Pre-Arrest Bail Application

IN THE court_type, district

Petition No. _____ of year

petitioner_name, son/daughter of petitioner_father, resident of petitioner_address, holding CNIC No. petitioner_cnic ... Petitioner

VERSUS

1. complainant_name, son/daughter of complainant_father, resident of complainant_address 2. The State, through SHO, Police Station police_station, district ... Respondents

PETITION UNDER SECTION 498 OF THE CODE OF CRIMINAL PROCEDURE 1898 FOR GRANT OF ANTICIPATORY BAIL

Respectfully sheweth:

1. That the Petitioner is an innocent citizen of Pakistan and files the present petition with bona fide intent to seek protection from wrongful arrest in a cognizable offence. The Petitioner has apprehension that on the basis of false and malicious allegations made by Respondent No. 1, a First Information Report (FIR) may be registered against him/her.

2. That on date_of_incident, the following alleged incident took place:

facts

3. That the allegations levelled against the Petitioner are wholly false, frivolous, and motivated. Respondent No. 1 has made these allegations with mala fide intent and ulterior motives to harass and extort the Petitioner.

4. That the offence allegedly committed, as per the particulars communicated to the Petitioner, does not fall within the definition of any cognizable offence under the Penal Code 1860 or any other law. No recovery of any property or object is alleged or sought by the complainant.

5. That Respondent No. 1 has a history of criminal antecedents and is known for filing false complaints. His/her allegations are not corroborated by any credible evidence or independent witnesses.

6. That the Petitioner has no criminal antecedents and is a respectable member of society. He/she is deeply rooted in his/her residential area and has no likelihood or motive to tamper with prosecution evidence or abscond.

7. That the FIR, if registered, would be mala fide and an abuse of the process of law. The Petitioner, fearing wrongful arrest and harassment, seeks anticipatory bail as a precaution.

8. That this Honourable Court has ample powers under Section 498 CrPC to grant anticipatory bail in cases where apprehension of arrest is imminent and reasonable. Such bail would serve the ends of justice.

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 pre-arrest bail to the Petitioner under Section 498 CrPC on such terms and conditions as this Honourable Court deems fit;

(b) Direct the police not to arrest the Petitioner on the basis of any complaint by Respondent No. 1 without the prior permission of this Court; 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 8 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