Application for Cancellation of Bail

IN THE court_type, district

Application No. _____ of year

The State / moving_party_designation ... Applicant

VERSUS

bail_recipient_name, son/daughter of bail_recipient_father, resident of bail_recipient_address, holding CNIC No. bail_recipient_cnic ... Respondent

APPLICATION UNDER SECTION 497(5) OF THE CODE OF CRIMINAL PROCEDURE 1898 FOR CANCELLATION OF BAIL

Respectfully sheweth:

1. That this application is filed by moving_party_designation against the above-named Respondent for cancellation of bail granted in FIR No. fir_number, Police Station police_station, district.

2. That on bail_grant_date, bail was granted to the Respondent by bail_granting_court in the aforementioned criminal case on bail_conditions.

3. That subsequent to grant of bail, the Respondent has breach_of_conditions. The Respondent has flagrantly violated the conditions imposed by the Court in the bail order.

4. That the Respondent intimidation_or_evidence_tampering. There is strong evidence that he/she has nature_of_breach.

5. That the Respondent has absconded and failed to appear before the Court on date_of_non_appearance. This constitutes a clear breach of bail conditions and demonstrates the Respondent's flight risk.

6. That additional_ground, which is a ground enumerated under Section 497(5) CrPC for cancellation of bail.

7. That in view of the serious breach of bail conditions and the gravity of the charges, it is in the interest of the administration of justice that the bail granted to the Respondent be cancelled forthwith.

8. That under Section 497(5) CrPC, the Court which grants bail has the power to cancel the same on the application of the State or the complainant on grounds including breach of bail conditions and probability of absconding.

9. That this Honourable Court has territorial and pecuniary jurisdiction to entertain and decide the present application.

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) Cancel the bail granted to the Respondent in FIR No. fir_number, Police Station police_station, district;

(b) Direct the issuance of non-bailable warrant of arrest against the Respondent;

(c) Direct the police to apprehend and bring the Respondent into custody; and

(d) Grant such further and other relief as may be 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 9 of the above application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ moving_party_name moving_party_designation Through: _____________________________ counsel_name Advocate