GROUNDS

1. That the applicant / accused is quit innocent and have falsely

been implicated in this case by the police malafide intention
when the accused failed to fulfill illegal desire of police.

2. That the alleged offence does not attract against the

applicant / accused as the applicant have no concerned with
above mentioned alleged offence.

3. That the real facts are that the applicant / accused was
going to home on 23-o1-2019 while the police stopped him
and ask about original CNIC and job identity card. Which he
could not produced on that time, but the accused produced
the photocopy of CNIC on that time on which the police
asked for huge bribe which he could not give and
subsequently the police implicated him in this false case.

4. That nothing has been recovered from the applicant /

accused and false allegations have been leveled and
recovery showed by the police is foisted one.

5. That the entire quantity of alleged recovered charas was not

sent to chemical examiner, thus the case needs further
inquiry.

6. That the complainant has miserably failed to give the name

of any independent eye-witness of the incident that is the
mandatory provision of criminal law and non compliance of
the same needs further enquiry.

7. That there is no direct evidence available on the record

against the applicant / accused and In the absence of any
direct evidence the section ii proviso of section 497 Cr.p.c
and required further inquiry.

8. That the FIR is silent about that how and in whose presence
the alleged recovery was sealed and whether it was sent to
laboratory or not.
 9. That there is violation of section 103 Cr.p.c. that at the time
of incident the prosecution has failed to associate any
independent witness who saw the incident, as the place of
incident is a busy hotel, shops, parking area and thickly
populated area and located on a very busy main road and
the rush day hour.

10.That it is humbly submitted that it is the duty of prosecution

to prove the case and prior to this the applicant / accused is
innocent according to law. His continuous detention in jail is
detrimental to dispensation of justice.

11.That the accused belongs to a noble family and not have

been involved in any crime ever. Also the CRO of the
accused is not produced by the I.O.

12.That the applicant / accused has been remanded to judicial

custody and he is no more required for investigation.

13.That the applicant / accused is a permanent resident of

Karachi, and he undertakes not to abscond nor temper with
the prosecution witness.

14.That the applicant / accused is ready and willing to furnish

solvent surety to the satisfaction of this honorable court, if
admitted to bail.

15.That further grounds will be urged at the time of hearing of

this bail application with subject to permission of this
honorable court.

PRAYER
This is therefore, very humbly prayed that this honorable court
may be pleased to enlarge the applicant / accused on bail in the
interest of justice.

Karachi.
Dated. / /2019

…………………………………………………………..
Advocate for the applicant / accused.