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IN THE COURT OF ADDITIONAL SESSIONS JUDGE

TAXILA

Muhammad Rafique S/o Muhammad Yaqoob, caste Awan

R/o Dhoke Nadir, Dakhli Thatta Khalil, Tehsil Taxila
District Rawalpindi.
(Presently confined into Adiala Jail Rawalpindi).

………….Petitioner

Versus

The State
………Respondent

PETITION FOR BAIL AFTER ARREST U/S

497 Cr.P.C. IN CASE FIR NO. 244 DATED
26.05.2013, REGISTERED AT P.S. TAXILA,
UNDER ARTICLE 3/4 PEHO-1979.

Respectfully submitted:-

1- That petitioner has been falsely implicated in the

above mentioned case and presently, he is confined

into District Jail Adiala Rawalpindi.

2- That it has been alleged in the FIR that upon

advance spy information, a barricade was put and

present petitioner who was coming on a motorcycle,

was checked and apprehended and allegedly 2 bags

each containing 50 Kupees/bottles were recovered

from the present petitioner.

3- That the petitioner is quite innocent having no

nexus with the alleged liquor.

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4- That nothing has been recovered from the

petitioner and alleged recovery is planted one.

5- That the petitioner has been roped in this case

by the local police with malafide intention and

ulterior motives.

6- That the police did not associate any private

witness for the alleged recovery and thus violated

mandatory provisions of law.

7- That in circumstances, case against petitioner

falls under the ambit of further inquiry.

8- That offence mentioned above does not fall

within the prohibitory clause of Cr.P.C and in such

like cases, grant of bail is a rule and refusal an

exception.

9- That investigation into the case is complete in all

respects and person of the petitioner is no longer

required for the purposes of further investigation.

10- That petitioner belongs to a respectable family,

has the blotless career and is also a previous non-

convict.

11- That petitioner preferred his bail petition before

the learned Area Magistrate who dismissed the

same without any cogent and lawful reason.

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12- That petitioner is ready to furnish adequate

surety to the entire satisfaction of this honourable

court.

It is therefore, respectfully prayed that

petitioner may kindly be admitted to

Post Arrest bail till final disposal of the

case.

PETITIONER
` Through

SAMINA KOUSAR
Advocate High Court
Date: 08-06-2013

CERTIFICATE:
Certified that this is first post arrest
bail petition moved before this
honourable court.

Counsel