Application for Recall of Warrant

IN THE COURT OF THE LEARNED JUDICIAL MAGISTRATE, district

Application No. _____ of year

applicant_name, son/daughter of applicant_father, resident of applicant_address, holding CNIC No. applicant_cnic ... Applicant

VERSUS

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

APPLICATION UNDER SECTION 70 OF THE CODE OF CRIMINAL PROCEDURE 1898 FOR RECALL OF WARRANT OF ARREST

Respectfully sheweth:

1. That the Applicant is a law-abiding citizen of Pakistan and is filing the present application with bona fide intent and clean hands to seek recall of the non-bailable warrant of arrest issued against him/her by this Honourable Court.

2. That this Honourable Court, by order dated warrant_date, issued a non-bailable warrant of arrest against the Applicant in case_title, Case No. case_number, on the charges of charges.

3. That since the issuance of the said warrant, circumstances have materially changed. The Applicant now seeks to attend Court voluntarily and cooperate with judicial proceedings.

4. That the Applicant has no criminal antecedents and is deeply rooted in the community. He/she has substantial immovable property and family ties in district, rendering him/her unable and unwilling to abscond.

5. That the charges against the Applicant are characterization_of_charges in nature. The evidence against him/her is nature_of_evidence and does not disclose a strong prima facie case.

6. That the Applicant's wilful and voluntary appearance before this Honourable Court would serve the ends of justice more effectively than continued issuance of the warrant, which causes unnecessary hardship and harassment.

7. That under Section 70 CrPC, this Honourable Court has discretionary power to recall a warrant when the Applicant appears before the Court and satisfies it that the warrant ought to be recalled.

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

PRAYER

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

(a) Recall the non-bailable warrant of arrest issued against the Applicant dated warrant_date;

(b) Permit the Applicant to appear before this Honourable Court voluntarily and participate in the trial in person or through counsel;

(c) Grant the Applicant regular bail on such terms and conditions as this Honourable Court deems fit; and

(d) Grant any 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 application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ applicant_name Applicant Through: _____________________________ counsel_name Advocate