IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Misc. No._____________/2000

Mst. Shamim alias Kaki wife of Anwar alias , caste Qasai, R/o
Y-Block, Peoples Colony, Vehari.
Petitioner
Versus
The State. …Respondent

F.I.R. No. 128/2000 dated 20.7.2000

U/s 302 P.P.C. P.S. City Vehari

Petition under section 497 Cr.P.C.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That the F.I.R. was registered on the application of one Ghulam

Rasool who stated that he is a resident of “Y” Block, Peoples
Colony Vehari and having a shoe-making business in the Landa
Bazar, Vehari. On the day of occurrence, the complainant and his
maternal uncle Allah Ditta were going to the house of
complainant, riding on a motorcycle. At 3 p.m. when they
reached Habib Chowk, Peoples Colony Vehari, near the house of
complainant they saw that the petitioner had caught Sakina Bibi,
the mother of the complainant, from the hair and was inflicting
fist blows. The complainant and his uncle got released the Sakina
Bibi who fell on the ground and taken to the home, by both of
them. The petitioner fled away. It was alleged that Mst. Sakina
Bibi passed away due to fist blows inflicted by the petitioner.
 Mst. Sakina Bibi had to recover the “money of committee” from
the petitioner and there was a quarrel over this matter, was a
motive behind the occurrence, hence this F.I.R. Copy of F.I.R. is
Annex “A” and Annex “A/1” is better copy.

3. That the petitioner was arrested and sent to judicial lock-up. The
petitioner applied for post-arrest bail, which was dismissed by the
learned Additional Sessions Judge, Vehari, Ch. Saeed Ahmad,
vide order dated 29.8.2000. Copy of order is Annex “B”.

4. That the petitioner seeks the concession of post-arrest bail inter

alia on the following: -

GROUNDS
a) That the occurrence as stated in the F.I.R. is a false one
and concocted story.

b) That the F.I.R. is lodged with the connivance of police.

C) That the petitioner is innocent and roped up falsely due

to personal enmity, malafidely and with ulterior
motives.

d) That there was an exchange of hot words between the

petitioner and deceased much early than the time stated
in F.I.R. but no fight was happened. This fact is also
proved during the investigation.

e) That no cause of death has been given in the post-

mortem report, and same is reserved till the report of
Chemical Examiner.

f) That in the circumstances, the case against the

petitioner is one of further enquiry.

g) That being a woman the case of petitioner falls within

the preview of Sec-497 (i) Cr.P.C.

h) That the petitioner has six children, who are un-

attended in the absence of the petitioner.
 i) That the investigation of the case is complete and
person of the petitioner is no more required by the
police.

j) That the petitioner is behind the bars since last four

months, and no useful purpose can be served by the
detention of the petitioner.

k) That there is no likelihood of submission of Challan or

Commencement of trial in the near future.

l) That the petitioner is neither a previous convict nor

having any record.

In view of the above submissions, it is

respectfully prayed that this petition may please be
accepted and petitioner may please be granted bail.

Any other relief, which this Hon’ble Court deems

fit may graciously be extended in the interest of justice.

Humble Petitioner,

Dated: ___________

Through: -
Sheikh Muhammad Faheem, Hamad Afzal Bajwa,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20176 C.C. No. 20959

CERTIFICATE: -
Certified that this is the first bail
petition before this Hon’ble Court. No
such petition has earlier been filed.
Advocate
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

Crl. Misc. No._____________/2000

Mst. Shamim alias Kaki Vs The State

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Bail Petition.
3 Copy of F.I.R. & better copy. A & A/1
4 Copy of order. B
5 Dispensation Application.
6 Affidavit.
7 Vakalatnama

PETITIONER
Dated: ____________

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
Hamad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. _____________/2000

In
Crl. Misc. No.______________/2000

Mst. Shamim alias Kaki Vs The State

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPY OF ANNEXURE.
=========================================

Respectfully Sheweth:-
That certified copy of Annexure “A” is not available.
However, uncertified/photo state copy of the same has been
annexed with the petition, which is true copy of the original
document.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copy of
the document.

PETITIONER

Dated: __________
(Mst. Shamim)

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
Hamad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. _____________/2000

In
Crl. Misc. No._____________/2000

Mst. Shamim alias Kaki Vs The State

DISPENSATION APPLICATION

AFFIDAVIT of: -
Mst. Shamim alias Kaki wife of Anwar alias , caste Qasai, R/o
Y-Block, Peoples Colony, Vehari.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above petition are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of November 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT