Sample Bail Urgent Application

Applicant in custody

IN THE HIGH COURT OF SINDH AT

KARACHI

Criminal Bail Application No. Of 2023

[APPLICANT/ACCUSED NAME]----------- APPLICANT/ ACCUSED

(Presently confined in central jail)

VS

THE STATE ----------------------------- RESPONDENT

FIR NO: 22/2023

U/S: 302/397/392/34

P.S: LIAQUATABAD

APPLICATION UNDER RULE- IX CHAPTER III-A

VOLUME-V OF SINDH CHIEF COURT RULES.

For the facts and reasons stated in the accompanying affidavit as well as in the bail application filed U/S 497 & 498 of Criminal Procedure Code. It is humbly submitted on behalf of the applicant above named that this Hon’ble Court may graciously be pleased to treat this matter as urgent motion and may please

Fix the same in Court/Chamber on dated: January 2024.

It is prayed accordingly in the interest of justice, equity, fair play and good conscience.

Karachi. ADVOCATE FOR APPLICANT

Dated:

Applicant in custody

IN THE HIGH COURT OF SINDH AT

KARACHI

Criminal Bail Application No. Of 2023

[APPLICANT/ACCUSED NAME]----------- APPLICANT/ ACCUSED

(Presently confined in central jail)

VS

THE STATE ----------------------------- RESPONDENT

FIR NO: 22/2023

U/S: 302/397/392/34

P.S: LIAQUATABAD

A F F I D A V I T

I, [WIFE NAME] w/o Ghulam Qadir Shareef Muslim, Adult R/o [ADDRESS REDACTED], do hereby make oath and state on solemn affirmation as under:

That I being the wife of applicant/ accused in the above matter, I am well conversant with the facts of the case.

That the accompanying application for urgent hearing has been drawn and filed under my specific instructions and for brevity sake the contents of the same may please be treated as an integral part of this affidavit.

That unless my accompanying application is granted, I shall be seriously prejudiced and shall suffer irreparable loss and inconvenience.

That whatever that has been stated in the above paras is true and correct to the best of my knowledge, belief and information.

Karachi. D E P O N E N T