been associated at the place of the
Wardhat and there is clearly violation of section 103 Cr PC,
therefore it is indicated from the facts of the case that whole story
is made on the basis of concoction by the complainant.
18. That prior of this FIR the brother of the applicant/accused has
been implicated by the police in same sections just to implicate

the applicant and his other family members otherwise
applicant/accused is innocent and has not committed alleged
offence.
19. That the applicant/accused is not hardened criminal nor
previous convicted as per instruction, and he has possessed good

reputation in vicinity due to down the fame and reverence of the
applicant/accused the complainant have made false and
fabricated story by showing the liquid etc. otherwise applicant is
not concerned with the alleged offence.
20. That all the PWs are police officials and are subordinate of the
21. That there is no apprehension of the tempering with the evidence
as all the PWs are police officials.
22. That there is no apprehension of the absconsion of the applicant
accused for which he is ready to furnish his solvent surety to the

satisfaction this honorable court.
23. That other ground will be urged at the time of hearing with
permission of this Honourable.
APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Asif Ali son of Muhammad Anwar

Chandio presently confined in Nara Jail
Hyderabad ……………………………………………Applicant
The State ………………………………………………Opponent
Crime No: 180/2013, P.S, Kazi ahmed

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
BAIL APPLICATION

applicant/accused , above named, that this Honorable Court
may be pleased to release him on bail in the above
grounds:-
-: F A C T S :-

complainant Inspector/SHO Ghulam Hussain Dahri of PS
Kazi Ahmed lodged his FIR at PS Kazi Ahmed on 27-8-2013 at
about 14:00 hours alleging therein that he alongwith his
subordinate staff left the PS vide entry No 3 dated 26-8-2013 at
about 08:45 Hours, and went for patrolling duty within his
beat, during the patrolling when they reached at Sarkari
KHooh they received spy information that Mst Satara
daughter of Muhammad Anwar Chandio had left her house
and had gone with Waheed Kalaoi and she has been got
returned through brothery level and today her brothers
Muhammad Sharif and others are planning to murder her, the
complainant alongwith his subordinate staff proceeded
towards the pointed place and when at about 1000 hours they
reached common street of village Anwar Chandio they saw
that
[2]
each Muhammad Sharif with repeater, Asif Ali the applicant

accused armed with repeater,. Hanif Chandio armed with
pistol, all three sons of Anwar Chandio were coming while
dragging one girl in the street and one women was coming
while running behind the said girl by saying that they may
not kill his daughter Sittara, meanwhile all the three accused
on seeing the police party made firing with their respective
weapons and killed her in the meanwhile the accused Haji
Sikandar Hidayatullah both sons of Nizam Din Chandio,
Manthar son of Haji Sikandar Chandio were also came out
from their houses who all made straight fires upon the Mst
Umeeda alias Porhi wife of Anwar Chandio and killed her
and than al the accused persons decamped towards the sugar
cane crop, the complainant party tried to capture them but
they succeeded to run away towards the crop after departure
of the accused persons the complainant party went over both
the ladies and found that both were having firearm injuries
on their chest abdomen and other part of their body and were
bleeding and both were died away. The complainant then
called ASI Muhammad Allam Kaliyar from PP Nawab Wali
Muhammad and both dead body were shifted for postmortem
through ASI Muhammad Allam Kaliyar and complainant
alongwith his staff went behind the accused persons, due to
disturbance law and ,order situation and due to enmity in
between the Chandio and Kaloi caste the complainant
remained there to maintain law and order situation and they
asked to legal heirs of the deceased of Chandio community to
register the FIR but no one appeared for lodging the FIR, the
complainant than lodged the FIR on behalf of the state by
showing himself to be the complainant.

investigation the police arrested the applicant/accused who is
in jail and after usual investigation the challaned was
submitted before the competent court of law hence this bail
[3]
-: G R O U N D S :-

committed the alleged offence but he has been falsely
ulterior reasons.
108. That preliminary investigation in the above case has

been conducted before lodging the FIR which his clear
violation of the section 154 Cr PC and as such the case against
the applicant accused has become of further inquiry .
109. That no specific role part , or any ,overt act is assigned

to either ,of the accused including the applicant and there are
general allegation of making fires upon the de eased Sittara
and it is yet to be determined at the time of trial that whose
fire was hit to the deceased and whose fire was proved fatal to
caused the death of deceased which required further inquiry
which makes the entitle to the applicant for the concession of
the bail .
110. That co accused Muhammad Hanif has been granted on

bail by this Honourable Court and all other co accused has
been admitted on pre arrest bail by the Honourable High
Court of Sindh Circuit Bench Hyderabad and as such under
the rule of consistency the applicant is also entitle for the same
concession .
111. That since the case is compoundable one and all the
legal heirs of the deceased Sitara and Umeeda alias Porhi has
sworn affidavits before this Honourable Court in which they
have categorically stated that they have patched up wit all the
accused persons nominated in the FIR including the
applicant/accused and they have no objection if the applicant
accused is granted bail by this Honourable court because they
are intending to file compromise application before this
Honourable Court and it would be possible for them if the
applicant is granted bail by this Honourable Court .
112. That admittedly the incident was took place in the

village but not a single independent person was cited to be the
eye witness of the incident which itself creates doubt in the
prosecution story.
[4]
113. That in fact the incident is unseen one and non of the
PW who are police officials have seen the actual incident but
after happening of the murder of both deceased when they
came and saw the deceased persons then they lodged the FIR
against the all the male members of the family of applicant
just to paralyzed them so that no one should left who pursue
the case with malafide intention for the ulterior reasons .
114. That the case has been challaned and the applicant
accused is not more required to the police for the further
investigation.

evidence.


arguments.
AYAZ ALI GOPANG

APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Asif Ali … ………………………………………………Applicant
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Roshan Ali son of Muhammad Anwar Chandio Muslim

Adult R/O Village Muhammad Anwar Chandio Taluka Kazi
ahmed District Shaheed Benazirabad do hereby state on oath as
under:-
6. That I am the real son of the deceased Umeeda alias Porhi widow
of the Muhammad Anwar Chandio and brother of deceased
Sitara.

the above case including the applicant accused as over
and the applicant has got clear his position on holy Quran and he
has became proved innocent so I have no objection if the
applicant accused is granted on bail. By this Honourable Court
and we are intending to file compromise application before this
Honourable Court for which it would be facilitate to us if the
applicant is granted on bail by this Honourable Court.

Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Muhammad Sharif son of Muhammad Anwar, Muslim

under:-
1. That I am the son of the deceased Umeeda alias Porhi widow of

the Muhammad Anwar Chandio and brother of deceased Sitara.



Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Muhammad Haneef son of Muhammad Anwar , Muslim

under:-
1. That I am son of the deceased Umeeda alias Porhi widow of the

Muhammad Anwar Chandio and brother of deceased Sitara.


Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Ashraf Khatoon Wife of Muhammad Anwar ,
Muslim Adult R/O Village Muhammad Anwar Chandio Taluka
Kazi ahmed District Shaheed Benazirabad do hereby state on
oath as under:-
1. That I am widow of Muhammad Anwar Chandio and step

mother of the deceased Sitara.



Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Rubeena Wife of Hidayatullah, Muslim Adult R/O

Village Muhammad Anwar Chandio Taluka Kazi ahmed District
Shaheed Benazirabad do hereby state on oath as under:-
1. That I am daughter of the deceased Umeeda and sister of

deceased Sitara.



Advocate

BENAZIRABAD
B. A. No: OF 2013.

VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Naheeda daughter of Muhammad Anwar, Muslim

under:-

deceased Sitara.



Advocate
BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Yasmeen Wife of Sardar Ali , Muslim Adult R/O


deceased Sitara.




Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Hazooran Wife of Asghar Ali , Muslim Adult R/O


deceased Sitara.


Advocate

BENAZIRABAD
B. A. No: OF 2013.
VS

OFFENCE U/S 302, 311, 147 , 148, 149
PPC
AFFIDAVIT
I Mst Seema Wife of Zahid Ali, Muslim Adult R/O Village

Muhammad Anwar Chandio Taluka Kazi ahmed District

deceased Sitara.



Advocate

BENAZIRABAD
B. A. No: OF 2013.
Abdul Hameed alias Shakti son of Ali Nawaz Brohi

Presently confined at District Jail Shaheed
Benazirabad ……………………………………...…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 395 PPC
BAIL APPLICATION

-: F A C T S :-

complainant Muhammad Ali son of Ahmed Ali R/O Village
Muhammad Hussain Brohi, lodged his FIR at PS Daur on 13-
12-2013 at about 17:30 hours, alleging therein that he is
residing at above mentioned address, and has held Kamdari
of Rais Pervez Dahri at his lands, the sons of the complainant
namely Shahzad, Imtiaz Ahmed, Neeman, are used to read in
Khadar School at Daur. On 28-11-2013 complainant came
there to take back to his house when they were coming from
Daur to their village , where the villager of the complainant
each Shahnawaz son of Muhammad Solangi, Ali Gohar son of
Chanyal Brohi arrived Daur city for their personal work and
they were coming to their village, the complainant was
driving the motorcycle and above villager were
[2]
coming behind of the complainant when complainant crossed

Daur road which runs through 60:Mile link road he reached at
land of choudhary Muhammad Afzal at about 2:00 PM the
complainant saw the five persons were standing at road
containing one motorcycle, to whom complainant identified
to three persons each namely Abdul Hameed alias Shakti son
of Ali Nawaz Brohi R/O village Walidad Brohi, Rahim Khan
son of Behram, Sikandar son of Behram, both by caste Brohi,
both R/O village Azam Burghari and two unknown accused
persons who were un-muffled faces, who can be identified if
seen again, all accused were armed with pistol who signaled
the complainant to stop the motorcycle, due to fear of the
weapons the complainant stopped the motorcycle, meantime
Abdul Hameed alias Shakti Brohi got down the applicant
from his motorcycle and he by boarding the motorcycle with
two unknown accused persons and Raheem Khan and
Sikandar they by boarding their motorcycle run away
towards western side, thereafter complainant narrated whole
facts with Shahnawaz and also narrated facts with Abdul
Qadir Dahri they went to father of the accused Raheem khan
and Sikandar Ali they narrated whole facts with him, who
admitted their guilty by stating that motorcycle was robbed
by persons of the Behram and they shall return the same but
they kept the complainant party on hollow hopes and dud
not return the motorcycle
After usual investigation the police of PS Daur arrested

the applicant/accused who is in judicial custody, hence
applicant/accused filed present bail application on the
following grounds .
-: G R O U N D S :-

119. That there is delay in lodging of the FIR for about 15

days, without any plausible explanation which goes to show
that the same has been lodged after deliberation and
applicant/accused can not be ruled out .
[3]
120. That no such incident whatsoever stated in the FIR is

ever took place but complainant with malafide intention has
managed this false story, just to implicate the applicant and
other in this case, otherwise applicant accused is not
concerned with alleged story.

verified from the facts that when the complainant admitted
that some villagers named above were coming behind and
they were behind of some distances but having the such
incident they did not support the version of the case of the
complainant, which creates doubt in above story which makes
the case of the applicant for concession grant of bail .

ever taken place and place of Wardhat shown by the
complainant which is thickly populated place and superior
number of the passerby are running fro Daur to Link Road
60th Mile but despite of that no such eye witnesses was made
by the complainant which is too clearly false story which
makes on the basis of concoction.

verified from the facts that three robbery were identified by
the complainant and two were unidentified by the
complainants such facts came on the record and indicates that
complainant was already in knowledge and he by taking
benefit of unseen area has shown identification parade of the
applicant and other just to implicated the applicant/accused
in this case otherwise applicant is not concerned with the
alleged offence.
be verified from the facts that complainant shown the five
robbery persons, they robbed the motorcycle and all were
armed with pistols and they were standing there without any
fear and at the time of robbery no any single firearm injury,
any single scratch, butt, sustained by the complainant party
from applicant accused which makes the whole case doubtful
un-understandable and implausible.
125. That the applicant/accused is respectable persons has

possessed good reputation his vicinity but complainant with
intention to disrepute his fame and reverence has implicated
him in this false case just to show his influence power.
[4]
126. That applicant accused is neither disparate nor previous

127. That no any guilty was admitted by the complainant nor

they are concerning with the same alleged offence but
complainant has find out technical method to implicate the
applicant and other in this case to drag before this
Honourable just to pressurize and implicate him.
128. That the section applied in the FIR is neither punishable

more then 10 years nor less then 4 years, whereas story
narrated by the complainant is ineffectual and discontented.

evidence.

arguments.
ALI ASGHAR JAMALI

APPLICANT/ACCUSED
2ND Bail Application

IN THE COURT OF 2nd ADDITIONAL SESSION JUDGE
SHAHEED BENAZIRABAD
B. A. No: OF 2013.
Muhammad Umar alias Roomi son of Siddique Khanzado

R/O Khanzada Mohalla Sakrand now confined
In Sub-Jail Sakrand …………………………………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 324, PPC, 337-A(i) (iv)
Q.
BAIL APPLICATION

and grounds:-
-: F A C T S :-

Rehana Zardar Khan lodged his FIR at PS Sakrand on 26-6-2013 at
about 12:00 hours, alleging therein that complainant is by
profession General Secretary of Women Development Organization
at Sakrand and complainant solemnized Nikah with one
Muhammad Umar alias Roomi Khanzada to whom tow children
son and daughter were born from him, about one and half year ago
due to matrimonial affairs complainant got divorce from accused
from competent court of law thereafter complainant used to live
with mother of the accused at their home , now recently she died
some four days ago, whereas accused Muhammad Umar alias
Roomi used to extend threats that he did not allow to the
complainant to live in house of Muhammad Umar, and also
threatened that if the complainant used to live in house then he
would not spare the complainant. On 11-6-2013 the complainant
was present with her children at about 8:00Am the present accused
Muhammad Umar alias
[2]
Roomi knocked the door of the room, the complainant saw

that present accused standing outside of the door armed with
hatchet on seeing the complainant the accused threatened that
he will not spare today so present applicant caused hatchet
blows on head of the complainant and right side of her
shoulder due to blows on different parts of the body the blood
was oozing, meantime complainant made cries where on the
cries one Rakhsha driver and brother of the complainant
attracted there and rescued the complainant, meantime
complainant immediately went at PS and got letter for
treatment thereafter complainant got shifted at PMCH
Nawabshah after getting free complainant came at PS and
lodged present FIR.
After usual investigation the case has been challaned

and applicant was arrested who is in Sub Jail Sakrand. The 1 st
Bail Application was rejected by this Honourable Court now
2nd Bail application is sought on medical grounds. Hence this
-: G R O U N D S :-
48.That the applicant/accused is innocent and had not committed

the alleged offence.
49.That there is inordinate delay in lodging of the FIR more then 15

days without any plausible explanation which goes to show that
the same has been lodged after deliberation and consultation as
such false implication of the applicant in present case can not be
ruled out.
50.That no such incident whets over stated in the FIR is ever took
with core connivance of her brother actual facts are that
complainant is lady of define nature and is groom type due to
matrimonial affairs she used to pressurize the applicant mere by
applying role of her brother complainant made present story by
alleging baseless assertions.
[3]
51.That as per the FIR the contents of the complainant are that due
to matrimonial affairs she got divorce from the
applicant/accused and now the complainant is willing to
occupy the house of the
applicant/accused with dint of force and with core connivance

of her brother in fact no such type of incident was ever taken
place whole story is managed one by the complainant just to
pressurize the applicant/accused and to occupying the house of
52.That 337-A(i) is bailable and compoundable however section 324

and section 337-(iv) was misapplied which are not attracting to
present case there is matter occupying the house of the
applicant/accused and to pressurize him otherwise applicant is
not concerned with alleged offence .
53.That the complainant is supported by political person and with
influence of her post as General Secretary of Women
Development she showed her efficiency to implicate the
applicant/accused in present case.
54.That the applicant accused is seriously ill and such proposal of

treatment also proposed by PMCH Nawabshah through Sub Jail
Sakrand and there is critical condition of the accused and his
treatment is necessary and there is no further treatment available
at PMCH same was referred for Karachi hospital for further
treatment hence this bail application.
55.That all the PWs are setup persons as well as they are interested

[4]


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
1. Younis son of Khan Muhammad Brohi

2. Raoof son of Karim Bux Brohi
3. Muhammad Ayoob son of Ghulam Qadir Brohi
All
…...… .Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 324 Q, 114, 34 PPC
BAIL APPLICATION

-: F A C T S :-
Khuda Bux son of Ghulam Asghar Unar lodged his FIR at PS
A Section Nawabshah, on 1-12-2013 at about 23:30 hours,
alleging therein that , complainant is residing at above
mentioned address, the complainant is regional Officer in
National Bank at Sukkur, namely Badaur Ul Nissa D/O
Muhammad Mithal is cousin of complainant, she is doing
house job in Nawabshah Hospital, whose Nikah has
solemnized with Imdadullah who is brother of the
complainant, today complainant departed from Sukkur to
Hyderabad, on way at Moro city the complainant stayed to
his
[2]
friend Muhammad Siddique with purpose to take lunch,

wherefrom complainant informed to his cousin Badur Ul
Nissa by way of phone that complainant is going to
Hyderabad, and further complainant stated they at right time
he was available at Moro city with his friend, where she
invited to complainant to come at Nawabshah city, we shall
got Hyderabad in gathering, thereafter complainant
alongwith his friend Muhammad Siddique at sunset time
reached at Nawabshah city, where they met with his cousin
Badur Ul Nissa Unar, where she invited them to take dinner
after taking the dinner then they shall got to Hyderabad,
thereafter complainant his friend and his cousin went to
Gyme Khana Hotel where they took the dinner after taking
the dinner the cousin of the complainant told to complainant
her friend namely Naseem is available in room No 204 in
gyme Khana Hotel after meeting with her then they shall
depart for Hyderabad , at about 10:15 , complainant and his
cousin Dr, Badur Ul Nissa went to room No 204 to meet with
her friend, that time friend of the complainant Muhammad
Siddique was standing at outside, when complainant entered
into room where he saw that unknown person of the
complainant each Ashraf son of Khadim Hussain Bhatti R/O
Pir Jo Goth, District Khairpur, Najeebullah son of Sanaullah
Bhatti, R/O Village Pir Hajjana Shah, District Khairpur they
were available there, meantime Dr, Badur Ul Nissa said that
she will consummate the marriage with Ashraf Bhatti, and Dr,
Badur Nissa abetted to Ashraf Bhatti and Najeeb Bhatti to
kill the complainant and not spare him, meantime Ashraf
Bhati attempt to kill him with knife with intention to kill the
complainant, the complainant saved himself, and complainant
received knife injury on his right hand skin and Najeebullah
alongwith his cousin Badur Ul Nissa by falling down the
complainant on bed they tied the hands and foot of the
complainant and strangulated, where complainant raised cries
of murder murder, meantime on the cries of the complainant
the friend of the complainant and other Hotel barrier came
there, they accused person by seeing the above peoples they
skipped away, thereafter complainant came at PS and lodged
present FIR.

Nawabshah arrested the applicant/accused who is in police
[3]

-: G R O U N D S :-

133. That there is delay in lodging of the FIR 1 and half

hours without any plausible explanation which goes to show

with alleged story.
135. That there is no any eye witness when the applicant

attempted to cause the applicant by knife but complainant has
no received any single injury , which makes the creates in
above story otherwise the applicant is innocent.
136. That no any substantial evidence or record is attributing

to the applicant accused but complainant falsely implicated
the applicant in this present case otherwise whole story has
been made on basis of concoctions.
137. That section 324 PPC is not attributing to the

applicant /accused which is misapplied whereas the role of
the complainant is attributing to section 511 PPC but no any
plausible fact is connecting with the applicant otherwise
whole drama has been managed by the complainant due to
matrimonial affairs.
138. That the section applied in the FIR doesn’t fall within
139. That there are general allegation against the all accused
and no overt act has been assigned to the applicant accused.
[4]
140. That all the PWs cited in the FIR are sweet obligor of
the complainant hence they are interested witnesses of the
complainant

complainant

arguments.


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Najeebullah son of Sanaullah Bhatti

Presently confined at PS A Section
Nawabshah ………………………………...… .Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
BAIL APPLICATION

-: F A C T S :-

his
[2]

present FIR.

[3]

-: G R O U N D S :-



with alleged story.



[4]
complainant
complainant

arguments.


APPLICANT/ACCUSED
MAGSITRATE-II NAWABSHAH
B. A. No: OF 2013.
1. Ghulam Qadir son of Abdullah Brohi

2. Ahmed Ali son of Ghulam Qadir
3. Hakim Ali son of Ghulam Qadir
Presently confined in Police Lockup
At Balu Ja Kuba ………………………...…
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 29/2013 P.S, Balu Ja Kuba

OFFENCE U/S 506/2, 504. 337A(i),
L(ii), H(ii) Q 34 PPC
BAIL APPLICATION

pleased to release them on bail in the above case/crime on
-: F A C T S :-

Nabi Bux son of Abdul Hakeem Brohi lodged his FIR at PS
Balu Ja kuba on 2-12-2013 at about 11:30 hours, alleging
therein that complainants is residing at above mentioned
address, the accused Ghulam Qadir is cousin of the
complainant, who used to reside the alongwith his sons at
village of the complainant, who has belongs with loafer
persons, to whom complainant request to mend his way it is
not well for villager, on which they annoyed with
complainant. On 27-11-2013 the accused persons fought with
[2]
complainant, in which brother of the complainant Rasool Bux

sustained and on different part of the bodies sustained serious
injuries and Mst Souz Pari sustained injuries on her right side
of arm and other part of the body, such NC is already
registered against the accused persons, and complainant got
referred to injured at hospital they are under treatment, today
complainant Rasool Bux brother of the complainant were
available at their Otaq at about 8:00 at morning time he saw
the Ghulam Qadir, Hakim Ali, Ahmed Ali, Ahsan Ali, they
armed with lathees came there the Ghulam Qadir started
abuses to the complainant told that complainant have nothing
well today they will not spare them, by saying so the accused
persons straight their weapons due to fear of weapons the
complainant party remained silent , meantime Ahmed Ali and
Ahsan Ali caused kicks and fists blows to the complainant
which complainant sustained on his diffident part of the
bodies, where complainant party raised cries on the cries of
the complainant the villager attracted there, the accused
persons by seeing the villager they run away by issuing aerial
firing and threatened that if the complainant party did not
come on their terms then they will come again and not spare
the complainant party, then complainant party came at PS
and lodged the present FIR.
After usual investigation the police of PS Balu Ja Kuba

arrested the applicants/accused who are in police custody,
hence applicants/accused filed present bail application,
before this Honourable Court, on the following grounds .
-: G R O U N D S :-

157. That there is delay in lodging of the FIR about 3 hours

as such false implication of the applicants/accused can not be
ruled out .
[3]

with alleged story.
159. That complainant has no sustained any injuries from the

applicants/accused but complainant just to show his
influence has suppressed actual fact and to drag the
applicants /accused have made false story on basis of
concoction, otherwise applicants/accused are not concerned
with alleged story.
160. That the complainant shown the applicants/accused

armed with deadly weapons but at the time of fight no any
single injuries was sustained either side which creates doubt
in above story which makes the applicant entitle for bail.
161. That the section applied in the FIR are bailable except
the section 506/2 which too doesn’t fall with the prohibitory
complainant

complainant

arguments.
165. That applicants are prepared to furnish solvent surety to


APPLICANTS/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Najeebullah son of Sanaullah Bhatti

Presently confined at PS A Section
Nawabshah ………………………………...… .Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
BAIL APPLICATION

-: F A C T S :-
his
[2]

present FIR.

[3]

-: G R O U N D S :-



with alleged story.



[4]
complainant

complainant

arguments.


APPLICANT/ACCUSED
3rd BAIL APPLICATION
IN THE COURT OF SPECIAL JUDGE ANTI TERRORISM
COURT SHAHEED BENAZIRABAD
B. A. No: OF 2013.
3. Beg Muhammad son of Yar Muhammad Rajper

R/O Village kareem Bux Rajper District Khairpur Mirs.
4. Mumtaz alias Bhooral Shah S/O Ghulam Shah

R/O Rato Dero District Larkana
5. Ghulam Fareed son of Mithal Soomro

R/O Gharhi Yaseen Shikarpur
6. Mashooq Ali Son of Allah Dino Babar

R/O Hishnat Abad District
Jacombabad ……………………………..………
.Applicants/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 65 /2013 , PS PS Sakrand

OFFENCE U/S 364, 365,A 109 PPC
6/7 ATA
Cr,BAIL APPLICATION
UNDER SECTION 21-D of ATA 1997, R/W S-497, Cr.P.C.
It is prayed on behalf of the applicants/accused ,

that this Honorable Court may be pleased to release them on bail in
and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant Talib

Hussain son of Amanat Ali Veesar got registered his FIR at PS
Sakrand on 8-6-2013 at about 16:30 hours, alleging therein I
contractor of bananas as I got contract lease of bananas from Abdul,
Aijaz Jokhio and I and my broker Abid Ali Veesar aged about 22
years used to look after the banana by ourselves, on 18-5-2013 I, my
brother Abid Ali relative each other Muhammad Akram son of
Manzoor Hussain Veesar and Aijaz
[2]
son of Ghulam Rasool Veesar together went to supply the fertilizer
to the labourers and after supply of fertilizer to the labourers we all
three after boarding on motorcycles were coming from Satpiri road
towards Nawabshah it was about 3:00 PM morning when reached
near at the land of Abdul Aziz Jokhio we saw that 6 persons were
standing on the road who were armed with pistols they got stopped
our motorcycles and brought us in the banana out of whom we
identified four ac used to be each, Khadim Hussain son of Dariya
Khan Rind, Ayaz Ali son of Soomar Kalhoro, Riaz alias Deedar son
of Rahib Ali Rind, Beg Muhammad son of Yar Muhammad Rajper,
and tow unidentified accused they kept us under confinement in
the banana and they contracted on mobile phone after 15 minutes
one golden color corolla car arrived there from which 15 minutes
one golden colour corolla car arrived there from which 5 accused
alighted out of whom four accused were armed with pistols and
one was armed with repeater who also came inside the banana and
they were identified each accused Mashooq Ali son of Allah Dino
Babr Jamali, Mumtaz alias Bhooral shah son of Ghulam Shah,
Shahjahan son of Sikandar Ali Jatoi, Ghulam Fareed son of Mithal
Soomro Abdul Razaque alias Raban son of Abdul Rehman Abro
who brought my brother Abid Ali Veesar with them got him seated
in the car and while leaving the place of incident they asked the
applicant party that if they never accept their demands they would
commit murder of my brother Abid Ali due to fear we never
apprise any fact to anybody else ti8ll yet as this plan was made by
Dhani Bux son of Shah beg Chandio for kidnapping of my brother
Abid Ali in order to achieve their malicious object as such the said
Dhabi Bux has hand in the kidnapping of my brother the tow
identified accused were clearly seen by me and my PWs and would
be identified if seen again I am complainant prayed for
investigation
After usual investigation the Police of PS Sakrand arrested

the applicants/accused named above, they filed their first bail
application but same was dismissed on merit, thereafter
applicants/accused filed 2nd Bail application same was dismissed on
merit , hence this fresh bail application on the following grounds .
-: G R O U N D S :-
59.That the applicant accused are quite innocent and have nothing
to do with the alleged offence.
[3]
60.That the applicants accused are quit innocent and have been
falsely implicated by on suspicious basis by the complainant
party.
61.That complainant namely Talib Hussain and abductee Abid Ali ,

PWs Muhammad Akram, Aijaz all by caste vaseer have filed
their affidavits , in which categorically disclosed that the above
named accused persons have been given on suspicious basis in
fact now they have came to know that above named accused
persons are innocent and if this Honourable Court may release
them on bail then they have no objections.
62.That there is inordinate delay for about 19 days in lodging of the

FIR without any plausible explanation, which creates doubt as
such false implication of the applicants accused can not be ruled
out .
63.That there is also delay of 9 days in recording of 161 Cr PC

statements of PWs which creates doubt in the case prosecution .
64.That neither the complainant has disclosed in his FIR nor the
alleged abductee disclosed in his 164 Cr PC statement that the
present applicants/accused from whom presence and where
they gathered to make plan for kidnapping of his brother hence
the matter requires further inquiry .
65.That as per the 164 Cr PC statement of alleged abductee the

abductee has been recovered on 6-9-2013 while his 164 Cr PC
statement has been recorded on 17-6-2013 after the delay of 8
days which also create a reasonable doubt in the case of
prosecution. It is well settled principle of law that every benefit
of doubt goes to the accused even at bail stage.
66.That there is a general allegation against the present

applicant/accused but alleged recovery has been foisted upon
present applicants accused nor they have encountered with
police party but encountered story has been falsely managed
upon the present applicant accused persons only in order to
show efficiency to higher authorize of police department.
[4]
67.That the grievances in amongst the applicants named above and
complainant has been resolved, whereas complainant has sworn
the affidavit and categorically stated that he has no objection if
the above named accused may released on bail, by this
Honourable in present case.
68.That the entire story setup in the FIR is totally based on
suspicious .
69.That nothing has been recovered from the present

applicants/accused but alleged recovery has been foisted upon
the present applicant accused persons not they have encountered
with the police party but encountered story has been falsely
managed upon present applicants accused persons only in order
to show efficiency to higher authorize of police department .
70.That the case has been challaned and the applicants accused are
not more required for the further investigation but requires
further inquiry.
71.That the case of present applicant/accused requires further

inquiry .
72.That there is appear no reasonable grounds to believe that the

applicants/accused are guilty of the alleged offence.
73.That no useful purpose would be served to the prosecution if the

applicants/accused remained more in jail
74.That applicants accused will never abscond away for which they
are ready to furnish highly respectable surety to the entire
75.That applicants/accused seeks persons to urge more grounds if

any at the time of arguments.
76.That grant of bail to applicants/ accused will meet in the interest
of justice.

APPLICANT/ACCUSED
IN THE COURT OF SPECIAL JUDGE CNS, SHAHEED

BENAZIRABAD
The State
VS
Taj Mohammad Brohi

BAIL APPLICATION

applicant/accused , Taj Mohammad alias Tajoo alias Mumtaz
S/O Ameer Bux Brohi, R/O Village Mirza, Taluka
Nawabshah, District Shaheed Benazirabad, now confined in
District Jail Nawabshah, that this Honourable Court may be
pleased to release him, on bail in the above crime/case, on
-: F A C T S :-
Brief facts of the case are that on 25-7-2012 , SIP Bisharat

Ali Mallah on behalf of state lodged FIR with PS B Section
Nawabshah, alleging therein that on the day of incident, he
alongwith him subordinate staff left PS, vide entry No 25 for
patrolling in the vicinity, after patrolling various places when
reached at Daur 60 Mile Road they received spy information,
that in crime No. 102/2012, PS B Section Nawabshah, U/S
399, 402 PPC, wanted accused Taj Mohammad Brohi is selling
Chars in 60-Mile road near Sim Nala, with the result the went
towards the pointed place and saw on person standing who
after seeing the
[2]
police tried to escape away, but police encircled him and

arrested, during interrogation he disclosed his name to be the
applicant, during search they allegedly received 3 pockets of
Chars wrapped in white Tawal tied with chest which was
allegedly weighted, which became 3000 Grams. One hundred
grams from each pocket was separated and sealed for sample
and 2700/- grams was sealed separately, the police also
allegedly recovered Rs 250/- from the side pocket of his shirt.
The police prepared such Mashirnama arrested the accused
in crime No 102/2012, also brought him at PS and registered
the present case. Hence this FIR.

the applicant is in Jail hence this Bail application.
-: G R O U N D S :-
alleged offence.
238. That actually the applicant was detained much before the
present case and when the relatives of applicant raised hue and
cry the police booked him in this case by foisting the Chars upon
him.
239. That the complainant himself had investigation the case both
the Mashirs are his subordinate, thus there is clear cut violation
of section 25 (2) of police rules 1934 and section 18 (4) of police
order 2002, PLD 2009 Karachi Page Number 191.
240. That the applicant is in Jail since 16 months.
section 497 Cr PC as the Quantum of sentence normal and
standard sentence for the allegedly substance is 5 years six
months and fine of Rs 2500/- in default to suffer 51 for 5 months
and 15 days, PLD 2009 Lahore page No 362.
[3]
242. That the police had admittedly arrested the applicant on spy
information in spite of that they had not obtained the services of
private independent person, therefore there is clear violation of
section 103 Cr PC reliance is placed PLD 2009 Karachi 191 and
PLD 1997, SC page No 422. PLD 2002 SC page Number 590.

chemical analyzer though the same is entrusted to PC
Amanullah on 6-8-2013 reliance is placed on MLD 2009 page No
133.

less than 10 years the grant of bail is of rule and refusal an
exception reliance is placed on PLD 1995 SC Page No 34.
246. That the applicant is not involved in such nature of case and is
not likely to abscond and temper with the evidence as all the
witnesses are police men.
247. That the applicant is prepared to furnish solvent surety to the

M. SHARIF SIAL
APPLICANT/ACCUSED
B. A. No: OF 2013.
Luqman son of Muhammad Uris Jamali

R/O Kazi Ahmed Mor Nawabshah
Shaheed Benazirabad……………………..………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 195/2013 , PS A Section

Nawabshah
OFFENCE U/S 353, 504, PPC and 11
Hudood ordinance
BAIL APPLICATION

and grounds:-
-: F A C T S :-
Briefly facts leading to present case are that complainant HC

Imdad Ali with PS A Section Nawabshah on 6-11-2013 at 2:30 hours
at PS A Section Nawabshah alleging therein that complainant
alongwith his subordinate staff each PC Habibullah PC Khushi
Muhammad, PC Rasool Bux PC Mehrab Khan duly dress armed
with government ammunition in government vehicle No SP 6951
with driver PC Ghulam Hussain left PS vide Roznamcha entry No
33 dated 5-11-2013 at about 2:000 hours for patrolling in his beat
during patrol at about 100 when they reach Lasani chock Katchery
road Nawabshah they saw three person were standing in drinking
condition of wine and they were abusing by passers the police
p[arty try to arrest them but they also abused them and disturbance
in discharging their lawful duties the police party with technicality
arrested them due to on availability of private Mashirs the
complainant arranged PC Habibullah PC Khushi Muhammad made
Mashirs and enquired their
[3]
names personal percentage, search of accused persons, during

personal search one accused disclosed his name to be Ghulam
Nabi son of Muhammad Mithal Mangsi R/O Village Muhammad
Mithal Mangsi, near Airport road, to whom police party recovered
Rs 50/- from his front pocket of shirt and smell of wine was coming
from his mouth, second person disclosed his name to be Qurban Ali
S/O Muhammad Mithal Mangsi R/o village Lal Khan Mangsi
Taluka Nawabshah from his search Rs 100/- was recovered from
his front pocket of shirt and smell of wine was coming from his
mouth, third person disclosed his name as Luqman Ali son of
Muhammad Uris Jamali R/O Kazi Ahmed Tum Nawabshah, from
his personal search Rs 100/- was recovered from his front pocket of
shirt and smell of wine was coming from his mouth All 3 accused
person were arrested U/S 353 , 504 PPC 11 Huddod ordinance such
Mashirnama were prepared on street light in presence of above
mashirs thereafter all accused brought at PMC hospital Nawabshah
for medical checkup after medical checkup accused and recovered
property brought at PS and lodged FIR.
After usual investigation the Police of PS A Section Nawabshah

arrested the applicant/accused , who is in judicial custody hence
this Bail application on the following grounds
-: G R O U N D S :-
77.That the case against the applicant/ accused is false and

applicant is innocent
78.That no such incident whatsoever stated above is ever took place

but complainant with malafide intention has implicated the
applicant/accused in this present case on the basis of concoction
story.
79.That alleged story is managed one actual facts are that when the
police arrested the applicant/accused that time smell was
coming from mouth of the applicant party but no any bottle fill
up or empty was recovered from the possession of the applicants
which creates doubt in prosecution story which makes the
applicant entitle for the bail.
[3]
80.That alleged recovery of the amount is not huge amount but

complainant with intrigue of his subordinate by showing his
efficiency has malafidly implicated the applicant, just to
pressurize and blackmail the applicant otherwise applicant is not
concerned with same offence.
81.That the case against the applicant is false and fabricated one
which is not plausible nor understandable as such story narrated
in facts clearly false and after arrest of the applicant the
complainant demanded huge money which is against nature
principle of law.
82.That the place of incident is thickly populated place and round

the clock superior numbers of the person are available and
superior numbers of the persons are working whole day, but
complainant did not try to associate any single person as a
private Mashir to corroborate their version, which creates doubt
in prosecution story which makes the applicant entitle for the
concession of the bail.
83.That all the witnesses cited in the FIR are police officials and they
are interested witnesses of the complainant.
84.That the section applied in the FIR are not concerned with the
applicant and which not comes in definition of the prohibitory
85.That the applicant has possessed good reputation in their vicinity

but complainant with malafide intention to down their fame
reverence has implicated him in this false case otherwise no any
sort of incident was ever took place.
86.That the applicant/accused is Chingchi driver and leads

respectable life by earning hardly and whole family members
and senile aged parents aged about 70/80 years are depending
upon the applicant but complainant dint of force has cruelly
arrested and implicated in this false case.
[4]

as all the witnesses cited in the FIR are police official as they are
interested witnesses.
88.That there is no apprehension of absconsion of the applicant as

he is ready to furnish his solvent surety to the satisfaction to this
Honourable court.

APPLICANT/ACCUSED
BENAZIRABAD
The State
VS
Taj Mohammad Brohi

BAIL APPLICATION
-: F A C T S :-

after seeing the
[2]

-: G R O U N D S :-
alleged offence.
him.
[3]

133.


M. SHARIF SIAL
APPLICANT/ACCUSED
BENAZIRABAD
The State
VS
Taj Mohammad Brohi

BAIL APPLICATION

-: F A C T S :-

after seeing the
[2]


-: G R O U N D S :-
alleged offence.
him.
[3]

133.


M. SHARIF SIAL
APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2013.
The State
VS
Haq Nawaz

OFFENCE U/S 9/C, CNS Act,
BAIL APPLICATION

applicant/accused , Haq Nawaz S/O Sono Khan Zardari,
R/O Chanesar Near Arbab Stop Taluka Nawabshah now
confined in Sub-Jail Sakrand, that this Honourable Court may
be pleased to release him on bail in the above crime/case, on
-: F A C T S :-
Brief facts of the case are that on 5-12-2012, SIP Abrar

Hussein of PS Sakrand lodged FIR with PS Sakrand alleging
there in that from arrested accused in crime No 231/2012,
U/S 324, 353 PPC, 9 CNSA two Kilogram of Chars has been
recovered out of which 100/100 grams has been separated
and sealed for sample, and also recovered Rs. 300/- cash,
hence this FIR.
[2]
After usual investigation the case has been challaned.
The applicant/accused is in Jail. Hence this Bail application
-: G R O U N D S :-
90.That the applicant/accused is innocent and had not committed

alleged offence.
91.That the applicant/accused has been roped in this case by the

police.
92.That the applicant on the alleged day of incident was entering in

the court of Civil Judge & Judicial Magistrate Sakrand and from
the outer gate of court was arrested by the police and roped in
this case by foisting Chars upon him, due to enmity, such
application was moved by the father of the applicant/accused to
Civil Judge and Judicial Magistrate Sakrand, which is attached
herewith.
93.That the offence doesn’t fall within the prohibitory clause of

section 497 Cr PC as maximum sentence in such cases is
provided 4 years, 6 months. Besides all the witnesses are police
officials and there is no apprehension of tempering with the
evidence reliance is placed on PLD 2009 Lahore page No 362.
94.That the case of the applicant/accused is also covered by the

policy laid down by the apex Courts whereby the Quantum of
sentence has been provided according to nature of contraband
substance and the same ahs been up held by the supreme court
of Pakistan, reliance is placed on 2012 PLD (SC) page No. 380.
95.That the case of the applicant /accused is of further inquiry.

96.That the FIR it self is also vague one as it doesn’t not show how,
when, from where and is whose presence the alleged Chars has
been recovered. Nothing is about the Wight and sealing of
remaining Chars.
97.That there is delay in sending the sample to chemical Examiner.
[3]
99.That applicant/accused is ready to furnish his solvent surety to

M. SHARIF SIAL
APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Khamiso son of Sobharo , Muslim Adult

By caste Zardari, R/O Qazi Ahmed Taluka
Kazi Ahmed, District Shaheed
Benazirabad ……………………………………….…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
Crime No: 214/2013, P.S, Qazi
Ahmed
OFFENCE U/S 9/B CNS Act, 9 Opium
Act
BAIL APPLICATION

-: F A C T S :-
Brief facts of the case are that on 9-10-2013, SIP Ghulam

Abbas Shar, SHO of PS Qazi Ahmed lodged his FIR with PS
Qazi Ahmed, alleging therein that on 9-10-2013 he alongwith
ASI Mola Bux, HC Karim Bux, and other police constables in
pursuance of Mashirnama prepared in crime No 213 of 2013,
U/S 9/B CNS Act 9 Opium Act, PS Qazi Ahmed arrested
accused Khamiso S/O Sobharo Zardari, while keeping 250
Grams of Opium had committed offence U/S 9-B CNS Act, 9
Opium Act, 50 Grams are said to have been separated sealed
for sample, Rs 50/- Cash is also said to have been recovered,
thereafter applicant and recovered property brought at PS and
lodged present FIR.
[2]

arrested, who is in Jail custody, hence this bail application on
the following grounds.
-: G R O U N D S :-

101. That the alleged opium has been foisted upon the applicant by
police at the instance of his rivals.
102. That the applicant is an old man of more then 60 years old.
103. That offence doesn’t fall within the prohibitory clause of

section 497 Cr PC.
104. That the FIR is also vague type doesn’t show how when and
from there the alleged Opium was recovered, nothing is about
the weighing.
105. That the case is of further inquiries.
106. That other grounds will be urged at the time of garments

APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Gulab son of Umar Jagirani both

R/O Pritamabad Taluka Sinjhoro
Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

and grounds:-
-: F A C T S :-

Mirz Ali son of Abdullah Khan Pathan lodged his FIR at PS
Jam Dattar on 6-9-2013 at about 14:00 hours, alleging therein
that, complainant have cattles cows and buffaloes and
complainant have catle Pand on 30-8-2013 at night
complainant tied his cattle in cattle Pan and closed the door
with hedges and went to sleep. At about 2:30 night time
complainant got up to look after his cattle the light was on the
complainant saw the door of the cattle Pand was opened and
one buffaloes was missed and likely to be stolen. Where 4
person’s foot prints were available there, thereafter with the
help of villager and foot tracer follow the foot prints on the
way tracing of the foots prints of the culprits Israr Ahmed son
of Muhammad Abdul Pathan, Zaheer Ahmed son of Shah
Zaman met
[2]
with the complainant to whom they were present at their land

for flowing the water in their lands, where they disclosed that
they were flowing the water and saw on the torch of light and
identified that they were Allah Yar son of Dahar Shar R/O
own house Taluka Shahdadpur, Shahan alias Kuraro son of
Saeed khan alias Titar Jagirar , Gulab son of Umar Jagirani
both R/O Pritamabad Taluka Sinjhoro and one unknown
person who can be identified if seen again they were going
with buffaloes thereafter complainant party alongwith Israr
Ahmed and Zaheer Ahmed traced the foots prints which led
at Allah Yar Shar , where Allah Yar and Shahan alias Kuraro
met with complainant and promised to return buffaloes and
give the faisla but they kept the complainant on pretexts
thereafter refused now complainant came at PS and lodged
the FIR against the mentioned above culprits as well as they
have stolen the buffaloes from cattle Pand of the complainant
prescription is given below, hence this present FIR
arrested who is in judicial custody hence this bail application
-: G R O U N D S :-

108. That there is inordinate delay in lodging of the FIR more then
7 days without any plausible explanation which goes to show
that the same has been lodged after deliberation and consultation
as such false implication of the applicant in present case can not
be ruled out.
109. That no such incident whets over stated in the FIR is ever
took place but whole drama has been engineered by the
complainant with malafide intention as well as no recovery was
made from the applicant/accused but complainant malafidly
implicated the applicant/accused in this false otherwise
[3]
110. That the as per the contents of the FIR the names are given on
the instance of PWs Israr and Zaheer which makes the case of
applicant/accused for further inquiry and it is unbelievable
story.
section 497 Cr PC.
112. That the story narrated in the FIR is false and fabricated one
how its possible for the complainant to believe on the promise of
the culprits.
114. That applicant/accused is behind the bar hence he is not

115. That the applicant accused is falsely implicated in this present

case in fact no such incident was ever took place.
116. That the complainant did not disclosed description of the

alleged stolen property (buffaloes) which makes the case
doubtful.

his vicinity as well as he is not hardened criminal nor did
disparate nor previous convict.
119. That complainant no any single name of the villager was

disclosed at the time of tracing the foot prints which creates
doubt in prosecution story put forth hence applicant/accused is
entitle for concession of bail.

complainant
[4]


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.

.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 392, 342. PPC
BAIL APPLICATION

-: F A C T S :-

Syed Javed Ali Lodged his FIR at Police station B Section
Nawabshah on 22-8-2013 at about 15:00 hours alleging therein
that he used to resides on the address shown in the column
No 1 of the FIR and is a Tai driver on the vehicle Car Of
Muhammad Bux Pathan re3sident of Lateefabad No 7
Hyderabad bearing registration No AZP-547, Engine No Y-
814243, Chassis No NZE-140-2168117, Model 2013 company
Corolla GLI. It is further case of the complainant that on the
day of incident viz 21-8-2013 he alongwith his friends Syed
Fida Shah and Nadeem Ahmed was
[2]
present at Taxi stand of Lateefabad No 4 at about 4:00- PM,

where tow person came there and asked him to go to
Nawabshah on fare. It is further the case of the complainant
that they inquired their names etc, who disclosed themselves
to be each one Fakir Muhammad alias Comrade Jakhrani,
Abdul Razaque Babhan whom the complainant party settled
the fare and then boarded the car and proceeded to
Nawabshah from Hyderabad and when reached at
Nawabshah town the persons sitting in the car asked the
complainant that they have to go to outside the Nawabshah it
is further case of the complainant that when at about 6:00
evening reached Katcha Path leading towards village Chakkar
Khan Shahani near Sim Nala Deh 91 Nasrat Taluka Daur a
Motorcycle of Black Colour was standing and nearby the
Motorcycle tow persons were standing who have been clearly
seen and would be identified if seen again and seeing them
the persons sitting in the car immediately took out pistols
from their fold of aimed the same at the complainant and
asked him to stop the car, the complainant stopped the car,
due t fear of weapons and got down from the car, it is further
case of the complainant that, the persons standing near the
Motorcycle were also having pistols in their hands who on the
force of pistols took the complainant towards the sugarcane
crop, on the southern side of the Sim Nala and stood guard
upon the complainant with pistols and tow persons Fakir
Muhammad alias Comrade Jakhrani and Abdul Razaque
Babhan went away in the Car while tow persons of
Motorcycle robbed one mobile of Nokia company driving
license and cash amount of Rs 6,000/- of different currency
notes and after about tow hours went away on the motorcycle
on the northern side by leaving the complainant in sugarcane
crop thereafter complainant came out from the crop of
sugarcane and came at Nawabshah on foot wherefrom he
informed the owner of the car through PCO who came and
alongwith him the complainant came at Police station and
lodged his FIR .

Nawabshah during the course of investigating arrested the
applicant/accused who is in custody, A bail application was
filed by the applicant before the Honourable civil judge &
Judicial Magistrate-II
[3]
Nawabshah which was dismissed. hence applicant filed

present fresh bail application before this Honourable Court
with fresh grounds .
-: G R O U N D S :-


in this false case by the police.
180. That there is inordinate delay of more then 21 hours in

lodging the first report and such a delay has not been
explained at ll which goes to show that every thing has been
managed and as such the false implication of the
181. That the name of the applicant/accused doesn’t

transpired in the FIR who has been implicated in this case on
the basis of supplementary statement of the complainant
which has been recorded after six days of registration of the
FIR which has got no value in the eye of law.
182. That the malafide in the present case can be seen from
the facts that complainant is resident of Hyderabad but in-
spite of that he has given the name of village Deh Taluka and
its not known how the complainant knew all this which
makes the whole case of the prosecution doubtful and that of
further inquiry.
183. That in fact no such incident has taken place but

complainant has managed the whole story falsely on the
instance of police.
184. the story narrated in the FIR is absurd as the same is

185. That the incident as alleged has taken place near village
Chakar Khan Shahani which is quite a big village but in-spite
of that non from the vicinity came forward to support the
version put forth by the complainant.
[3]
186. That nothing has been recovered from the exclusive

possession of the applicant.
187. That the minimum punishment of section 392 PPC is
three years and at bail stage minimum punishment would be
taken into consideration and as such section applied in the
First report doesn’t fall within the prohibitory clause of
section 497 Cr PC .
188. That admittedly there is nothing to connect the

applicant accused with alleged offence.
189. That the applicant/accused is in judicial custody and no

more required for the purpose of investigation.

applicant/accused who is ready to furnish solvent surety to
192. hat the other grounds will be argued at the time of

hearing

APPLICANT/ACCUSED
IN THE COURT OF JUDICIAL MAGISTRATE-III
NAWABSHAH
B. A. No: OF 2013.

.Applicant/accused
VS
The State ……………….…………………………..………………
Opponent

Nawabshah
OFFENCE U/S 392, 342.
AFFIDAVIT
I Pir Lutafullah son of R/O
Taluka District Shaheed Benazirabad

BENAZIRABAD
B. A. No: OF 2013.
Mumtaz son of Haji Allam Rind

Presently confined in Sub Jail Sakrand …...…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 324, 353, PPC & 5
Gambling Act
BAIL APPLICATION
-: F A C T S :-

Abdul Wahab Rind lodged his FIR at PS Sakrand on 13-9-2013
at about 18:45 hours , alleging therein that complainant
received spy information that some persons plying the
gabling near at Dalail Dero in Banana Garden and came at
different place and different vehicles after receiving such
information the complainant alongwith subordinate staff left
the PS under the entry No 20 dated 3-9-2013 at about 17:30
hours complainant reached near Dalel Dero railway Furda
where they saw the above mentioned vehicles were parked
there and superior numbers of the persons were playing
gambling , they by seeing the police party tried to skip
[2]
away meantime accused Mumtaz Rind and 9 unidentified

accused by making straight fires upon the police party they
run away the unidentified can be identified if seen again and
the police captured the accused, each Riaz Ahmed Soomaro ,
Manzoor Ahmed Kalhoro , Ali Nawaz Machi, Umaid Ali
Shah, Moula Bux , Ali Ahmed , Ghulam Swarwar, Misri , Mir
Muhammad, Ali Hyder, Shafique Ahmed, Luqman, Ghulam
Serwar due to non availability of the private Mashir the HC
Muhammad Ali PC Suhrab Ali were made mashirs of the
place of the Wardhat, the police party conducted personal
search of every body but nothing secured from the their
personal search , where police secured 4 fingers of TASH
Patas which was consisted on 52 Patas and Rs 30,000/- cash
which police party secured in their possession thereafter
police brought the recovered property and accused persons at

arrested the applicants/accused who are in judicial custody
hence applicants/accused filed present bail application on the
following grounds .
-: G R O U N D S :-

194. That there is delay in lodging of the FIR 1:45 hours

as such false implication of the applicants/accused can not be
ruled out .
195. That the section 5 gambling Act and section 353 are
bailable whereas the section 324 PPC is misapplied .
196. That there is ineffective firing, it is imagine to say that

more ten 10 persons directly fires upon the police party but
none has been injured even no sustained single firearm injury
to the persons so also the mobile.
[3]
197. That the investigation has been completed and

challaned has been submitted before the competent court of
law hence the applicant accused is not required for further
investigation.
199. That applicant/accused did not know regarding the this

offence as he appeared before the civil judge JM-I in an other
case at there, he was taken the custody by the judicial
magistrate in this case/crime.
200. That all the PWs cited in the FIR are police officials as
well as they are sweet obligor of the complainant hence they
are interested witness of the complainant

complainant

arguments.


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.

.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 392, 342.
BAIL APPLICATION

-: F A C T S :-

Syed Javed Ali Lodged his FIR at Police station B Section
Nawabshah on 22-8-2013 at about 15:00 hours alleging therein
that he used to resides on the address shown in the column
No 1 of the FIR and is a Tai driver on the vehicle Car Of
Muhammad Bux Pathan re3sident of Lateefabad No 7
Hyderabad bearing registration No AZP-547, Engine No Y-
814243, Chassis No NZE-140-2168117, Model 2013 company
Corolla GLI. It is further case of the complainant that on the
day of incident viz 21-8-2013 he alongwith his friends Syed
Fida Shah and Nadeem Ahmed was
[2]
present at Taxi stand of Lateefabad No 4 at about 4:00- PM,

where tow person came there and asked him to go to
Nawabshah on fare. It is further the case of the complainant
that they inquired their names etc, who disclosed themselves
to be each one Fakir Muhammad alias Comrade Jakhrani,
Abdul Razaque Babhan whom the complainant party settled
the fare and then boarded the car and proceeded to
Nawabshah from Hyderabad and when reached at
Nawabshah town the persons sitting in the car asked the
complainant that they have to go to outside the Nawabshah it
is further case of the complainant that when at about 6:00
evening reached Katcha Path leading towards village Chakkar
Khan Shahani near Sim Nala Deh 91 Nasrat Taluka Daur a
Motorcycle of Black Colour was standing and nearby the
Motorcycle tow persons were standing who have been clearly
seen and would be identified if seen again and seeing them
the persons sitting in the car immediately took out pistols
from their fold of aimed the same at the complainant and
asked him to stop the car, the complainant stopped the car,
due t fear of weapons and got down from the car, it is further
case of the complainant that, the persons standing near the
Motorcycle were also having pistols in their hands who on the
force of pistols took the complainant towards the sugarcane
crop, on the southern side of the Sim Nala and stood guard
upon the complainant with pistols and tow persons Fakir
Muhammad alias Comrade Jakhrani and Abdul Razaque
Babhan went away in the Car while tow persons of
Motorcycle robbed one mobile of Nokia company driving
license and cash amount of Rs 6,000/- of different currency
notes and after about tow hours went away on the motorcycle
on the northern side by leaving the complainant in sugarcane
crop thereafter complainant came out from the crop of
sugarcane and came at Nawabshah on foot wherefrom he
informed the owner of the car through PCO who came and
alongwith him the complainant came at Police station and
lodged his FIR .

Nawabshah during the course of investigating arrested the
applicant/accused who is in custody , A bail application was
filed by the applicant before the Honourable Judicial
Magistrate-II Nawabshah which was dismissed hence
applicant filed present fresh bail application before this
Honourable Court with fresh grounds .
-: G R O U N D S :-


applicant/accused whereas applicant is not concerned same
alleged place of incident and with the pistol which false story
narrated by the complainant is unbelievable and implausible.

ever taken place but complainant with malafide intention for
the ulterior reasons by showing his efficiency involved the
207. That no such incident whatsoever stated is taken place

the place of Wardaht is thickly populated area the passerby
superior number of
[3]
the persons and vehicles runs round the clock but complainant
just to get help of falsification has shown involvement of the
applicant/accused in this present case there is clearly
contradiction of section 103 Cr PC.
208. That the case against the applicant accused is false and
fabricated one as well as applicant/accused has possessed
good reputation in his locality but complainant just to
vitiating and aggravating the fame and reverence of the
applicant has roped in this false case with core connivance of
his supporter Mashirs.

complainant

arguments.


APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2013.

.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 23/A S.A Act .
BAIL APPLICATION

-: F A C T S :-

SIP Ali Hussain Shar SHO of PS Bandhi lodged his FIR at PS
Bandhi on 27-9-2013 at about 23:30 hours, alleging therein that
complainant alongwith ASI Mumtaz Ali Jalbnai, ASI
Hyderabad Ali and other subordinate staff left the PS
containing government ammunition on government vehicle
No SP 7292 alongwith driver Muhammad Uris Jamali, under
the entry No 19 dated 27-9-2013 at about 19:30 hours, for
patrolling various places when the complainant with direction
of their higher officer they departed to Village Shehzado
Dahri which, whereas complainant party started checking of
the vehicles at Sadah Wah Mori, at about 22:00 hours
complainant party saw one persons was coming from eastern
side top of the Sada Wah Mori suspiciously complainant party
raised
[2]
hackles to stop, whereas on the hackles of the police the

accused person tried to skip away but complainant party
tactfully captured the accused person due to non availability
of the private Mashir the ASI Mumtaz and Hyder was
associated as Mashir of the place of Wardhat thereafter
complainant inquired about name address and who disclosed
his name to be the Qadir Bux alias Qadu by caste Dahri R/O
Village Karim Bux Dahri Deh 2 Nusrat Taluka Daur District
SBA on body searching police secured one pistol 30-bore
Magazine and which was unloaded wherefrom complainant
party secured 8 live bullets which kept in their possession
thereafter police party inquired about license of the pistol who
disclosed to be unlicensed , above accused was wanted
accused in crime No 24/2012 under section 395,399, 402 PPC
of PS Bandhi and crime No 66/2012 under section 395, 450
PPC of PS Daur which was absconder one thereafter police
party brought the accused alongwith recovered property ,

-: G R O U N D S :-



superior number of
[3]
complainant

arguments.


APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2013.
Qadir Bux alias Qadru son of Wahid Bux Dahri

R/O Village Sher Muhammad Dahri Deh
1-Nusrat, Taluka Daur District Shaheed
Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

raised
[2]


-: G R O U N D S :-



superior number of
[3]

complainant

arguments.

APPLICANT/ACCUSED

BENAZIRABAD
B. A. No: OF 2013.

Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

raised
[2]


-: G R O U N D S :-
1. That the applicant/accused is innocent and had not committed

the alleged offence.
2. That the pistol has been foisted upon the applicant/accused


place but complainant with malafide intention for the ulterior
reasons by showing his efficiency involved the
[3]
4. That no such incident whatsoever stated is taken place the place
of Wardaht is thickly populated area the passerby superior
number of the persons and vehicles runs round the clock but
complainant just to get help of falsification has shown
involvement of the applicant/accused in this present case there
is clearly contradiction of section 103 Cr PC.
5. That the case against the applicant accused is false and fabricated
one as well as applicant/accused has possessed good reputation
in his locality but complainant just to vitiating and aggravating
the fame and reverence of the applicant has roped in this false
case with core connivance of his supporter Mashirs.
6. That all the PWs cited in the FIR are police officials as well as



APPLICANT/ACCUSED
IN THE COURT OF SESSIONS JUDGE SHAHEED 7-
BENAZIRABAD
B. A. No: OF 2013.

Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

-: F A C T S :-

Roshan Ali son of Ladho Khan lodged his FIR at PS Daur on
26-12-2012 at about 16:30 hours, alleging therein that the
complainant is Zamidar and is residing on the above
mentioned address alongwith his brother Abdul Wahid and
his other family members/children he has own Mehran Car
No AUV-381 of white colored and his brother Abdul Wahid
has Super Star Motorcycle No NHH-0886 on 29-11-2012 at
evening time his cousin namely Ali Hassan Gorchani had
come to complainant after taking night meals and parking Car
and Motorcycle inside the house and closing main gate of
house they went to sleep electricity bulbs were alighting, on
29-11-2012 at about 12:30 Am Night there was knock in the
house on which complainant party woke up and saw
[2]
that 6 persons out of whom the complainant party identified 4

persons Sijawal alias Akbar alias jelo son of Miral Shar with
gun Gul Hassan son of Loung Mari with pistol Mour son of
Jan Muhammad alias Jani Dahri, Qadir Bux alias Qadiroo son
of Wahid Bux Dahri with KKS and tow unidentified accused
with muffled faces having pistols in their hands on arrival all
the accused aimed their weapons upon the complainant party
and directed them to remain silent due to fear of weapons the
complainant party remained calm then accused persons
robbed Rs. 2000/- cash on below detailed Mobile key of car
from the Pocket of the complainant key of Motorcycle Rs
3000/- Cash and below detailed mobile Pone from the brother
of the complainant Namely Abdul Wahid thereafter accused
persons broken the lock of Box and took tow pairs of Golden
Neelams and then tow unidentified accused on the
motorcycle and rest of the accused on the Car of the
complainant went away due to late hours of night the
complainant remained in his house and at morning time he
went to his neckmard Haji Ibrar Hussain Gorchani to his
village but he was not available in the village then the
complainant approached to Gul Hassan Mari and asked him
for restoration of robbed property but he kept the
complainant on false hopes and refused on the day of report
the complainant narrated the above facts to Neckmard Ibrar
Hussain who advised him to lodge the FIR at police station
then the complainant came and lodged FIR as stated above.

-: G R O U N D S :-

be ruled out.
[3]
125. That the identification of the applicant /accused on the

electricity light which is the weak source of the identification.
126. That the co-accused are granted on the bail by Honourable

High Court Sindh Circuit Bench Hyderabad for which applicant
is entitle for the same sort of relief.
127. That the alleged recovery of Car has been foisted upon the
applicant/accused .
128. That no any PW has stated in their statement under section
161 Cr PC that alleged Car was recovered from the exclusive
possession of the applicant/accused in their presence.
129. That the alleged recovered Car was recovered in broken

condition but no accused has received any injury in accident
though the accused were arrested on 28-12-2012 and alleged Car
was shown accident on 27-12-2-12 which great serious doubt in
the prosecution case and benefit of doubt will go to accused even
at bail stage according to law.
130. That the Mashirnama of arrest also creates serious doubt that
same was prepared in presence of Mashirs namely Abdul Wahid
son of Ladho Khan and Ali Hassan son of Sharbat Gorchani but
instead the Mashir Ali Hassan the signature was obtained from
Roshan Ali .
131. That the falsification of the case is proved from the facts that
the complainant or any PW raised no cries at the time of alleged
incident or after departure of accused on which any villager
would have come.
132. That factual position is that the applicant/accused are harries

of the complainant and some amount was out standing against
the complainant and in order to usurp the same the complainant
has involved them in this false case with the malafide intention.
133. That there is no reasonable ground to believe that the

applicants/accused are guilty of alleged offence.
[4]
134. That there is no likelihood of tampering with the prosecution
evidence.

complainant


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Allah Yar son of Dahar Shar

Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent
BAIL APPLICATION

and grounds:-
-: F A C T S :-

Zaman met with the complainant to whom they were present
at their land for flowing the water in their lands, where they
disclosed that they
[2]
were flowing the water and saw on the torch of light and

-: G R O U N D S :-

be ruled out.
[3]
story.
section 497 Cr PC.
the culprits.



doubtful.



complainant
[4]


APPLICANT/ACCUSED
MAGISTRATE-II NAWABSHAH
B. A. No: OF 2013.
Allah Yar son of Dahar Shar

Benazirabad ………………………………………..…
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

BAIL APPLICATION

and grounds:-
-: F A C T S :-

Zaman met with the complainant to whom they were present
at their land for flowing the water in their lands, where they
disclosed that they
[2]
were flowing the water and saw on the torch of light and

-: G R O U N D S :-

be ruled out.
[3]
story.
section 497 Cr PC.
the culprits.



doubtful.



complainant
[4]


APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Muhammad Umar alias Roomi son of Siddique Khanzado

R/O Khanzada Mohalla Sakrand now confined
In Sub-Jail Sakrand …………………………………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 324, PPC, 337-A(i) (iv)
Q.
BAIL APPLICATION

and grounds:-
-: F A C T S :-

Rehana Zardar Khan lodged his FIR at PS Sakrand on 26-6-2013 at
about 12:00 hours, alleging therein that complainant is by
profession General Secretary of Women Development Organization
at Sakrand and complainant solemnized Nikah with one
Muhammad Umar alias Roomi Khanzada to whom tow children
son and daughter were born from him, about one and half year ago
due to matrimonial affairs complainant got divorce from accused
from competent court of law thereafter complainant used to live
with mother of the accused at their home , now recently she died
some four days ago, whereas accused Muhammad Umar alias
Roomi used to extend threats that he did not allow to the
complainant to live in house of Muhammad Umar, and also
threatened that if the complainant used to live in house then he
would not spare the complainant. On 11-6-2013 the complainant
was present with her children at about 8:00Am the present accused
Muhammad Umar alias
[2]
Roomi knocked the door of the room, the complainant saw

that present accused standing outside of the door armed with
hatchet on seeing the complainant the accused threatened that
he will not spare today so present applicant caused hatchet
blows on head of the complainant and right side of her
shoulder due to blows on different parts of the body the blood
was oozing, meantime complainant made cries where on the
cries one Rakhsha driver and brother of the complainant
attracted there and rescued the complainant, meantime
complainant immediately went at PS and got letter for
treatment thereafter complainant got shifted at PMCH
Nawabshah after getting free complainant came at PS and
lodged present FIR.

and applicant was arrested who is in judicial custody hence
this bail application on the following grounds
-: G R O U N D S :-

be ruled out.
172. That no such incident whets over stated in the FIR is ever took
with core connivance of her brother actual facts are that
complainant is lady of define nature and is groom type due to
matrimonial affairs she used to pressurize the applicant mere by
applying role of her brother complainant made present story by
alleging baseless assertions.
173. That as per the FIR the contents of the complainant are that
due to matrimonial affairs she got divorce from the
applicant/accused and now the complainant is willing to
occupy the house of the
[3]
applicant/accused with dint of force and with core connivance

of her brother in fact no such type of incident was ever taken
place whole story is managed one by the complainant just to
pressurize the applicant/accused and to occupying the house of
174. That 337-A(i) is bailable and compoundable however section

324 and section 337-(iv) was misapplied which are not attracting
to present case there is matter occupying the house of the
applicant/accused and to pressurize him otherwise applicant is
not concerned with alleged offence .
175. That the complainant is supported by political person and

with influence of her post as General Secretary of Women
Development she showed her efficiency to implicate the
applicant/accused in present case.
176. That all the PWs are setup persons as well as they are
interested witnesses of the complainant.

complainant

APPLICANT/ACCUSED

BENAZIRABAD
Cr, B. A. No: OF 2013.
Shan Alias Ali S/O Tofique Ahmed

Muslim Adult, Qureshi by caste
R/O Mohalla Esarpura Nawabshah
now confined ……………………………………………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

Nawabshah
OFFENCE U/S 371-A PPC.
BAIL APPLICATION

and grounds:-
-: F A C T S :-

Ali Mardan Lund of PS B-Section lodged his FIR on behalf of state
at PS B Section Nawabshah alleging therein that on the day of
incident he alongwith his subordinate staff vide entry No 07, dated
15-9-2013 at 9:20 hours, left PS for patrolling in the town after
patrolling from various places when they reached at stantasing
Colony Line Par Nawabshah they received spy information , on that
one Lady Mst Sughran Rajput R/O Dhobi Ghat Line par
Nawabshah is running brother and also deals with buying of ladies
of different places, in lieu of money and by now also some gents
and ladies are available in her house, with the result, he arranged
services of lady constable PC Farzana Memon alongwith other
police staff proceeded to pointed place, it is
[2]
further alleged that with the help of lady constable Farzana Memon
they saw the door of house was open and 3 ladies and one gent
were sitting who after seeing the police tried to escape but the
police tactfully apprehended them. During interrogation the gent
disclosed his name to be the applicant and during search nothing
was secured from him. The lady disclosed their names as Mst
Zohran W/O Gulzar Qureshi, R/O Ghulam Qadir Baloch Colony
Line par Nawabshah , Mst Sagheeran W/O Shahanshah Rajput
R/O Dhobi Ghat Lien par Nawabshah, Seema wife of Lalu Mochi
Taluka Daur District Shaheed Benazirabad. On inquiry they
allegedly disclosed that they were sitting there for purpose of
prostitution, hence this FIR
On 16-9-2013 the applicant/accused and co accused were

produced before the learned Civil Judge and JM-II who had
remanded in Jail custody the applicant is in Jail, Hence this Bail
application on the following grounds.
-: G R O U N D S :-

181. That the evidence available with the prosecution is

insufficient to connect the applicant with offence punishable
with death or life imprisonment.
182. That no any part is assigned to applicant .
183. That there is violation of 103 Cr PC.

184. That no search warrant was obtained to enter in a private
house premises.
185. That there is absolutely no evidence with regard to the

ingredients of section 371-A PPC.
[3]
186. That there is no medical evidence at all the applicant is no

more required for investigation.
187. That the case is of further inquiry.
188. That nothing has been recovered from the applicant/accused.
189. That the statement of the co-accused if any have got no value
in the eye of law as per article 38 of Qanun-e-shahadat 1984.
190. That it is admitted that the applicant has not been

apprehended performing any sexual act nor any money was
recovered from him. There is no any independent witness of
locality.

[M. Sharif Sial ]

APPLICANT/ACCUSED
BENAZIRABAD
B. A. No: OF 2013.
Ghulam Murtaza Shah son of Syed Moj Dariya Shah
Benazirabad……………………………………………
.Applicant/accused
VS
The State ……………….…………………………..………………

Opponent

OFFENCE U/S 23/A Sindh Crime Act
BAIL APPLICATION

and grounds:-
-: F A C T S :-

Raza Muhammad Khoso lodged his FIR at PS Daur on behalf of the
state on 16-8-2013 at about 14:00 hours, alleging therein that he
along with his subordinate staff left the PS vide entry No 5 dated
16-8-2013 at about 09:30 hours, in connection of investigation of
crime No 38/2013 under section 324, 337F(i) , 34 PPC of PS Daur
and during the patrolling the complainant of case crime NO 38 of
2013 namely Ghulam Qadir Shah and Mashirs Muhammad Rafique
Awan and Ghulam Shabir Shah met with them at Moro Road Daur
town who disclosed with the complainant party that required
accused of rime No 38/2013 namely Saiful Malooq alias Papi Shah,
Akbar Shah both sons of Ali Asghar Shah and Ghulam Murtaza
Shah son of Syed Moj Darya Shah the applicant /accused are
standing at Amerji Mori and are waiting for transport to go
somewhere.
[2]
The complainant alongwith his subordinate and private Mashir and

complainant of crime 38/2013 proceeded towards the pointed place
and reached there at about 13:00 hours and saw that three persons
were standing there who on seeing the police party in police mobile
tried to slip away but the complainant party stopped their vehicles
and tactfully arrested all the three accused persons in presence of
mashirs and inquired their name and address, the first person who
on the inquiry disclosed his name as Saiful Malooq Shah and
another person disclosed his name Akbar Shah both were searched
but nothing could be recovered from their physical possession and
the third person who disclosed his name to be the Ghulam Murtaza
Shah the applicant accused on his personal search police secured of
30 bore pistol alongwith magazine containing tow bullets form his
fold of Shalwar. The police inquired about the license about the
recovered pistol of 30 bore alongwith live bullets, who disclosed the
same to be the unlicensed, the complainant arrested all the three
accused persons in crime NO 38/2013 as well as the applicant was
arrested in offence under section 23/A Sindh crime Act and
prepared such Mashirnama and recovery and after signature of the
mashirs and after completing the whole proceedings the arrested
accused alongwith recovered articles were brought at PS where the
present FIR was registered against the applicant at PS Daur
After usual investigation the Police of PS Daur submitted

challaned before the competent court of law the applicant is in
judicial custody hence this bail application on the following
grounds.
-: G R O U N D S :-
193. That the case against the applicant/ accused is false and
applicant is innocent
194. That the alleged pistol alongwith its magazine containing tow
live bullets have been foisted upon the applicant by the
complainant with malafide intention just to show his efficiency
and oblige the complainant of main case of crime No 38 of 2013
otherwise nothing
[3]
has been secured from the applicant as alleged in the FIR and
Mashirnama of the arrest and recovery .
195. That the complainant of the main case and the injured witness
have patched up with the applicant and other co accused in
case/crime under section 38/2013 and as such case against the
applicant has become further inquiry.
196. That the PWs/ Mashir associated in the FIR are admittedly
setup persons of the complainant and are interested witness ever
otherwise parties have patched up in main case and there is no
possibility of conviction of the applicant accused in the present
case.
197. That case has been challaned and ht applicant/accused is no

more required to the police for further investigation and
remaining of the applicant in jail for indefinite period would not
serve any purpose of prosecution .
evidence as all the witnesses cited in the FIR are police official as
they are interested witnesses.
199. That there is no apprehension of absconsion of the applicant

as he is ready to furnish his solvent surety to the satisfaction to
this Honourable court.
200. That other grounds will be urged at the time of arguments
[AYAZ ALI GOPANG]

APPLICANT/ACCUSED
BENAZIRABAD
COVO REVISION NO OF 2013.
Atta Muhammad son of Haji Khan Mari

Muslim Adult R/O Chak No 5
Deh Suhelo Taluka Daur District Shaheed
Benazirabad
…………………………………………………………….Applicant
VS
1. Ali Muhammad son of Dilawar Khan

S/O Jhangli Khan Korai R/O Deh 10 Nusrat
Taluka Daur District Shaheed Benazirabad
Since dead through his LRs.
a. Liaqsat Ali Son
b. Fayaz Hussain Son
Both Adults, Muslims, R/O Deh 10 Nusrat Taluka Daur

2. Mir Muhammad Son of Mitho Khan Brohi Muslim Adult

Zamidar R/O Chak No 5 Deh Suhelo Taluka Daur District
Shaheed Benazirabad
3.Deputy District Officer Revenue Daur

4.Mukhtiarkar Revenue Daur
5.Sub Registrar Nawabshah
6.Province of Sindh to be served through the
District Officer Revenue Shaheed Benazirabad ……………………
Respondents
REVISION
UNDER SECTION 115 CPC
Being aggrieved and dissatisfied by the order

dated 23-4-2013 passed by the learned 1st Senior Civil Judge
Nawabshah of F.C suit No 960/2009 and Meer Muhammad VS Atta
Muhammad and others where by application under article 76,83,84
of Qanun-e-Shahadat order 1984 was filed by the applicant was
dismissed the applicant prefers this revision with a prayer that this
Honourable court may be pleased to call for the R & P of the above
matter from the court of learned 1st senior civil Judge Nawabshah
and after examining its legality and propriety set –aside the
impugned order and allowed th application of the applicant on
consideration of the following facts and grounds
AMENDED TITLE
BENAZIRABAD
COVO REVISION NO OF 2013.
Atta Muhammad son of Haji Khan Mari

Muslim Adult R/O Chak No 5
Deh Suhelo Taluka Daur District Shaheed
Benazirabad
…………………………………………………………….Applicant
VS
1. Ali Muhammad son of Dilawar Khan

S/O Jhangli Khan Korai R/O Deh 10 Nusrat
Taluka Daur District Shaheed Benazirabad
Since dead through his LRs.
a. Liaqsat Ali Son

b. Fayaz Hussain Son
Both Adults, Muslims, R/O Deh 10 Nusrat Taluka Daur

2. Mir Muhammad Son of Mitho Khan Brohi Muslim Adult

Zamidar R/O Chak No 5 Deh Suhelo Taluka Daur District
Shaheed Benazirabad
3. Deputy District Officer Revenue Daur
4. Mukhtiarkar Revenue Daur
5. Sub Registrar Nawabshah
6. Province of Sindh to be served through the

District Officer Revenue Shaheed Benazirabad ……………………
Respondents
REVISION
UNDER SECTION 115 CPC
ADVOCATE FOR THE APPLICANT
BENAZIRABAD
B. A. No: OF 2013.
Muhammad Hanif son of Muhammad

Anwar Chandio presently confined in Nara
Jail Hyderabad …………………………….. …...…
.Applicant/accused
VS
The State ……………….……………….……………..………………

Opponent

Ahmed
OFFENCE U/S 23/A Sindh Arms Act
2013
BAIL APPLICATION

-: F A C T S :-
Briefly facts leading to present case are that complainant SHO

Ghulam Hussain Dahri of PS Kazi Ahmed on 2-9-2013 at
about 19:00 hours alleging therein that on the day of lodging
the FIR complainant took out the arrested accused Asif Ali
and Hanif Chandio for interrogation purpose from the lockup
of the PS Kazi Ahmed and during the interrogation both
accused persons admitted their guilt before him and ready to
gave the crime weapons used in the commission of the offence
of murder, the complainant then left the PS along with his
subordinate staff and arrested accused vie entry No 18 dated
2-9-2013 at about 16:45 hours, and proceeded towards the
pointed place at about 17:20 hours they reached at Khairo
Fakeer graveyard where the accused Asif Ali and Hanif
Chandio asked the complainant to stop the mobile and they
both got down .

his
[2]
IN THE COURT OF 1ST SENIOR AND JUDICIAL MAGSITRATE
MORO
CR, MISC, APPLN, NO. OF 2014.

Manzoor Ali Memon
…………………………………………….Applicant
VS
Syed Sajid Ali Shah and others ………………………….Respondents
OBJECTIONS ON THE POINT OF MAINTAINABILITY
The objections on the point of maintainability on behalf of the

respondent NO 2 are very respectfully submits as under:-
1. That all the allegations leveled by the applicant against

respondent No 2 and his institution viz Ahal Albait School are
false and fabricated and managed one tend with malafide
intention and ulterior motive.
2. That applicant has not filed any single documents regarding his
entitlement and locus-standi to initiate the local proceedings
either criminal or civil before any forum, therefore very
applications filed by the applicant herein false and fabricated
and based on verbal verbatim nothing else.
3. That Ahl ALbait School is in existence since 25 years and is based

institution of locality which is registered one under the education
and literacy department of government of Sindh and is being
Supervised and run by the Asghria associates and welfare
society and during this period no any single of the citizen has
raised any objection on its ownership or any respect of any other
education or moral fact. Therefore filing of the application by the
applicant after long standing period of 25 years is looking to be
the false and fabricated one and very applications are liable to be
dismissed in liming, as the staff of
[2]
Ahl Albait is consisting upon 63 employees including teaching

staff out of which the daughter of applicant Manzoor Ali Mst
Tahmina Memon is also serving as a PST since 2008 and this
application has been filed by the applicant in order to give the
undue promotion and benefits of his daughter nothing else .
4. That even otherwise no any crime has been committed by the

any of the Opponent and instant application has been filed by
the applicant is under section 156 (3) Cr PC which is even
otherwise not maintainable at the law and the entitlement if any
with the applicant he has to approach to proper forum for
redressal of his alleged grievances .
5. That the applicant has filed the instant application in order to

blackmail the educational institution in shape of instant type of
application therefore it is very humbly prayed that very
application may be dismissed . so that no one came blackmail the
educational institution or other institution of country being
regulated by their owners .
Moro
Dated __________ MIR NAWAZ KALHORO
Advocate for the respondent No
2
F.C Suit No 371 of 2007
Bahawal khan son of Umed Ali Zardari ………………….

VS


order passed, on 10-3-2014 passed by this Honourable Court due to
which, this order has been obtained by way of fraud and
reproduced below.

Therefore, as per order that respondents No 1 to 3 have filed joined

statement but reality is that respondents No 1 was not present at the
time of passing order before this Honourable Court and attorney of
the respondents No. 1 having no power to compromise and
withdrawal of the case for which, for passing of this order of this
Honourable uncountable loss shall take place to respondent No 1
and his son hence this application
Prayed accordingly
Nawabshah
RESPONDENT NO 1
F.C Suit No 371 of 2007
Bahawal khan son of Umed Ali Zardari ……………………..

VS
AFFIDAVIT




of this affidavit.
34.That, applicant namely Bahawal Khan ahs obtained this order

passed 10-3-2014 by way of misrepresentation and fraud due
to which, as per order of this Honourable Court respondents
No 1 to 3 have filed joint statement duly signed by them but
reality is that at the day of passing of this order, respondent
No 1, was not present before this Honourable Court.
35.That, applicant namely Bahawal khan along with other

person have made misstatement before this Honourable Court
that parties have settled their dispute outside of the court and
entered into compromise, for which, it is a false statement due
to which, respondents No 1 resides in Qatar since long and he
having Qatar nationality and whole property of the
respondent No 1 have illegally been occupied by the present
applicant for which, attorney of the respondent No 1 having
also no authority to do compromise or withdraw the case.
Condition No 3 of the power of attorney is reproduced below.

otehrw3ise and to do all the acts that may be necessary
36.That, the applicant Ahmed son of Muhammad has already filed

an application under section 12 (2) CPC R/W 151 CPC before
2014 has been fixed , ( copy of the application 12 (2) alongwith
its affidavit and show cause notice of Honourable High Court are

more he has also mentioned in CPC that he having apprehension
according to law the Copy of the CPC is attached herewith as
annexure C.

above CPC filed by him as in person that he had no power to
39.That order may pleased be set-aside otherwise, we will suffer

irreparable loss and injury .

I know the deponent

Deponent
Advocate
Prayed accordingly.
Nawabshah
Dated ___________
VERIFICATION
[2]
3]. That on 23-12-2014 applicant was standing at his plot, situated
in Mujahid Colony Nawabshh alognwiht other labourer namely
Waseem son of Muhammad Aslam was also labourer of
Muhammad Yaqoob, where at about 4:00 PM, all proposed accused
arrived, while prposed accused Ghulam Mustafa and unknown
armed with pistols, proposed accused Hadi Bux and Ghulam Ali
carrying lathies and proposed accused Ghulam Muartaza having
Iron Rod and on arrival they abused the applicant and labourer
Waseem by saying so why they habve started work of cosntrutiosn
over the plot, but the construction was raising over the plot of
Muhammad Yaqoob which is adjacent plot of the applicant party,
on which applicant and Waseem replied that why they abused
them, which annoyed the proposed accused and proposed accused
Ghulam Murtaza caused Iron Rod blow to the Waseem to his right
wrist near the hand, who fallen down while raising cries, while
proposed accused ghulam Murtaz, Hadi Bux and Ghulam Ali
caused kicks and fists blows to applicant, meanwhile on hue and
cries of the applicant party, the Mohalla people Roshan son of
Shouban Solangi and others attracted there, and rescued the
applicant party from the clutches of proposed accused and after that
all the proposed accused went away while issuing murderious
threats to applicant.
4]. That thereafter applicant alognwiht above anmed PWs

brought the injured Waseem at poice station B-Section Nawabshah
and apprised whole the facts to the Opponent and requested for
registration of FIR and issurance of letter for medical treatment and
letter but Opponent became deaf and dump and due to influence of
proposed accused neither registerwed the FIR of the applicant nor
issued letter for the medical treatment and certificate of injured
besides this issued threats to applicant that is better for him to
remain silent otherwise he will face dire consequences, hence
applicant was left with no other alternate but to approach the
Honourable court with prayer
PRAYER
It is therefore prayed that this Honourable court may be
pleased to direct the SHO of PS B Section to register the FIR of the
applicant against the proposed accused persons and justice may
kindly be done with the applicant.
APPLICANT

BENAZIRABAD

VS
The State

Nawabshah
OFFENCE U/S 452, 363, 496-A, 498, 34
PPC
APPLICATION

pleased to Cancel the Bail Order passed on 3-7-2014 in favour
of the Noor Muhmamad and Abdul Razzak alias Motu and to
grounds:-
-: F A C T S :-

Muhammad Usman lodged his FIR at PS A Section
Nawabshah on 31-5-2014 at about 11:00 Hours , alleging
therein that he is married with the Mst Haleema aged about
46 years, ouit of this wedlock she gave birth 08 chidlren and
baby Sanam aged about 9 years is last one, his relative are
residing in District Snaghar, complainant and his relative are
vesting t3rms with Abdul Razzak alias Moto, Noor
Muhammad and Reheem Leghari, some time back the
complainant came to know that which he asked his wife to
not
[2]
talk with him. On 3-5-2014 at morning time as usual he went
to his job at PMC Nawabshah while leaving his brother Ali
Khan son fo Nadir Ali and other inmates were present in the
house, when at about 1:00 PM the compliannat came for lunch
at thwe same time he heard sound of vehicle and there was
knock on the door as soon as he opened the door the above
referred accused each Abdul Razak alias Moto with pistol ,
Noor Muhammad Leghari with pistol, Raheem Leghari and
one unknodied person who trespassed his house, who
straight their weapons upon them dyue to fear compliannt
remained silent the above accused kndiapped away his wicfe
and daughter Sanam saying so that Abdul Razzak alias Moto
will marry with his wife and went away in white colour coure
car, due to harassment he could noted the number of the Car
he further stated that his wife was with amouitn of Rs.
25000/- and she was worn with gold ornaments i.e Gold
Kangan , Gold Locket earning, he approached to BAdul razak
and his brothery for get return of his wife and daughter who
kept him on false hopes and later on refused to return them
hence this FIR.
After registering of the FIR applicants/accused Noor

Muhammaad and Razzak filed their bail application, before
this Honourbale court which was granted, after granting of
bail to the accused now both accused are not returning the
wife and daughter of the applicant they are detained in
private confinement of the both accused persons as there is
apprehension that wife and daughter of the complainant
might be killed by accused and now they are threatening the
complainant to come in thier terms otherwise he harm will be
caused to compliannat and abductees hence this present
application for cancellation of bail on the following grounds.
-: G R O U N D S :-
942. That order passed in favour of the applicants /accused

namey Noor Muammad and Abdul Razzak is against the
principle law and justice and equities.
943. That applicants/accused are clear crystal nominated in

the above FIR and they are hardened and criminal and
culprit.
[3]
944. That there was no possibility to granting the accused

persons on bail as since offence they have kept the wife and
daughter of the complainant in their detentions and are not
ready to release them.
945. That now contrary they are threatening the complainant

that if the complainant did not come in their illegal demands
and terms and furthermore threatened that if the complainant
did not patch up with forcefully with them then they will
cause the harm to his detained wife and daughter.
946. That criminal record in respect of the above case is

existed in the FIR but having the heinous shocking offence
accused were released on bail and grevancies of the
compliannat could be redressed by this Honourable court and
since offence he abductees are under pressure and threats of
the accused persons therefore such order of granting the bail
is liable to be cancelled and accused should be committed in
the custody of the police and inquiry may be made abouit
cruelties of the accused persons.
947. That after granting of bail to the accused now both

accused are not returning the wife and daughter of the
applicant they are detained them in private confinement of
the both accused persons as there is apprehension that wife
and daughter of the complainant might be killed by accused
and now they are threatening the complainant to come in
thier terms otherwise the harm will be caused to compliannat
and abductees.
948. That there is great apphresnion to the life of the

complainant and accused persons are behind the complainant
and in odd hours and other time are roaming with deadly
weapons just to give harm to the complainant.
949. That Bail order granted by this Honourable court may

kindly be cancelled otherwise complainant and abductees
will sustain harm by the hands of the accused.
950. That police has no interest with above case whereas

complainant
[4]
has lot expectations t o get justice from this Honourable court

and to get release the abductees from illegal detentions of the
accused persons.
951. That complainant has been threatened by the accused

persons that they are not providing foods and clothes to the
abductees and abductees are in troubles under wrongful
confinement of the accused persons.
952. That complainant is aggrieved party and they have

legally right to redressing their grevancies and accused may
kindly be committed in custody of the police and their bail
order may kindly be cancelled with interest of justice.

COMPLAINANT
BENAZIRABAD
VS
The State

Nawabshah
OFFENCE U/S 452, 363, 496-A, 498, 34
PPC
APPLICATION
It is respectfully submitted on behalf of the complainant that
this Honourable court may be pleased to record the statement of
abductee baby Sanam daughter of the applicant in above case crime
under section 164 Cr PC, as she yet has not been recorded her
statement, since loding of the FIR whereas, threats by the accused
have been/ are extending continually and applicant, abductee are
under apprehension therefore justice may kindly be done with
interest of justice.
This application may in the interest of justice

Bail Application

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IN THE COURT OF SESSIONS JUDGE SHAHEED

Kando son of Tooh Chandio

Crime No: 264/2019, P.S,Kazi Ahmed

ANTICIPATROY BAIL APPLICATION

It is prayed on behalf of the applicant/accused, that

Briefly facts leading to present case are that

After registering of the FIR, applicant/accused was

2. That admittedly FIR is delayed about one day without furnishing

3. That it is further worth to mention here that, the complainant

4. That it is further worth to mention here that, complainant party

5. That place of incident shown by the complainant is very thickly

6. That there is no specific role, part injury on the other

7. That at the time of alleged incident, applicant/accused was not

8. That applicant/ accused is not hardened criminal nor desperate

9. That applicant/ accused possessed good reputation in his

10.That it is well settled principle of law that if a single doubt arose

11.That there is no any previous criminal record against the

12.That PWs cited in the FIR, he is pocket person and subordinate

13.That there is no appreshanssion of tempering with the evidences

14.That applicant/accused is ready to furnish solvent surety to the

15.That orther ground will be urged at the time of arguments.

This is Certify that this is 1st Pre Arrest Bail

ADVOCATE FOR APPLICANT/ACCUSED

Naseer Ahmed son of Rehmo Ghori

The State…………….……… .…………………………Opponent

Crime No: 72/2019, P.S, Bandhi

It is prayed on behalf of the applicant/accused, that this

Briefly facts leading to present case are, that

After registration of the FIR, applicant/accused was

1. That the case registered against the applicant/accused is false

and fabricated one he has committed no any alleged offence but

2. That in fact no such incident, whatsoever stated in the FIR has

applicant/accused, otherwise he has no concerned with the

4. That complianant failed to associate independent witnesses

having the populed area there is voialtion of 103 Cr PC.

5. That all sections applied in the FIR are bailable.

complianant and are sweet obligor.

this whole drama has been staged by the complainant with

8. That there is no apprehension of the tampering with the

evidence, as all the PWs are sweet obligor of the complainant.

9. That applicant accused is ready to furnish solvent surety to the

satisfaction of this Honourable Court.

10. That other grounds will be urged at the time of arguments.

DATED__________ ADVOCATE FOR

This is to certify that this is first bail application of

Advocate for applicant/accused

IN THE COURT OF SESSIONS JUDGE SHAHEED

Aslam son of Shahmeer Chandio

Crime No: 27/2019, P.S, Pubjo

It is prayed on behalf of the applicant/accused,

After registration of FIR, applicant/accused was

17.That admittedly FIR is delayed more then 7 days, without

19.That it is surprisingly worth to mention here that, complainant

brother of complainant, neither complainant caused any injury nor

20.That place of incident shown by the complainant is very thickly

21.That no injury is on the part of the cousin of complainant,

22.That applicant/ accused is not hardened criminal nor desperate nor

23.That applicant/ accused possessed good reputation in his vicinity.

25.That no any injury sustained by the brother of complainant or

26.That medical certificate if obtained by the complainant party same

27.That there is no any previous criminal record against the applicant/

28.That PWs cited in the FIR, he is pocket family member of

29.That there is no appreshanssion of tempering with the evidences as