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    489-B Saeed Ahmed 2

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    rizwanullah123321

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    489-B Saeed Ahmed 2

    Uploaded by

    rizwanullah123321
    5 views4 pages

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    489-B saeed ahmed 2

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    5 views4 pages

    489-B Saeed Ahmed 2

    Uploaded by

    rizwanullah123321

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    BEFORE THE COURT OF SESSION JUDGE, QUETTA.

    Bail application No.___ of 2024

    Saeed Ahmed s/o Baig Muhammed Cast Shahwani


    R/o Kechi Baig Saryab, Quetta.
    Applicant.

    VERSUS

    The State. Respondent.

    OFFENCE UNDER SECTION 489-B & 34 OF PAKISTAN PENAL CODE

    APPLICATION UNDER SECTION 497 Cr.P.C FOR GRANT OF


    BAIL.

    The applicant /accused respectfully submits as under: -

    ● 1. That a case vide FIR No.117/2024, under above mentioned

    section has been registered with P.S Civil Line Quetta, on the report of

    Tahir Anwar (police official) with the allegation that on the same day at

    10:30 PM, the police along with the informer reached at civil hospital,

    where they arrested the above mentioned applicant/accused under the

    above cited section of Pakistan Penal Code, that the above mentioned

    applicant is been nominated in the instant FIR with the allegation of

    keeping the fake currency notes of amounting 5000/= for further

    details the copy of FIR is here by annexed as ANNEXURE A.


    2. That applicant / accused has nothing to do with the commission of

    alleged offence, but he has been arrested in the instant case, hence

    this bail application on the following amongst other grounds.

    GROUNDS: -

    A. That the applicant / accused has not committed any offence

    as alleged in the FIR and the applicant has been falsely

    dragged in the instant case with malafide of police.

    B. That according to the contents of the instant FIR the

    applicant/accused has not transmitted the alleged currency to

    any other person for any sale purchase neither has

    transferred it to any person with intent of fraud and it is

    established principle of law that mere fact of keeping the

    possession of fake currency does not constitute any offence

    under the provisions of 489-B, Hence the applicant /accused

    is entitled for grant of bail.

    C. That the material available on record calls for further inquiry,

    as such the applicant / accused is entitled for grant of bail.

    D. That the offences alleged do not fall within the ambit of

    prohibitory clause of section 497 Cr.PC Hence on this ground

    too the applicant / accused is entitled for the grant of bail.


    E. That bail cannot be with held as mere punishment. hence on

    this ground too the applicant /accused is entitled for grant of

    bail.

    F. That applicant / accused is no more required for any further

    investigation or probe, hence further detention of applicant

    will not serve any purpose to the prosecution, as such the

    applicant is entitled for grant of bail.

    G. That applicant reserves his right to argue any other point of

    fact and law available at the time of hearing of this

    application.

    H. That applicant is ready to furnish solvent surety bonds to the

    satisfaction of this honorable court and there is no

    apprehension of his absconsion or tempering with the

    prosecution evidence, if admitted to bail

    It is, therefore, respectfully prayed that the instant

    application for grant of post arrest bail may kindly be accepted and the

    applicant may kindly be granted bail, in the interest of justice, equity and

    fair play.

    DATED -09-2024.
    ACCUSED-APPLICANT.
    THROUGH COUNSEL.
    CERTIFICATE

    This is to certify that no other application for grant of bail has


    been filed by the applicant on the subject matter.

    COUNSEL FOR ACCUSED/APPLICANT.

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