BEFORE THE HONOURABLE LAHORE HIGH COURT, LAHORE

Protected Bail Petition No. _____/23

___________________________
…Petitioner

Versus

THE STATE
…Respondent

FIR No. __________________
Offences Under: __________________
Police Station: __________________
Date of Occurrence: __________________
Date of Registration of FIR: __________________

APPLICATION FOR GRANT OF PRE-ARREST PROTECTED BAIL UNDER SECTIONS 497 & 498 Cr.P.C.

Respectfully Sheweth:

1. That the Petitioner has been falsely implicated in a criminal case by the complainant with mala fide intent and ulterior motives.

2. That the allegations leveled in the FIR are fabricated, baseless, and do not correspond with any actual incident.

3. That the FIR has been registered in collusion with the local police and is aimed at harassing and pressurizing the Petitioner.

4. That no offence, as alleged, was ever committed and the FIR is the result of personal enmity and vendetta.

5. That the allegations in the FIR are vague and lack material particulars to connect the Petitioner with the commission of any offence.

6. That the FIR appears to be a retaliatory move due to an existing civil dispute between the parties.

7. That there is a clear delay in the registration of the FIR, which casts serious doubt upon the veracity of the prosecution’s version and points towards ulterior motives.

8. That the matter requires further inquiry as contemplated under Section 497(2) Cr.P.C.

9. That the Petitioner is a law-abiding citizen with no previous criminal record and there is no apprehension of absconding or misuse of bail, if granted.

10. That the bare perusal of the FIR and available material reveals that no reasonable grounds exist to believe that the Petitioner has committed a non-bailable offence.

11. That the Petitioner apprehends imminent arrest, and due to threats and harassment, is unable to safely approach the court of competent jurisdiction without protection from this Honourable Court.

12. That the Petitioner seeks limited protective relief solely for the purpose of approaching the Court of competent jurisdiction for pre-arrest bail.

13. That the Petitioner undertakes to furnish surety to the satisfaction of this Honourable Court.

PRAYER

In view of the above submissions, it is most respectfully prayed that this Honourable Court may graciously be pleased to grant protected pre-arrest bail to the Petitioner, enabling them to approach the Court of competent jurisdiction in the interest of justice, equity, and fair trial.

 
Petitioner
Through Counsel:
_________________________
Advocate High Court
_________________________ Law Associates
(Address)

CERTIFICATE

Certified that as per instructions, this is the first petition for protected bail filed before this Honourable Court.

Advocate

BEFORE THE HONOURABLE LAHORE HIGH COURT, LAHORE

Protected Bail Petition No. _____/20

_________________________
…Petitioner

Versus

THE STATE
…Respondent

AFFIDAVIT

I, _____________________, son of _____________________, resident of ______________________________, do hereby solemnly affirm and declare as under:

1. That I am the Petitioner in the accompanying application and am fully conversant with the facts stated therein.

2. That the contents of the accompanying application for protected bail are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

 
DEPONENT

VERIFICATION

Verified on oath at ___________ this ___ day of ________, 20, that the contents of the above affidavit are true and correct to the best of my knowledge and belief.

 
DEPONENT