Sample Bail 397 Muzammil

IN THE COURT OF IVth ADDITIONAL DISTRICT & SESSIONS JUDGE (CENTRAL) AT KARACHI

Criminal Bail Application No.________ of 2025

[APPLICANT/ACCUSED NAME],

Son of [FATHER NAME],

Muslim, Adult, Resident of

Karachi, presently confined

In the Central Jail

Karachi. ………………………… Applicant

Versus

The State …………………………. Respondent

FIR No.192/2024,

U/S. 397/34 PPC

P.S. [POLICE STATION REDACTED],

Karachi.

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

It is most respectfully submitted on behalf of the above named Applicant/Accused that pending trial this Hon’ble Court may graciously be pleased to grant bail to the Accused named above, in the offence(s) arising out of F.I.R. No. 192 of 2024 (“the FIR”), lodged at [POLICE STATION REDACTED] Police Station, Central Karachi and upon furnishing solvent surety to the satisfaction of this Hon’ble Court and inter alia, upon the consideration of the following facts and grounds amongst others, viz:-

FACTS

The brief facts of the case as narrated in the FIR are that, I the complainant live in a rented house with my family at the address above mentioned in the column no.2. That I work as a postman in a TCS company. That on dated: 01-08-2024 I was on duty and delivered a letter to the house no. R-28 Block-18 FB Area and as I sat on my motorcycle to return back to my office. Around 5:30 pm three unknown persons riding on a motorcycle stopped their vehicle in front of me. That one of them was carrying a weapon, two of them were wearing an eastern dress i.e. shalwar/qameez while the third one was dressed in pant a t- shirt appearing to be rangar/ thugs/ hooligans from their appearance whom I can identify, robbed me off the company’s cash amount i.e. Rs. 16,750/- along with my personal cash amount i.e. Rs. 400/- as well as snatched my personal use cell phone i.e. China keypad mobile on gun point. That people in the surrounding witnessed such incident of robbery with me. Hence, legal action shall be taken against such person(s). Hence, this FIR.

That the Applicant/Accused is innocent, has been falsely implicated and has not concealed