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    Bail Before Arrest U S 489

    Uploaded by

    Yasir Khan
    1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

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    © All Rights Reserved
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    Bail Before Arrest U S 489

    Uploaded by

    Yasir Khan
    161 views3 pages
    1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

    Original Description:

    format for bail

    Original Title

    BAIL-BEFORE-ARREST-U-S--489-

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    1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    161 views3 pages

    Bail Before Arrest U S 489

    Uploaded by

    Yasir Khan
    1. Ajaz Hussain has filed a petition for bail before arrest in the Court of Sessions Judge Islamabad against an FIR registered under section 489-F PPC by Police Station Aabpara, Islamabad. 2. Ajaz claims the FIR was registered with malafide intentions due to a delay in lodging the complaint and that the essential ingredients of the offense are missing as the cheque was issued without consideration. 3. Ajaz further states that he is a previous non-convict and the case is fit for bail as per law. He prays that the court grants him bail before arrest.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    [1]

    IN THE COURT OF SESSIONS JUDGE,


    ISLAMABAD

    Ajaz Hussain S/o Ghulam Hussain R/o house no.10,block no. 90-
    B,Sec G-9/2, Tehsil & District Islamabad
    … Petitioner
    Vs.
    The State
    … Respondent

    FIR NO. 209 DATED 01.07.2013


    U/S 489-F P.P.C.
    P.S. AAbpara, ISLAMABAD.

    PETITION UNDER SECTION 498 Cr. P.C. FOR BAIL


    BEFORE ARREST

    Respectfully Sheweth:

    1. That the petitioner has been falsely implicated in the case,


    particulars of which have been given above in detail.

    2. That very registration of instant FIR is based on malafide on


    part of the complainant as well as police.

    3. That there is inordinate delay in lodging FIR for which no


    justification, whatsoever, has been given in the FIR. Delay is
    fatal to case of prosecution if not explained, as in this case, and
    sufficient to prove malafide on part of the complainant.

    4. That the Cheque in question has been rendered without


    consideration and the main ingredients which must exist to
    constitute offence under section 489-F ppc i.e., consideration,
    dishonest issuance of cheque, are missing in the instant case.

    5. That it is the civil court which has to determine the rights of the
    parties. The complainant has tried to convert a civil dispute into
    a criminal one.
    [2]

    6. That the police is behind the petitioner for his arrest due to
    ulterior motives and if petitioner arrested in hands of police it
    will result into humiliation and unjustified harassment to him.

    7. That the petitioner is previous non-convict and has unblemished


    past to his credit. The offences leveled in the FIR do not fall
    within the prohibitory clause of Section 497 Cr. P.C. and in
    such like cases bail is ruled and no exceptional circumstance
    exist in this case.

    8. That case of the petitioner is one of further inquiry; hence


    petitioner is entitled for bail as of right.

    It is, therefore, respectfully prayed that this Honourable Court


    may very graciously be pleased to admit the petitioner to bail before
    arrest till final decision of the instant case.

    Further prayed that ad-interim pre arrest bail may also be


    granted till final disposal instant petition.

    Petitioner

    Through

    Ch. Abdul Rehman Bajwa


    Advocate High Court
    Islamabad
    Certificate:

    Certified that this is the first petition for


    bail before arrest being filed in this
    Honourable Court. No other bail petition
    of the petitioner is pending at any other
    forum as per information furnished by
    the petitioner.

    Counsel
    [3]

    IN THE COURT OF SESSIONS JUDGE,


    ISLAMABAD

    Ajaz Hussain Vs. The State

    FIR NO. 209 DATED 01.07.2013


    U/S 489-F P.P.C.
    P.S. AAbpara, ISLAMABAD.

    PETITION UNDER SECTION 498 Cr. P.C. FOR BAIL


    BEFORE ARREST

    AFFIDAVIT

    I, Ajaz Hussain S/o Ghulam Hussain R/o house no.10,block no.


    90-B,Sec G-9/2, Tehsil & District Islamabad do hereby solemnly
    affirm and declare on Oath that contents of accompanying bail
    petition are true and correct to the best of my knowledge and belief
    and nothing has been concealed therefrom.

    DEPONENT
    VERIFICATION:

    Verified on Oath that contents of my above affidavit are true


    and correct to the best of my knowledge and belief and nothing has
    been concealed therefrom.

    DEPONENT

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