Application for Acquittal under Section 249-A CrPC

IN THE COURT OF THE LEARNED MAGISTRATE, district

Criminal Case No. case_number of year

accused_name, son/daughter of accused_father, resident of accused_address, holding CNIC No. accused_cnic ... Accused

VERSUS

The State and complainant_name, son/daughter of complainant_father, resident of complainant_address ... Respondents

APPLICATION FOR ACQUITTAL UNDER SECTION 249-A OF THE CODE OF CRIMINAL PROCEDURE 1898

Respectfully sheweth:

1. That the Accused is charged with the offence(s) of penal_section of the Penal Code 1860 on the basis of the FIR registered at Police Station police_station, district. The trial is pending in this Honourable Court.

2. That the charge framed against the Accused is wholly groundless and unsupported by any credible or sufficient evidence. The Accused respectfully submits that at the present stage of the trial, there is no material on record to establish the allegations.

3. That the prosecution has wholly failed to establish even a prima facie case against the Accused. The evidence led by the prosecution is evidence_quality and does not satisfy any ingredient of the alleged offence.

4. That specific_grounds and therefore the charge against the Accused is manifestly groundless.

5. That the prosecution witnesses have deposed in a manner which is witness_issues and their testimony cannot form a reliable basis for conviction.

6. That the Accused has offered a satisfactory explanation which has not been effectively rebutted by the prosecution evidence.

7. That this Honourable Court has the jurisdiction and authority under Section 249-A CrPC to acquit the Accused at any stage if the charge is found to be groundless.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:

(a) Allow the present application under Section 249-A CrPC;

(b) Acquit the Accused of the groundless charges levelled against him/her; and

(c) Grant such further and other relief deemed just and proper in the circumstances of the case.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of paragraphs 1 to 7 of the above application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ accused_name Accused Through: _____________________________ counsel_name Advocate