Amanuallah Ujjan

BEFORE HONORABLE DISTRICT & SESSION JUDGE
EAST
Pre Bail Application No: /2023
1. Amanuallah Ujjan s/o

Allah Dino Ujjan R/o
Village Karim Dino Ujjan Post & Daur
Taluka Daur District Shaheed Benazirabad .…
Applicants/Accused
CNIC NO 45402 7933388-9 Cell No
VERSUS
The State ……………Complainant
FIR NO: 149/2023

U/S 489- F P.P.C
PS Mobina Town
CR BAIL APPLICATION U/S 498. CR.P.C.
It is respectfully prayed on behalf of the above named

applicant/accused that this Honorable court may graciously be
pleased to grant Pre Arrest bail in the above crime as the applicant/
accused is ready to surrender himself before trial court, taking into the
consideration the following facts & grounds:-
FACTS
Briefly facts leading to this bail application are that:-
Complainant Ali Lutif Ali S/O Lutifullah Ujjan Resides at above

address and also serving at NED university, during 2020 in presence
of his cousin Imran Ali S/O Mumtaz Ali Ujjan paid 25 lacs to the
Anamaullah Ujjan for business purpose, against the such amount a
Cheque NO 00000066 dated 03.12.2022 HBL Bandhi Benazirabad
was issued with the name UJJAN COMMUNICATION, the subject
cheque was presented on 08.11.2022 in NBP NED Branch Gulshan
e Iqbal Karachi, the said account has insufficient funds therefore
Cheaque was dishonored , same was also informed to the Amaunllah
Ujjan , where he shown his lame excuse and refused for the applicant
amount, the complainant has complaint against the accused for
registration of FIR . Copy of FIR is marked as annexure A. /
GROUNDS
1. That the applicant/ accused is innocent, law-abiding and carrying a

little business of Mobil accessories, easy load at his home town
Bandhi and does not imagine about partnership or loan from any
other person, therefore from the bare reading of FIR does not
appears any reasonable grounds to believe that applicant has
committed the alleged offence.
2. That applicant carrying his business to arrange the butter and bred
for his family, therefore does not imagine about the commission of
offence or any violation or cheating as alleged by the complainant.
3. That, its admitted fact and known by entire Ujjan community that
both parties are close relative as their relation based on WATA-
SATTA in Family, currently due to the Social Media and
Education the new watta proposal was refused by the applicant
party, the subject FIR is result of revenge nothing else.
4. That the it is also admitted that both parties has good visiting family
relation therefore during the such visits by the complainant, the
Applicant noted the Cheaque Book leaves were missing/stolen,
therefore being a law-abiding immediately matter reported with
Bank, the copy of application farm dated 23.01.2023 with
reference No 07301 is marked as annexure A/2.
5. That the applicant has earned good reputation in the vicinity, the
complainant wants to tarnish the applicants honor in Society by
filing false cases, complaints at Community heads, the titled FIR is
also part of personal grudge.
6. That when entire Community supported the younger decision and
refused the Complainants son proposal after that with the delay of
147 days registered the FIR on false and fabricated grounds as a
revenge.
7. That from the bare reading of FIR it clearly appears that the FIR is
bundle of lies as Complainant has failed to mention about the
Business nature, partnership Business area, , quantum of Profit
and loss sharing, even failed to reference any partnership deed or
documents.
8. That after registration of FIR complainant along the local Police at
Shaheed Benazirabad is bent upon to arrest the applicant in false
and fabricated FIR, in order to humiliate, tarnish the applicants
respect in society therefore, applicant had serious apprehension
of his arrest thorough the hands of local Police.
9. That the alleged offences does not come with in the prohibitory
clause, there are reasonable grounds for believing that
applicant/accused had not committed the alleged offence,
therefore the rule is bail not the jail.
10.That the applicant/ accused is ready to furnish a solvent surety to
the entire satisfaction of this Hon’ble Court.
11.That further grounds will be urged/ added/ altered at the time of
hearing of this Bail Application with the permission of this Hon’ble
Court.
PRAYER
In view of the above facts and circumstances, it is most

respectfully prayed on behalf of the Applicants/Accused that this
Honorable court may be pleased to grant the pre Arrest and same
may be confirmed in the interest of justice.
APPLICANT
KARACHI
ADVOCATE FOR APPLICANT / ACCUSED.

EAST

Allah Dino Ujjan
Applicants/Accused
VERSUS
FIR NO: 149/2023

U/S 489- F P.P.C
PS Mobina Town
AFFIDAVIT
I, Amanuallah Ujjan s/o Allah Dino Ujjan R/o Village Karim Dino
Ujjan Post & Daur Taluka Daur District Shaheed Benazirabad,
do hereby state on oath as under:-
1. That I am Applicant/Accused in accompanying bail application; hence

well aware with the facts of the case.
2. That I am innocent there is no reasonable ground to believe that the
deponent committed the alleged offence.
3. That prior to this I have not applied for my Pre Arrest bail before this
honorable court.
4. That the grounds and facts mention in accompanying memo of bail
application may treat as a part of this affidavit.
5. That the above para’s were read over to me in my own language, I
understand and sign.
6. That whatever stated here-in-above is true and correct to the best of my
knowledge and belief.
DEPONENT
CNIC NO 45402 7933388-9 Cell No
COMMISSIONER FOR TAKING AFFIDAVIT

EAST

Allah Dino Ujjan
Applicants/Accused
VERSUS
FIR NO: 149/2023

U/S 489- F P.P.C
PS Mobina Town
STATEMENT
It Is Respectfully submitted that this is 1 st bail application
on behalf of Applicant and prior to this no any application
is filed nor pending before any other court .

Amanuallah Ujjan

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BEFORE HONORABLE DISTRICT & SESSION JUDGE

Pre Bail Application No: /2023

1. Amanuallah Ujjan s/o

The State ……………Complainant

FIR NO: 149/2023

CR BAIL APPLICATION U/S 498. CR.P.C.

It is respectfully prayed on behalf of the above named

Complainant Ali Lutif Ali S/O Lutifullah Ujjan Resides at above

1. That the applicant/ accused is innocent, law-abiding and carrying a

In view of the above facts and circumstances, it is most

ADVOCATE FOR APPLICANT / ACCUSED.

1. Amanuallah Ujjan s/o

The State ……………Complainant

FIR NO: 149/2023

1. That I am Applicant/Accused in accompanying bail application; hence

COMMISSIONER FOR TAKING AFFIDAVIT

BEFORE HONORABLE DISTRICT & SESSION JUDGE

1. Amanuallah Ujjan s/o

The State ……………Complainant

FIR NO: 149/2023

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