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IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No. _____________B/2002

Zahid Mehmood S/o Basheer-ul-Haq, caste Sangi, R/o H. No. 5/E,


Opposite Police Station Lohari Gate, Multan.
……PETITIONER
VERSUS
The State. ……RESPONDENT

BAIL PETITION U/S 497/498 CR.P.C.

In Case: -
F.I.R. No. 87/2002 Dated: 6.5.2002
U/s: 3/4, 4/79 P.O.
P.S. Lohari Gate, Multan.

Respectfully Sheweth: -

1. That the names and addresses of the parties have correctly


been given for the purpose of their summons and citation.

2. That the allegation against the petitioner is that on the


pointation of the petitioner, police recovered three crates of
liquor from his drawing room (Baithak). In one crate, there
were 70 bottles (Kuppies) and the remaining two crates
contained 25 bottles (Kuppies) each. Copy of F.I.R. is
attached as Annex “A”, whereas better copy is Annex “A/1”.

3. That the petitioner was sent to judicial lock up on the next


day. The petitioner filed a bail petition for the grant of post-
arrest bail in the Court of Judicial Magistrate, which was
disagreed vide order dated 27.6.02. Copy of the order is
Annex “B”.
4. That the petitioner filed a petition before the learned Sessions
Judge with the same request. This petition was entrusted for
further hearing to the Court of Mr. Javaid Mahmood Sindhu,
the learned Additional Sessions Judge, Multan; and the
petition was dismissed vide order dated 19.7.02. Copy of the
order is Annex “C”.

5. That the petitioner is entitled for the grant of post-arrest bail


inter-alia on the following:

GROUNDS

i) That orders of both the courts below are against the law
and facts of the case.

ii) That both the learned courts miserably failed to assess


the material required for the insertion of Article 3 of
Prohibition Ordinance IV of 1979 in the F.I.R.

iii) That there is no evidence available in respect of


Article-3 on the file and insertion of the same in the
F.I.R. is nothing but a mockery of law.

iv) That the ulterior motive and malafide of police is fully


transpired from the narration of the F.I.R., because
simultaneously the police tried to involve the other two
brothers of the petitioner as well.

v) That it was plea of the petitioner that the required


material is neither liquor nor it is a kind of liquor.

vi) That it was a kind of mild siprit which is used by the


doctors to intermix the medicines.

vii) That the plea of the petitioner was fortified by the


result of Chemical Examiner.

viii) That Article 4 of the Prohibition Ordinance IV of 1979


having the punishment of 2 years is a bailable one.
ix) That the petitioner is innocent and case against the
petitioner is a case of further inquiry.

x) That the petitioner is behind the bar since the date of


arrest and the further detention of the petitioner could
not serve a useful purpose, even it will be a punishment
in advance.

xi) That the investigation of the case is complete and the


person of the petitioner is no more required for further
investigation.

xii) That the petitioner is neither a previous convict nor


having previous record.

In view of the above submissions, it is


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

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

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

Crl. Misc. No. _____________B/2002

Zahid Mahmood Vs The State

INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Bail Petition.
3 Copy of F.I.R. alongwith better copy. A & A/1
4 Copy of order dated 27.6.2002 B
5 Copy of order dated 19.7.2002 C
6 Dispensation Application.
7 Power of attorney.

PETITIONER
Dated: __________

Through: -

Hammad Afzal Bajwa, Sheikh Muhammad Faheem,


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

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


In
Crl. Misc. No. _______B/2002

Zahid Mahmood Vs The State

APPLICATION FOR DISPENSING WITH THE


FILING OF CERTIFIED COPY OF THE ANNEX.
========================================

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

2. That certified copy of Annex “A” is not readily available.


However, uncertified/photo state copy of the same has been
annexed with the petition, which is the true copy of the original
document.

It is, therefore, respectfully prayed that this


Hon’ble court may please dispense with the filing of
aforesaid copy of the document.

APPLICANT,
Dated: __________

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