IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No. _____________B/2003

Muhammad Azam S/o Muhammad Ramzan, caste Baloch, R/o

Mauza Doran Wala, Tehsil & District Lodhran.

……PETITIONER

VERSUS
The State. ……RESPONDENT

POST-ARREST BAIL PETITION U/S 497 CR.P.C.

In Case: -
F.I.R. No. 201/2003 Dated: 17.05.03
U/s: 6/7-B.G, A.T.A. P.S. City, Lodhran.

Respectfully Sheweth: -

1. That the names and addresses of the parties have correctly

been given for the purpose of their summons and citation.

2. That the instant case was registered on the application of one

Mujeeb-ur-Rehman, stating therein that he is a Naib
Mohtamim and resident of Mudarsa Darul Hadis
Muhammadia, while the accused Muhamamd Azam S/o
 Muhammad Ramzan is a criminal, having record and there
are many cases in different police stations against him. He
committed high-handedness with different people and also
receiving BHATTA ( ) by force. The said Azam now-a-
days is out of the jail and has started his illegal and unlawful
activities again. The complainant by grace of Allah is a well
off person and the accused in the presence of witnesses,
demanded BHATTA from the complainant, on which the
accused was advised, but the accused did not act upon. On
9.5.03 at the time of Asar prayer, when there were many
prayer observers present, accused Muhammad Azam along-
with two unknown persons came to Madarsa, demanded
Rs. 400,000/- as BHATTA pointed weapons and started stone
pelting. The people present on the spot cool down the
situation, but on the return, accused Azam extended threats
that he will not allow any religious gathering in the Madarsa.
Due to this action of accused Azam, the people of
complainant’s community felt themselves unsecured. The
accused also uttered indecent sentences against the
community of complainant, hence, this F.I.R. Copy of F.I.R.
and better copy are attached as Annex “A & A/1”.

3. That the petitioner applied for the post-arrest bail in the court
of competent jurisdiction, but the same was refused on the
ground that the challan had been put up in the court. Copy of
order dated 13.6.03 is Annex “B”.

4. That the petitioner is entitled for the grant of post-arrest bail

inter-alia on the following: -

GROUNDS

i) That the F.I.R. is registered due to malafide & ulterior

motive, while the petitioner is wrongly roped up in the
case.
ii) That the complainant and his brothers prepared a
forged document for the agricultural land of Ghulam
Qadir, the real uncle of the petitioner. A civil litigation
started between them, while the petitioner was helping
his uncle and saving him from the high-handedness of
the complainant and his brothers. The complainant
party in any case wanted to take revenge of this help.

iii) That the real brother of the complainant Abdul Wahhab

lodged an application before the police on which the
proceedings U/s 107/151 Cr.P.C. were initiated against
the petitioner. Copy of Kalandra is Annex “C”.

iv) That there is an unexplained delay of one week for the

registration of the case.

v) That the petitioner remained on physical remand for a

sufficient period, but nothing was recovered from the
petitioner.

vi) That the contents of F.I.R. do not disclose the formation

of any offence under Ant-Terrorism Act rather depict
the element of personal enmity.

vii) That the maximum punishment of the offences

mentioned in F.I.R. is five years, which does not attract
the prohibitory clause of 497 Cr.P.C.

viii) That the petitioner is behind the bar since last more
than four weeks and the further detection of the
petitioner could not serve any useful purpose.

ix) That the investigation of the case is complete and the

person of the petitioner is no more required.

x) That the case against the petitioner requires further

probing and case is of further enquiry.
 In view of the above submissions, it is
respectfully prayed that petition in hand may
please be accepted and the petitioner may
graciously be ordered to be released on bail.

Any other relief which this Hon’ble Court

deems fit, may please be granted in the interest
of justice.

Humble Petitioner,
Dated: ________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first post-arrest bail petition
of the petitioner. No such petition has earlier
been filed before this Hon’ble Court.

Advocate
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

Crl. Misc. No. _____________B/2003

Muhammad Azam Vs The State

INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Bail Petition.
3 Copy of F.I.R. along-with better copy. A & A/1
4 Copy of order dated 13.6.2003. B
5 Copy of Kalandra. C
6 Power of attorney.

PETITIONER
Dated: __________

Through: -

Hammad Afzal Bajwa, Sheikh Muhammad Faheem,

Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176