In the court of learned Judicial Magistrate Changa Manga.

In Re:- Zahoor Ahmad Alias Ladoo son of Muhammad Din by cast nomuslim sheikh, resident of 33 chack tehsil chunian.

(Petitioner) VS State. (Respondent)

Case : Dated: Offence: Police Station Fir No 64/2012 08-02-2012 3/4 of the prohibition order 1979. Changa Manga.

Petition under section 497 Cr.P.C for grant of post arrest bail. Respectfully sheweth:1:- That allegation against the petitioner as stated in abovementioned FIR are that in a raid was conducted after gaining spy information which resulted into the recovery of liquire and some household pots. Copy the F.I.r is attached with as annexture 1. 2:- That petitioner is innocent, hence prayes for bail on the following :GROUNDS. A) That the petitioner has been falsly implicated in this case, there is no truth in the said story. The alledged raid conducted was in daylight time and it was at a busy public place but surprisingly there was no independent civil witness which shadows the case with doubts. B) That the petitioner has been sent to judicial lockup and hence no more required to the police for any kind of further investigation. C) That the investigation has been completed. Petitioner is no more required to the police ; so there is no usefull purpose to keep him behind the bar. D) That petitioner has a grand family and he is the only breadwinner of the family, his family is under constant pressure and facing problems after his arrest. E) That Petitoner has been enroped in the abovementiond case without waiting chemical examiners report. F) That maximum sentence provided in the Law for the offence under section 3 of the abovementioned Order is five year, whereas section4 of the order is bailable, therefor petitioner's case does not fall within the prohibitory clause of section 497 Cr.P.C so grant of bail is a rule an refusal is an expection. referance can be invited to the following case laws. PLD 1995 SC 34 PLD 1997 SC 545 G) That petitioner is ready to furnish the surety bonds to the satisifaction of this honorable

Court. For what has been submitted above it is respectfully prayed that by allowing this bail petition the petitioner may very kindly be admitted to and enlarged on bail till the final decision of the case. PETITIONER THROUGH COUNSEL. MIAN ARSHID FAROOQ Advocate CHUNIAN.