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Brief facts, giving rise to present application
Are that, on 23.06.2022; Complainant/injured Hassan Ali Bijarani lodged FIR with P.S
Karampur, alleging therein that, On 31.05.2022; he alongwith his cousins
Everyone Ghulam Rabbani and Mashooq Ali left Meer Mehran Khan House in his own Mehran
Car bearing its registration BJK – 473 and were going to karampur town while Complainant
himself was driving the car. That when at 09:30 AM reached near Village gurddo link road where
a white a color. Corolla car and two persons on a Motorcycle arrived
There, they came infront of complainant party from southern side. That they stopped their
Motorcycle and car in front of complainant party; two un known persons duly armed with
Kalashnikoves un-boarded and four unknown persons un-boarded from said car out of them two
accused persons were armed
With Kalashnikoves and one accused person with T.T Pistol and one person was empty handed it
is alleged that accused persons signaled complainant party to stop the car and same was stopped
by the complainant party, on which one accused of Motorcycle made straight fire of K.K upon
complainant party with intention to commit murder which hit at the front glass of the car and the
pieces
Of the glass of the car hit at the center of head of the complainant another accused of Motorcycle
fired from his K.K at the car of complainant but they saved themselves by leaving the car from
doors of the western side. Then accused persons by seeing the
Complainant fallen on the ground made aerial firing and fled away towards northern side on their
car and motorcycle. Than complainant saw that he has received a fire at the center of head blood
was oozing and some fires marks were available at front side and near tank of the car. During
incident one mobile set of Oppo Company A 05 2022 was misappropriate. Than complainant was
brought by his witnesses at P.S from where obtained a letter for treatment to RHC karampur
where treatment was provided by
Doctor to him. Complainant went to infrom his nek mard about the incident but he was not
available as and when his nek mard meet with him complainant narrated the above facts with
him who advised the complainant to register the FIR.
Police after registration of FIR started

Investigation and submitted the report on 06.07.2022 under “A” Class and the magistrate
accepted the same on 20.07.2022 with a direction to submit a fortnight report of the case.
On 11.10.2022 the learned Magistrate passed

The Order for further investigation by the I.O Of the other District, who also submitted the same
report but the learned Magistrate directed the police to submit the Challan of the case upto
07.12.2022, the same report under section 173-A Cr.P.C, was submitted by the police on
07.12.2022 against applicant and co- accused persons, on the basis of
Further statement of the Complainant and PWS recorded by police on 31.07.2022; hence, this
application for Bail.
Present applicant had no knowledge regarding registration of case and submission of report
under section 173 Cr.P.C, but how police raided the house of present applicant with malafide
intention for his
Intended arrest just to harass, humiliate, disgrace and disrepute him in the society.
The case against co-accused Bakhtiaro was
Proceeded and finally acquitted; while case against present applicant was kept on dormant;
hence, this Bail Before Arrest Application.
GROUNDS
1. That, the applicant/accused is innocent,
And is the victim of ‘enmity over the
Landed property.
2. That, there are no any reasonable
Grounds to believe that, he
Had committed any offence, whatsoever, and
The case is totally false, fabricated and
Concocted one/engineered one and managed by Complainant.
3. That, neither the name of present

Applicant/accused find placed in the FIR
Nor face features has been given by the
Complainant in the FIR or even no such
Identification parade was held which
May
Connect
The applicant with
The
Crime.
That, on 23.06.2022 FIR was registered by
The Complainant and on 24.06.2022; 161
Cr.P.C Statements of both the witnesses
Were recorded by Police but they failed to
Nominate any of the accused resultantly
On 06.07.2022 report under section 173
Cr.P.C was submitted-by: police under A
Class.
That, there is inordinate and unexplained
Delay of Twenty Four DAYS in lodgment
Of FIR, for which no any plausible
Explanation has been furnished by the
Complainant party, though the distance
Between Police Station and alleged place.
Of incident is 6/7 K.m Only.
That, the delay in lodging of the FIR
Shows that, it has been lodged after due
Deliberations
And consultations with each-other by the complainant party;
Therefore, the false implication of the
Applicant/accused cannot be ruled out.
That, on 31.07.2022 with the delay of Two

Months
Further
Statement
Of
Complainant
And his PWS
Everyone
Mashooq and
Ghulam
Rabbani were
Recorded by police in which all of them
Have introduced the name
Name of present
Applicant/accused alongwith Others. It is
Well settled principles of law that, there is
No provision of further statement is
Available in Cr.P.C.
That, twice case was disposed of by

Police Under A Class including I.O of
Another District and finally the case was
Challan by police at the Order Of Learned
Issued
Magistrate and straight away
NBWs instead of issuing notice/summons
Or BWs.
That,
Had
On 31.05.2022 complainant
Appeared where certain documents were
Prepared such entry was also kept by
Police but he failed to nominate any of
The accused.
“
10. That, police during the track of
Investigation recorded the Statements of
Independent
Persons Edan Bunglani,
Sathi Khan Choliyani and Others who in
Their statements categorically stated that
On the fate full day of incident present
Applicant and Others attended the charity
Program
Arranged by one
Ghulam
Muhammad Nindawani in village Rehan
Khan Nindwani present applicant was
With them at the relevant time.
11. That, Complainant party introduced the

Name of present applicant in their further
Statements with malafide intention just to
Harass, humiliate, disgrace and disrepute
Him in the eyes of general public.
12. That, co-accused Bakhtiaro has already
Been
Acquitted by
The
Idan Ist.
Additional Sessons Judge, Kandhkot and
During the pendency of case, he was on
Bail; So on the principle of rule
Consistency; he is bail.
13. That, the ingredients of section 324 are

Missing in the case as neither there was

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Brief facts, giving rise to present application

Police after registration of FIR started

On 11.10.2022 the learned Magistrate passed

3. That, neither the name of present

That, on 31.07.2022 with the delay of Two

That, twice case was disposed of by

11. That, Complainant party introduced the

13. That, the ingredients of section 324 are

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