302 Post Arrest Bail Redacted

IN THE COURT OF VIIth ADDITIONAL DISTRCIT AND SESSIONS JUDGE AT KARACHI

CENTRAL

CR. BAIL APP. [REDACTED]/2024

[REDACTED] ------------------------------- APPLICANT/ ACCUSED

S/O [REDACTED]

(Presently confined in Central Jail [REDACTED]

VS

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

FIR No. [REDACTED]/2024

U/S: 302/397/392/34

P.S. [REDACTED]

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 an ambulance driver in edhi service. That my mother in law had been residing alone from 12 years to 13 years in the house no [REDACTED] Qasimabad [REDACTED], liaqautabad Karachi. That she also kept a maid at her house two days ago. That on dated [DATE REDACTED] my wife went to meet with her mother at her house in the evening and knocked on the main gate to which her mother did not open the door and my wife kept knocking. Then, my wife asked a boy from locality to climb the wall of the house of my mother in law and to open the main gate. As soon as my wife entered the house of her mother she saw that her mother is lying on the bed faced down while blood was streaming down from her neck in a lifeless condition. My wife hurriedly called me and upon my arrival to the house of my mother in law. We discovered that the amount of committee, two android cellphones and one keypad cellphone owned by my mother in law were missing from the Almirah. That I, immediately called on 15 and upon the arrival of police the dead body of my mother in law was sent to hospital for post mortem. That I am lodging an FIR against unknown persons for harassing my mother in law and entering into the house with the motive of robbery and later murdering my mother in law.

GROUNDS:

That the applicant/accused is a law-abiding citizen of Pakistan and has been falsely and