Post Arrest Bail Draft

IN THE COURT OF VII ADDITIONAL DISTRICT AND SESSIONS JUDGE AT KARACHI

(CENTRAL)

Cr. Case no: ____/202_

(Applicant/ Accused’s name)S/o(Father’s name) --------------------------- Applicant/ Accused

V/S

THE STATE --------------------------- Respondent

FIR NO: ___/202_

U/S:(Relevant sections mentioned in FIR)

P.S: (Police station where FIR was lodged)

BAIL APPLICATION UNDER SECTION 497 OF THE CODE OF CRIMINAL PROCEDURE 1898

It is most respectfully prayed on behalf of the above-named Applicant/ Accused that this Hon’ble Court may be pleased to release/enlarge the Applicant on bail pending trial, and upon furnishing surety inter-alia, on the following facts and grounds, amongst others,viz:-

FACTS:

Brief facts of the case as narrated in the FIR are that complainant stated that the complainant is a private bank employee. On dated: _____around 12 am the complainant received a phone call from his mother and told the complainant that some unknown persons has killed the younger brother victim/ deceased of the complainant namely ____S/o _____during robbery. Further that the neighbor rushed the victim/ deceased to the Hospital. That the complainant called one of his neighbor namely ____who told the complainant that they are taking the victim/ deceased to (mention hospital name). Upon arrival of the complainant to (mention hospital name)the doctors told the complainant that his younger brother i.e. victim/deceased has been shot twice and that the backbone of the victim/ deceased has severely been injured to which the complainant took his younger brother victim/ deceased to the private hospital namely (mention hospital name)where doctors took the victim/deceased to the operation theatre and as per complainant his younger brother i.e. victim/ deceased passed away during the operation. Further that the complainant refused the doctors for the post mortem of the victim/ deceased and took the dead body of the victim/ deceased along with them to home. That I am lodging an FIR against unknown persons riding motorcycle for killing my younger brother namely ______S/o_____ during the incident of robbery.

According to the circumstanc