Accountability Court / High Court · National Accountability Ordinance 1999, Section 9 read with Section 497 CrPC
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IN THE ACCOUNTABILITY COURT, district
Petition No. _____ of year
petitioner_name, son/daughter of petitioner_father, resident of petitioner_address, holding CNIC No. petitioner_cnic ... Petitioner
VERSUS
1. The Director General, National Accountability Bureau, through his/her authorized representative 2. The State, through the Prosecutor, National Accountability Bureau ... Respondents
PETITION FOR GRANT OF BAIL UNDER SECTION 9 NAB ORDINANCE 1999 READ WITH SECTION 497 CrPC
Respectfully sheweth:
1. That the Petitioner is an innocent citizen of Pakistan who has been arrested on arrest_date by the National Accountability Bureau in case FIR No. nab_fir_number/nab_fir_year registered at NAB Inquiry inquiry_number.
2. That the Petitioner was accused of the following offence: offence_description, allegedly constituting corruption under the National Accountability Ordinance 1999.
3. That despite thorough interrogation by NAB officials spanning interrogation_period, no recovery of any asset or document material to the allegations has been made from the Petitioner's custody.
4. That the Petitioner is a person of impeccable character and has been engaged in occupation for the past years_occupation years. He/she is known in his/her locality as a respectable and law-abiding citizen.
5. That bail is sought under Section 9 NAB Ordinance, which permits bail where the Accountable Person satisfies the requirements of Section 497 CrPC. The burden is on the prosecution to show grounds for continued detention.
6. That the Petitioner has deep roots in the community, permanent residence, family dependents, and no history of absconding or criminal conduct. He/she is not a flight risk.
7. That the allegations are allegation_characterization and the prosecution has failed to establish any prima facie case against the Petitioner through substantive evidence during the interrogation period.
8. That continued detention serves no lawful purpose of investigation as further inquiry into inquiry_matter cannot be conducted through custodial detention of the Petitioner.
9. That the Petitioner is willing to furnish a surety in the sum of Rs. surety_amount and provide such conditions as this Honourable Court deems fit.
LIMITATION: This bail application is filed within the prescribed period and at the appropriate stage of proceedings, with no prior bail application pending before any other forum, save and except as disclosed herein.
PRAYER
It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:
(a) Grant bail to the Petitioner under Section 9 NAB Ordinance read with Section 497 CrPC;
(b) Fix appropriate bail amount and surety terms as per law;
(c) Direct NAB to release the Petitioner forthwith upon furnishing surety; and
(d) Grant such further and other relief deemed just and proper in the circumstances.
VERIFICATION
Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of paragraphs 1 to 9 of the above petition are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.
_____________________________ petitioner_name Petitioner Through: _____________________________ counsel_name Advocate
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