Petition Under Section 497 Cr.p.c. For Grant of Bail - 420 - 68 - 71

IN THE COURT OF SESSIONS JUDGE, LAHORE.
Name , S/o, D/o Father Name , resident of

_____________________.
….Petitioner
VERSUS
1. Muhammad Ramzan Son of Mushtaq

2. Muhammad Irfan Son of Muhammad Ismail
3. Safia Begum Widow of Mushtaq Ahmed
All Residents of House no. 300, Block C, Gowala Colony, Rakh

Chandrai, Lahore.
4. The State
….Respondents
Case FIR No. : 870/12 dated 17.11.2012

Offence : U/s 420/468/471 PPC
Police Station : Ghaziabad, Lahore.
******
PETITION UNDER SECTION 497(5) Cr.P.C.

FOR CANCELLATION OF BAIL OF RESPONDENTS NO. 1 TO 3.
******
Respectfully Sheweth:-
1. That the brief facts which have led to the institution of the
titled petition before this Honourable Court are that a criminal
case under sections 420, 468, 471 PPC was registered at the
instance of the petitioner against the respondents vide FIR No.
870/12 dated 17.11.2012 at police station Ghaziabad, Lahore,
in which pre-arrest bail of the respondents No. 1 to 3 was
confirmed vide order dated 15.12.2012 by Javaid Iqbal Sheikh,
the then learned ASJ, Lahore. Copies of FIR and order dated
15.12.2012 are attached herewith.
2. That respondent No. 3 with the active connivance of
respondents No. 1 & 2 prepared a fake and forged agreement
to sell in her favour on behalf of petitioner and during the
course of investigation the plea was taken by the respondents
that agreement dated 15.05.2008 has been attached with the
case pending in the court of Civil Judge and thus the I.O. of the
case failed to get recover the said document and also to send
the same for comparison to Forensic Science Laboratory. It was
further alleged by the respondents that the agreement in
question is genuine and they have committed no forgery on
the document and the same was executed by the petitioner
after receiving the consideration amount and learned ASJ was
pleased to confirm the bail of the respondents on the ground
that no result to the extent of thumb impression on the

document in question in the hand of prosecution thus there is
no material against the respondents to connect them with the
commission of alleged offence.
3. That the I.O. of the case moved an application before the court
of Mr. Imran Shahbaz, learned Civil Judge, requesting therein
to handover the document in question for sending the same
for comparison but the learned Civil Judge refused to accept
the request of I.O. thus the investigation of the case could not
be completed at that time.
4. That afterwards the petitioner moved an application before
the court of Mr. Imran Shahbaz with the request to send the
documents in question for combparison to the Forensic
Science Laborqatory and this application was contested by the
respondents in the court but the learned Civil Judge was please
to send the same to the Forensic Science Laboratory, in
presence of respondents specimen of thumb impressions were
obtained by the learned Civil Judge and these specimens
alongwith documents in question was sent to Forernsic Science
Laboratory who after comparing the specimens with the
thumb impressions on the document in question come to the
conclusion that the document in question doesn’t bear the
thumb impression of the petitioner and the same are forged
one. Report of the Forensic Science Laboratory is attached
herewith, which proves that the respondent No. 3 who is the

beneficiary of the document in question alongwith
respondents No. 1 & 2 who are the marginal witnesses
deliberately, willfully and intentionally prepared a forged
document with the intention to deprive the petitioner from his
valuable rights over the property.
5. That the Forensic Science Laboratory report fully proves the
version of the petitioner and negate the contention of the
respondents and it is necessary to mention here that though
the report dated 30.07.2013 is very much in the knowledge of
the respondents and the same has not been assailed in any
higher forum, thus the report has attained the maturity and it
proves that the respondents have deliberately and willfully
prepared a forged document with the intention to get undue
advantage and as such they have committed the offences falls
under the purview of section 420, 468 & 471 PPC.
6. That the respondents are constantly advancing threats to the
petitioner as well as to the witnesses of the case with dire
consequences and in this respect a fake and false application
was submitted by the respondent No. 3 at police station
Islampura, which after preliminary inquiry was found false and
frivolous and was consigned to the record room, it shows that
the respondents are advancing the threats to the petitioner
and are also misusing the concession of bail granted to them.

7. That confirmation of pre-arrest bail is an extra ordinary relief
always granted to innocent persons but the persons of such
category who intentionally, willfully committed fraud and
forgery are never deserved to get this relief and in the instant
case the forgery committed by the respondents is clear in all
respects.
8. That the respondents No. 1 to 3 have tried to tamper with the
prosecution witness by threatening the witness.
9. That the respondents No. 1 to 3 are threatening the petitioner
for dire consequences if the petitioner pursues the case.
10. That the respondents No. 1 to 3 have fulfilled all the
ingredients which are required for the cancellation of bail.
In the light of aforementioned facts and
circumstances it is most humbly prayed that bail
granted to the respondents No. 1 to 3 vide order dated
15.12.2012 may kindly be recalled / cancelled.
Any other relief which this Honourable Court
deems fit and proper may also be granted.
Petitioner
through
Advocate
IN THE COURT OF SESSIONS JUDGE, LAHORE.
In re:
Ch. Karamat Ali VS Muhammad Ramzan etc.
Case FIR No. : 870/12 dated 17.11.2012

Offence : U/s 420/468/471 PPC
Police Station : Ghaziabad, Lahore.
******
PETITION UNDER SECTION 497(5) Cr.P.C.

FOR CANCELLATION OF BAIL OF RESPONDENTS NO. 1 TO 3.
AFFIDAVIT OF Ch. Karamat Ali Son of Ch. Muhammad Ali, Caste

Jutt, Resident of Khanoharni, Tehsil Cantt, District
Lahore.
I the above named deponent do hereby solemnly affirm and

declare as under:
That the contents of accompanying petition are true and
correct to the best of my knowledge and belief and nothing
has been concealed therein.
Deponent
VERIFICATION
Verified on oath at Lahore this 2 nd day of December
2013 that the contents of above affidavit are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Deponent

Petition Under Section 497 Cr.p.c. For Grant of Bail - 420 - 68 - 71

Uploaded by

Copyright:

Available Formats

You might also like

Petition Under Section 497 Cr.p.c. For Grant of Bail - 420 - 68 - 71

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Petition Under Section 497 Cr.p.c. For Grant of Bail - 420 - 68 - 71

Uploaded by

Copyright:

Available Formats

IN THE COURT OF SESSIONS JUDGE, LAHORE.

Name , S/o, D/o Father Name , resident of

1. Muhammad Ramzan Son of Mushtaq

All Residents of House no. 300, Block C, Gowala Colony, Rakh

Case FIR No. : 870/12 dated 17.11.2012

PETITION UNDER SECTION 497(5) Cr.P.C.

titled petition before this Honourable Court are that a criminal

instance of the petitioner against the respondents vide FIR No.

870/12 dated 17.11.2012 at police station Ghaziabad, Lahore,

in which pre-arrest bail of the respondents No. 1 to 3 was

confirmed vide order dated 15.12.2012 by Javaid Iqbal Sheikh,

15.12.2012 are attached herewith.

2. That respondent No. 3 with the active connivance of

respondents No. 1 & 2 prepared a fake and forged agreement

to sell in her favour on behalf of petitioner and during the

course of investigation the plea was taken by the respondents

that agreement dated 15.05.2008 has been attached with the

the same for comparison to Forensic Science Laboratory. It was

further alleged by the respondents that the agreement in

question is genuine and they have committed no forgery on

the document and the same was executed by the petitioner

after receiving the consideration amount and learned ASJ was

pleased to confirm the bail of the respondents on the ground

that no result to the extent of thumb impression on the

no material against the respondents to connect them with the

commission of alleged offence.

of Mr. Imran Shahbaz, learned Civil Judge, requesting therein

to handover the document in question for sending the same

for comparison but the learned Civil Judge refused to accept

be completed at that time.

4. That afterwards the petitioner moved an application before

documents in question for combparison to the Forensic

Science Laborqatory and this application was contested by the

to send the same to the Forensic Science Laboratory, in

presence of respondents specimen of thumb impressions were

obtained by the learned Civil Judge and these specimens

alongwith documents in question was sent to Forernsic Science

Laboratory who after comparing the specimens with the

thumb impressions on the document in question come to the

conclusion that the document in question doesn’t bear the

thumb impression of the petitioner and the same are forged

one. Report of the Forensic Science Laboratory is attached

herewith, which proves that the respondent No. 3 who is the

respondents No. 1 & 2 who are the marginal witnesses

deliberately, willfully and intentionally prepared a forged

document with the intention to deprive the petitioner from his

valuable rights over the property.

5. That the Forensic Science Laboratory report fully proves the

version of the petitioner and negate the contention of the

respondents and it is necessary to mention here that though

the report dated 30.07.2013 is very much in the knowledge of

proves that the respondents have deliberately and willfully

prepared a forged document with the intention to get undue

advantage and as such they have committed the offences falls

under the purview of section 420, 468 & 471 PPC.

6. That the respondents are constantly advancing threats to the

petitioner as well as to the witnesses of the case with dire