IN THE COURT OF THE SESSIONS JUDGE, MIANWALI
IN THE MATTER OF:
Muhammad Aqib son of Yaran Khan, Resident of Dhoke Kasora, Namal, Tehsil and District
Mianwali.
(Petitioner/Accused)
VERSUS
The State
(Respondent)
FIR No: 3/23, P/S: Chakrala , U/S: Section PAAO 2015-13-2(a)20, PAO 1965
APPLICATION UNDER SECTION 498 Cr.P.C FOR THE GRANT OF PRE-
ARREST BAIL
MAY IT PLEASE YOUR HONOUR:
1. That the FIR has been registered against the petitioners with ulterior motives by the
complainant, in collusion with the police, based on false, frivolous, and concocted grounds to
harass and malign the petitioners and have connection with the commission of offence.
2. That I was previously admitted to bail during the trial proceedings, but due to misinformation
about the hearing date, I missed the court date unintentionally, leading to my being proceeding
against him u/s 512 Cr.P.C consignment of the file under Section 512 Cr.P.C on 07-09-
2024.Copy of Order will be provided at the time of arguments.
3. That my absence from court was due to a genuine misunderstanding, without any malafide
intention to avoid trial proceedings.
4. That I am committed to presenting myself in court and cooperating fully in the trial process
and am willing to provide bail bonds as required.
5. That the Petitioner is innocent and above-mentioned FIR registered against the petitioner
malafidly.
6. That in support of petition the affidavit is attached.
PRAYER
In light of the above-mentioned facts and circumstances, it is respectfully prayed that this
Honorable Court may be pleased to:
1. Grant ad-interim pre-arrest bail to the petitioner and permit the petitioner to appear and
participate in the trial proceedings.
Petitioner
Through:
Malik Atif Iqbal
Advocate
