Post-arrest bail petition before the Court of Session covering FIR particulars, grounds of false implication, further inquiry and undertaking to attend trial.
When to use this draft
Use after arrest where the offence does not fall in the prohibitory clause, or where a case of further inquiry is made out.
Essential contents
- FIR number, police station, date and sections
- Custody period and stage of investigation
- Grounds - false implication, delay in FIR, no recovery, further inquiry
- Whether the offence falls within the prohibitory clause of Section 497(1)
- Undertaking to join investigation and attend trial
- Copy of FIR and police record annexed
Drafting notes
- Deal head on with the prohibitory clause - identify why the case falls outside it or attracts further inquiry.
- Delay in lodging the FIR without explanation is one of the strongest grounds.
- Plead the accused antecedents - first offender, no criminal history, local resident with sureties.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.