B.A 497 U/S 13D

IN THE COURT OF IIND CIVIL JUDGE AND J.M DADU

           Crl. Case No.                of 2016

            Bail Application No.     of 2016

Waheed Ali S/o Muhammad Soomar

Solangi R/o Village Pachooha Taluka

Dadu Muhalla Dadu, Now confined in

District Jail  Dadu………………….…...……Applicants/accused.

                            V E R S U S

The State…………………………………..…..Opponent.

                                          Crime No. 53 of 2014

Police Station Dadu

U/S 13-D.  A.O               .

                  

       CRIMINAL BAIL APPLICATION U/S 497 OF

    CRIMINAL PROCEDURE CODE 1898

                      It is humbly and respectfully prayed on behalf of the above named applicants/accused that this honorable court may kindly be pleased to admit him on bail in the above mentioned crime and offences, pending trial before this Honorable Court on the consideration of the following facts and ground :-

FACTS.

                Complainant ASI Ghulam Rasool Soomaro lodged FIR alleging therein that he had recovered a pistol of thirty bore along with magazine in crime No. 542 of 2014 U/S 324, 353, 148, 149, 411, 412 P.P.C from accused without license and such mashirnama of arrest and recovery was already prepared in presence of mashirs H.C Manzoor Ali Shah and P.C Abdul Hakeem therefore he lodged the FIR to this effect.

                            Police started investigation, and arrested the applicants/accused and finally challaned the case hence this bail application.

                  

GROUNDS

1.                 That the applicant/accused has been falsely implicated by the complainant.

2.                 That the applicant/accused was brought by  Dadu Police about a week ago and was kept in wrongful confinement and when the relatives including the father and others were coming to Honorable Court on 23.12.2009 when Dadu Police intercepted and started firing and injured so many villagers which photages was shown on various T.V channels therefore the police in order to save their skin file the false case of encounter and the present case of 13-D by foisting the case property upon the applicant/accused.

3.                 That the alleged offence do not fall within the prohibitory clause of Section 497 Cr.P.C.

4.                 That the applicant/accused is not likely to abscond or temper with the prosecution evidence.

5.                 That the applicant/accused is prepared to furnish solvent surety to the satisfaction of this Honorable Court.

6.                 That the Vakalatanama and copy of FIR are submitted herewith.

7.                 Prayer is made in the interest of justice.

Dadu.

Dated.         

                               

                                                                              Advocate

                                                                 For the applicant/accused.