IN THE COURT OF 3RD ADJ AT KARACHI SOUTH

B.A NO.
Fir No.301/13
U/S 496-A/34 PPC
P.S Balooch
Colony
M.SIDDIQUE
s/o.
Muslim, Adult,
R/o Pankha Hotel Gulberg
KarachiApplicant
v/s
The StateRespondent

Bail Application U/S 497CRPC 1898

It is prayed on behalf of the Applicant that this Honble Court
may be pleased to grant bail to the Applicant on the following facts
and grounds:FACTS:According to FIR the complainant M.Ejaz S/o Muhammad
Khan alleged that
I have been living in House No.105 St. No.2, Sector E, Manzoor
Colony, Karachi along with wife and children for two years. I drive
taxi for livelihood. That on 12-04-13 at 5 p.m I left home with my
taxi. My wife Shahnaz , Daughter 8/9 years old and small children
were at residence. On 12-04-13 approximately 7 p.m my daughter
KIRAN told me on phone that her mother left the house at 6:30 P.M
for purchasing flour but did not return. After that intimation I reached
home and checked the house. Cash Rupees 1 lac fifty thousand which
I saved for marriage of my daughter(Sumaira) and two golden tops
(balian) of my daughter(Kiran) was missing. I reported that incident to
police station. I and my brother-in-law(SALA), Muhammad Adeel S/o
M.Shair kept on finding my wife. Now I came to know that my wife
Shahnaz D/o Muhammad Shair was kidnapped by conspiracy of 1M.siddique(doctor) 2- Imran s/o Not known 3- Hakim S/o not known
4- Sakina , and shifted her to some unknown place and kept her there.

I have come to report. Action be taken. I have heard the report which
is correct.
ACTION BY POLICE : I ASI Muhammad Naseem, Investigating
Officer, do hereby certify that the report was read over to informer
and he put his thumb impression on the same after taking it as true.
From the report, Sections 496-A/34 of PPC are attracted. The
investigation officer registered this case and distributed the copies of
FIR as per Law and investigation is in process in this police station.
GROUNDS:
1. That the Applicant has been falsely implicated in this case. He has
nothing to do with this incident.
2. That the Applicant is respectable married person with two sons and
three daughters. His one son and one daughter are married. His
daughter has children.
3. That according to complainant he has one marriageable daughter
Sumaira, another daughter Kiran aged about 9 years and 3 other small
children from shehnaz D/o Muhammad Shair who might have been
married to him about 20 years back.
4. That according to the information given by mohallah people
Shahnaz was married to some other person namely
Before she was enticed away by complainant and got into marriage
about 20 years back. Shahnaz has one married daughter from her
previous husband.
5. That according to the complainant the incident took place on
12/4/13. He kept silent upto 11/10/13. He did not report this incident
to Police. The FIR is over delayed. It is an afterthought and
conspiracy against the applicant hatched in connivance with the police
personnel .
6. That the complainant is a regular informer and paid civilian
worker who has been obliged by the Police to blackmail the applicant.
7. That according to FIR the kidnappers are four persons, Applicant,
Imran, Hakim and Mst. Sakina. As such, the legal liability mentioned
in the section 496-A PPC does not attract to this case. Only one person
Could marry with Shahnaz not all others and Mst. Sakina as well.
8.
That no vicarious liability has been particularly attributed to the
Applicant. As Such, it is a case of further enquiry in which bail can be
granted to the Applicant U/S 497(2) of Cr.PC
9.
That the Applicant is the only earner of his family. He is
working as a male Nurse Privately. His family is near starvation and

his patient are badly affected by his detention since 11/11/2013.

When he was arrested in the Court.
10. That the applicant is a permanent resident of Karachi. He is not
in a position to influence the witnesses.
11.
That no recovery has been made from the Applicant. There is
no evidence against him. It is a case of no evidence.
12.

That the applicant is prepared to furnish solvent surety.

In view of the above this Honble Court may be pleased to

enlarge the Applicant on bail.

Karachi;
Dated:18-11-2013
ADVOCATE FOR THE APPLICANT