Summary: Bail denied --- (a) Code of Criminal Procedure, 1898— ----Ss. 497 & 498—Pakistan Penal Code, Ss. 141, 149, 354-A, 452, 147, 148, 149—Pre-arrest bail—Scope—Extraordinary relief—Conditions— Petitioners sought pre-arrest bail in case involving house trespass, assault, and outraging modesty of complainant’s daughter—Pre-arrest bail declined by Trial Court and High Court—Validity—Supreme Court held that pre-arrest bail is an extraordinary discretionary relief to be granted only in extraordinary circumstances to protect innocent persons from mala fide arrest and abuse of process—Petitioner must establish reasonable grounds showing prima facie innocence, existence of further inquiry, and mala fide intention behind arrest—Such relief cannot be used as substitute for post-arrest bail nor granted as matter of course—Petitioners failed to satisfy mandatory conditions—Pre-arrest bail rightly refused. Cited Case: Rana Muhammad Arshad v. Muhammad Rafique (PLD 2009 SC 427) (b) Code of Criminal Procedure, 1898— ----S. 497—Pakistan Penal Code, S. 354-A—Prohibitory clause—Heinous offence—Effect on bail— Offence under Section 354-A PPC (assault or use of criminal force to woman with intent to outrage modesty) falls within prohibitory clause of Section 497 Cr.P.C.—Such offences are treated as heinous and serious in nature—Where accused are specifically nominated in FIR with active roles and supported by statements under Section 161 Cr.P.C., bail cannot be granted in absence of exceptional circumstances—Petitioners’ involvement prima facie established—Case did not fall within ambit of further inquiry. (c) Pakistan Penal Code, 1860— ----Ss. 141 & 149—Unlawful assembly—Common object—Vicarious liability— Where accused persons form unlawful assembly and commit offence in prosecution of common object, each member becomes vicariously liable for acts done by others—Common object can be inferred from conduct of accused, weapons carried, and circumstances of occurrence—Specific overt act by each accused is not essential where offence is committed in prosecution of common object—Presence and participation of petitioners in unlawful assembly sufficiently alleged—Liability under Section 149 PPC attracted. (d) Criminal jurisprudence— ----Further inquiry—Scope— Further inquiry arises where tentative assessment creates reasonable doubt regarding involvement of accused—Expression “reasonable grounds” refers to legally admissible and credible grounds appealing to judicial mind—Where FIR is prompt, accused specifically nominated, roles assigned, and allegations supported by statements under Section 161 Cr.P.C., case does not fall within further inquiry. Disposition: Criminal Petition dismissed; leave to appeal refused; pre-arrest bail declined; observations held tentative and not to prejudice trial.

Summary: Criminal Procedure Code (V of 1898)--- ----S.498---Penal Code (XLV of 1860), S.376---Carnal intercourse with wife---Pre-arrest bail, grant of---Medico Legal Report---Negative DNA Report---Benefit of doubt---Case of further inquiry---Criminal case was registered by wife alleging commission of sodomy with her by her husband/accused---Validity---Complainant alleged in FIR that she had been repeatedly subjected to carnal intercourse by accused/her husband---Such version of complainant was negated by Medico Legal Report as allegation of committing unnatural offence by accused could only be corroborated by medical evidence---Medico Legal Report was in direct conflict with the version of complainant and had reduced its veracity almost to a non-entity---DNA report in such respect was also negative---Benefit of doubt could be extended to accused even while deciding pre-arrest bail application---Investigation to the extent of accused was complete and there was no allegation of his misusing concession of ad interim bail already granted to him---Pre-arrest bail was allowed in circumstances. Khair Muhammad and another v. The State through PG Punjab and another 2021 SCMR 130; Adeel Manzoo v. The State and others 2023 SCMR 967; Fahad Hussain and another v. The State through Prosecutor General Sindh 2023 SCMR 364; Khalil Ahmed Soomro v. The State PLD 2017 SC 730; Shahzada Qaiser Arfat alias Qaiser v. The State and another PLD 2021 SC 708; Abdul Rehman v. The State and others 2023 SCMR 2081; Saad Zia v. The State and others 2023 SCMR 1898 and Muhammad Aziz alias Mana v. The State and others 2023 SCMR 1773 rel. M. Imran Asmat Chaudhry for Petitioner. Hafiz Asghar, DPG with Arusa, Inspector for the State. Rana M. Raza for the Complainant.

Summary: Criminal Procedure Code (V of 1898)--- ----Ss. 497(2) & 498---Penal Code (XLV of 1860), Ss. 341, 337-A, 506(ii), 147 & 148---Wrongful restraint, causing shajjah, criminal intimidation, rioting, rioting armed with deadly weapons---Ad interim pre-arrest bail, confirmation of---Further inquiry---Allegations against the accused-petitioners were that they caused severe injuries to the complainant and his father over a parking issue---From perusal of record it transpired that the petitioner No.1/accused and two others were directly nominated in the FIR and the allegations levelled therein indeed disclosed commission of the offences under Ss.147, 148, 341, 337-A & 506(ii), P.P.C---Alleged occurrence had been committed at a road which was a populated area and was a hub of selling auto-parts of various vehicles by various people of almost all the districts as well as citizens of different provinces and various kinds of workshops of vehicles were situated in the area---Despite that, the complainant had failed to produce a single private witness regarding the occurrence which showed that the complainant had malafidely lodged the instant FIR just to harass the petitioners/accused in the hands of police---Moreover, as per contents of FIR, the petitioners/accused had beaten complainant and his father as such the complainant and his father got severe injuries on head and vital parts of body, whereas, the prosecution had failed to submit Medico-Legal Report despite lapse of two months---Moreover, the principal accused, who was directly nominated in the FIR, had already been released on bail by the Judicial Magistrate and acquitted him from the charges levelled in the FIR due to compromise between the parties, hence, the petitioners/accused were also entitled for concession of bail---Grant of pre-arrest bail was not to be withheld as a punishment, rather it was meant to protect innocent persons from humiliation and undue harassment at the hands of the police or complainant when a case of mala-fides or ulterior motive was made out---Admittedly, Ss. 147, 341 and 337-A, P.P.C, were bailable, whereas, Ss. 148 and 506(ii), P.P.C, were non-bailable, the punishment provided therein did not fall within the prohibitory clause of S. 497, Cr.P.C.---Allegations of mala fide on the part of the complainant as well as the police could not be ruled out at this stage---Bail application was allowed and interim bail already granted to the applicants was confirmed, in circumstances. 2009 YLR 184; 2009 YLR 187; 2016 YLR 2507 and 2017 YLR Note 32 ref. Mohammad Saleem for Petitioner. Malik Sherbaz, Addl. A.G. for the State. Mir Zeeshan Akhlaq for the Complainant. Date of hearing: 24th September, 2025.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S.498---Penal Code (XLV of 1860), S.406---Ad-interim pre-arrest bail, confirmation of----Criminal breach of trust---Inordinate delay in lodging of FIR---Dispute between the parties to be determined by Trial Court---In a pre-arrest bail, only a tentative assessment of the evidentiary material produced before the Court is to be made at bail stage---Based on a tentative assessment of the record, it evinced that there was an inordinate delay in lodging of FIR---Such delay shattered the sanctity of the crime report and reflected that the same was consumed in fabricating, deliberating, consulting and concocting a false story---The question of constituting the offence of criminal breach of trust under S.406, P.P.C, in the light of the dispute, would be determined by the Trial Court after recording the evidence---Ad-interim pre-arrest bail already granted to the petitioner was confirmed---Bail petition was allowed, in circumstances. Aamir Bashir and another v. The State and others 2017 SCMR 2060; Khalid Javed Gillan v. The State PLD 1978 SC 256; Jamaluddin and another v. The State 2023 SCMR 1243; Khair Muhammad and another v. The State through P.G. Punjab and another 2021 SCMR 130; Abdul Ghafoor Gondal v. The State 2020 SCMR 861 and Syed Darbar Ali Shah and others v. The State 2015 SCMR 879 ref. (b) Criminal Procedure Code (V of 1898)--- ----Ss.498 & 497(2)---Penal Code (XLV of 1860), S.406---Ad-interim pre-arrest bail, confirmation of---Criminal breach of trust---Pre-requisites, missing of---Pre-arrest bail stage---Merits of case, touching upon---Ex-facie from the contents of the FIR it was revealed that the matter pertained to business transaction and the elements of entrustment as well as misappropriation being pre-requisites for attraction of S.406, P.P.C, were missing in the present case---Although, it was a pre-arrest bail application and merits for grant of bail before arrest and after arrest are altogether different but while granting pre-arrest bail even the merits of the case can be touched upon---Thus, sending the petitioner behind bars would cause irreparable loss to his reputation and would serve no useful purpose---Hence, the case of the petitioner squarely fell within the ambit of subsection (2) of S.497 of Code of Criminal Procedure, 1898, calling for further inquiry into his guilt---Ad-interim pre-arrest bail already granted to the petitioner was confirmed---Bail petition was allowed, in circumstances. Ali Raza v. The State and others 2022 SCMR 1223; Khair Muhammad and another v. The State through P.G. Punjab and another 2021 SCMR 130; Sajid Hussain alias Jojo v. The State PLD 2021 SC 898 and Khalil Ahmed Soomro and others v. The State PLD 2017 SC 730 ref. Barrister Danyal Ijaz Chadhar with the Petitioner. Fakhar Abbas, Deputy Prosecutor General with Ismaeel, ASI for the State.

Summary: Criminal Procedure Code (V of 1898)--- ----S. 498---Penal Code (XLV of 1860), S. 489-F---Dishonestly issuing a cheque---Ad-interim pre-arrest bail, confirmation of---Allegation against the applicant was that he issued four cheques in lieu of payment for a vehicle purchased from the complainant, which cheques were dishonoured upon presentation---Circumstances of the case revealed that the FIR was registered after a considerable delay of more than three years without any plausible explanation---Such an unusual delay casted doubt on the veracity of the prosecution story and warranted further inquiry into the genuineness of the transaction as well as the actual liability of the applicant in terms of S.497(2), Cr.P.C.---Since the alleged offence did not fall within the prohibitory clause of S.497(1), Cr.P.C., the applicant had made out a case for confirmation of bail---Principle that bail is a rule and jail is an exception must also be kept in view, especially where the prosecution's own case suffered from delay and material deficiencies---The matter essentially had arisen out of a business transaction between the parties relating to the sale of a vehicle, thereby giving the case a strong color of civil dispute---Complainant had not placed on record any sale agreement, transfer documents or other supporting evidence to substantiate the transaction beyond the narration of the FIR---Such missing elements raised serious doubts which could not be ignored at this stage---Furthermore, the applicant was not a habitual offender nor he had any previous criminal record---Police raided the house of applicant and the apprehension of arrest further justified the applicant's plea that he was being subjected to undue harassment---On the tentative assessment, a case for grant of pre-arrest bail was made under S.498, Cr.P.C---Petition was allowed and ad-interim pre-arrest bail already allowed to the petitioner was confirmed, in circumstances. Ali Anwar Paracha v. The State 2024 SCMR 1596; Zafar Nawaz v. The State 2023 SCMR 1977; Abdul Saboor v. The State through A.G KPK 2022 SCMR 592 and Noman Khaliq v. The State 2023 SCMR 2122 rel. Applicant in person. Raja M. Khalil-uz-Zaman for the Complainant. Ms. Rubina Qadir, D.P.G for the State. Date of hearing: 10th September, 2025.

Summary: Bail granted --- (a) Penal Code (XLV of 1860) ---- S. 489-F ---- Dishonour of cheque issued by an advocate to his client for professional fees ---- Scope and applicability. Complainant, an advocate, lodged F.I.R. under S.489-F, P.P.C., against his client for dishonour of cheques allegedly issued towards payment of professional fee --- Question before the Court was whether a lawyer may initiate criminal proceedings against a client for failure to pay outstanding professional fees --- Held, that relationship between counsel and client is fiduciary in nature and founded on trust, confidentiality, and professional ethics --- Rule 155 of the Pakistan Legal Practitioners and Bar Councils Rules, 1976, and Article 9 of the Qanun-e-Shahadat Order, 1984, prohibit advocates from disclosing privileged communications or converting professional disputes into criminal controversies --- Non-payment of legal fees, being a civil liability, cannot ordinarily attract penal consequences under S.489-F, P.P.C., unless dishonest intent (mens rea) is clearly established --- Section 489-F, P.P.C., is a safeguard against fraud, not an instrument for enforcing civil recoveries --- Recovery of unpaid fees lies within civil jurisdiction under S.73 of the Contract Act, 1872, and provisions of the Civil Procedure Code, 1908 --- Criminal process must not be used to compel or coerce payment of professional dues --- Reliance placed on 2023 SCMR 1948 and 2013 SCMR 51. (b) Professional Conduct ---- Advocate’s duties and limitations in disputes over fees ---- Rule 155, Pakistan Legal Practitioners and Bar Councils Rules, 1976; American Bar Association Model Code EC 2-23. Rule 155 mandates advocates to avoid controversies with clients over compensation and to resort to litigation only to prevent injustice, imposition, or fraud --- International professional ethics, including ABA Model Code EC 2-23, similarly enjoin that lawyers must resolve fee disputes amicably and refrain from suing clients except to prevent fraud --- The initiation of criminal complaints by lawyers against their clients for fee recovery violates the spirit of professional discipline, confidentiality, and dignity of the Bar --- Advocates are officers of the court and servants of the public interest; abuse of criminal process to pressurize clients erodes professional integrity and public confidence in the justice system. (c) Qanun-e-Shahadat Order (X of 1984) ---- Art.9 ---- Privileged communications between advocate and client ---- Extent of protection. Article 9 of the Qanun-e-Shahadat Order, 1984, safeguards all communications made in confidence between advocate and client during professional engagement --- Disclosure of such communications or using them as basis for criminal prosecution is impermissible except in limited circumstances expressly provided in the proviso (communications made in furtherance of illegal purpose, or observations showing commission of a crime or fraud after commencement of employment) --- Filing of criminal complaints for fee recovery risks violation of professional privilege and fiduciary trust. (d) Administration of justice ---- Abuse of process ---- Misuse of criminal machinery by members of the Bar. Court took judicial notice of alarming increase in F.I.Rs. registered by advocates against their clients and others, as reflected in official AIGP Legal report submitted before Sindh High Court --- Such trend was held to impede efficient administration of justice and to threaten collapse of the judicial system if continued --- Lawyers using criminal process as a means of coercion in civil or fee-related disputes undermine both the nobility of their profession and public trust --- The credibility of the Bar rests on adherence to ethics, not on exertion of pressure through police or criminal law. Disposition: Petition converted into appeal and allowed; impugned order of High Court set aside; petitioner admitted to pre-arrest bail upon furnishing bonds of Rs.200,000 with one surety in the like amount to the satisfaction of the Trial Court.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S. 498---Penal Code (XLV of 1860), Ss. 436, 427, 337-H(2), 148 & 149---Mischief by fire and explosive substance, mischief causing damage to the amount of fifty rupees, rash or negligent act to endanger human life or personal safety of others, rioting, rioting armed with deadly weapons, unlawful assembly---Pre-arrest bail, dismissal of---Allegations against the accused-applicant were that he along with five others set ablaze the houses of complainant party along with their surrounding hedge by means of matchstick as a result whereof the hedge, houses and the household articles lying there were burnt to ashes, whereas, the co-accused persons resorted to aerial firing---From perusal of the record it would be seen that the applicant was named in the FIR and specific role of setting the houses on fire with surrounding hedge and household articles of complainant by means of matchstick was assigned to him---So far as delay in lodgment of FIR was concerned, delay per se was no ground to discard and/discredit the entire prosecution case/version---No mala fide was shown on the part of complainant to implicate the applicant/accused in the case falsely, particularly, nothing had been placed on record to substantiate the ground urged with regard to any land dispute between the parties---Principles governing thegrant of post arrest bail and those for seeking pre-arrest bail were altogether different---Basic ingredients for grant of pre-arrest bail were lacking in this case---Per progress report submitted by the Trial Court, after framing of charge against the accused, witnesses had been appearing but the defence was seeking adjournment on one or the other pretext---Such brazen attitude of accused showed they had no nexus or concern with trial but to press bail application only to linger on the trial proceedings to defeat the interest of prosecution---Applicant had no case for grant or confirmation of pre-arrest bail--- Bail petition was dismissed, in circumstances. Rana Muhammad Arshad v. Muhammad Rafique and others PLD 2009 SC 427 rel. (b) Criminal Procedure Code (V of 1898)--- ----Ss. 497 & 498---Bail order---Observations of the Court---Scope---Observations made in bail order are tentative in nature only for the purpose of deciding the bail application, which shall not, in any manner, influence the Trial Court at the time of final decision of the subject case. Abdul Rehman A. Bhutto for Applicant. Ali Anwar Kandhro, Addl. Prosecutor General, Sindh for the State. Javed Ahmed Soomro for the Complainant. Date of hearing: 15th September, 2025.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S. 498---Penal Code (XLV of 1860), Ss. 324, 452, 114, 337-H(2), 147, 148 & 149---Attempt to commit qatl-i-amd, house-trespass after preparation for hurt, assault or wrongful restraint, abettor present at the time of committing offence, rash or negligent act, rioting, rioting armed with deadly weapons, unlawful assembly---Ad-interim pre-arrest bail, confirmation of---Further inquiry---Allegations against the accused-petitioner were that he along with his co-accused persons caused firearms injuries to the injured after entering into the house of complainant---Although the applicant was named in the FIR with an attributed role, there existed serious inconsistency between the ocular version and medical record---Initially the injury on the thigh was opined to be of blunt weapon---Subsequently, overwriting was introduced in the word 'firearm'---Such tampering weakened the confidence with which medical evidence could be used in support of ocular testimony---Furthermore, the location of the alleged injuries, i.e. thigh and index finger, being non-vital parts, and the absence of repeated fire, prima facie, diluted the prosecution's claim of intent to commit qatl-i-amd---In the present case, keeping in view the disputed medical evidence, the nature of injuries, the admitted enmity between the parties, the delay in lodging of FIR, and the fact that the challan had already been submitted and the applicant was not required for further investigation, the case of the applicant clearly fell within the ambit of further inquiry under S.497(2), Cr.P.C.---At the bail stage only tentative assessment of material is to be undertaken---Ad-interim pre-arrest bail granted to the applicant earlier was confirmed, in circumstances. Muhammad Asif v. The State 2017 SCMR 486 and Muhammad Rafique v. The State 2019 SCMR 1068 ref. Muhammad Mansha v. The State 2018 SCMR 772 and Tariq Bashir and 5 others v. The State PLD 1995 SC 34 rel. (b) Criminal Procedure Code (V of 1898)--- ----S. 498---Bail order---Observations of the Court---Scope---Observations made in the bail order are tentative in nature and shall not prejudice the Trial Court in its determination on merits. Abdul Sattar Mahesar for Applicant. Abdul Raheem Mahar for the Complainant. Muhammad Raza Katohar, DPG for the State. Date of hearing: 3rd September, 2025.

Summary: Bail granted --- (a) Pakistan Penal Code (XLV of 1860) ---- Ss. 324, 337A(i), 337A(ii), 337F(ii), 148 & 149 --- Criminal Procedure Code (V of 1908) ---- S. 497 --- Bail Before Arrest --- Pre-Arrest Bail --- Maintainability --- Instant petition has been filed by Muhammad Irshad and Ali Raza (petitioners) against impugned order dated 23.04.2025, in Crl. Misc. No.14086-B of 2025, passed by Lahore High Court, Lahore with prayer to set-aside said order and grant pre-arrest bail to petitioners in case FIR No.160/2025, dated 28.01.2025, offences under Sections 324/337A(iii)/337A(ii)/337F(ii)/148/149 PPC, registered at police station Zafarwal, District Narowal --- Arguments heard --- Record perused --- It is evident from perusal of order dated 23.06.2025, of this Court that instant petition has already been partially dismissed to extent of Muhammad Sajid (Muhammad Sajid Iqbal) petitioner No.1, on account of his arrest --- Insofar as case of Muhammad Irshad and Ali Raza (petitioner Nos.2 & 3, respectively), is concerned, we have noted that as per contents of FIR, Muhammad Irshad (petitioner No.2), was assigned role of inflicting wooden 'bala' on forehead of Younas PW, whereas Ali Raza petitioner No.3, has been assigned role of inflicting hatchet blow on back side of head of Sufiyan PW --- Injuries attributed to both petitioners were declared by concerned Medical Officer to be punishable under section 337A (ii) PPC --- During investigation, it was concluded by Investigating Officer that Muhammad Irshad (petitioner No.2), was merely present at spot and he did not cause any injury on any member of complainant party --- Said findings of Investigating Officer have made prosecution case as one of further inquiry entitling Muhammad Irshad (petitioner No.2), to relief of pre-arrest bail as observed in judgments reported as 'Ehsan Ullah v. The State" (2012 SCMR 70) and 'Muhammad Ishaq v. The State and others' (2012 SCMR 1137) --- So far as Ali Raza (petitioner No.3), is concerned, we have noted that in medico legal report of Sufiyan PW, Medical Officer has mentioned injury on his head as skin deep --- Section 337A(ii) PPC, is attracted when bone under injury is exposed but it is evident from perusal of medico legal report of Sufiyan PW that no such finding regarding exposing bone of head of Sufiyan PW was mentioned in report rather it was categorically mentioned that injury on head of Sufiyan PW was skin deep, hence offence under section 337A(i) PPC, which is bailable offence, is attracted instead of section 337A(ii) PPC, to extent of abovementioned injury entitling Ali Raza (petitioner No.3), to grant of pre-arrest bail --- Reference in this context may be made to judgment reported as "Muhammad Qasim and another v. The State and others" (PLD 2014 Lahore 555) --- We have also noted that sixteen (16) named and 4/5 unknown accused persons total 20/21 accused persons have been implicated in this case by complainant, therefore, possibility of malafide involvement of petitioners in this case by complainant while using wider-net cannot be ruled out at this stage --- In light of above discussion, this petition is converted into appeal and same is partly allowed --- Consequently, impugned order is set-aside to extent of Muhammad Irshad and Ali Raza (petitioner Nos.2 & 3, respectively) --- Ad-interim pre-arrest bail already granted to Muhammad Irshad and Ali Raza (petitioner Nos.2 & 3, respectively), vide order dated 23.06.2025, is hereby confirmed subject to their furnishing of fresh bail bonds in sum of Rs. 50,000/- (rupees fifty thousand only) each with one surety each in like amount to satisfaction of learned Trial Court --- Petition was allowed accordingly.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S. 498---Penal Code (XLV of 1860), Ss. 302(b), 324, 337-H(2), 147, 148 & 149---Qatl-i-amd, attempt to commit qatl-i-amd, rash or negligent act to endanger human life or personal safety of others, rioting, rioting armed with deadly weapons, unlawful assembly---Pre-arrest bail, recalling of---Allegation against the accused-applicants was that due to their indiscriminate firing, one person lost his life and another sustained grievous injuries---Since both parties were admittedly known to each other, the possibility of misidentification did not arise---Furthermore, the police had secured crime empties as well as blood stained earth from the scene of occurrence---Ocular account was corroborated by the medical evidence and the statements of prosecution witnesses, recorded under S.161, Cr.P.C by the Investigating Officer, supported the version advanced by the complainant---It was alleged by defence that counter cases had been registered by both parties against each other, the applicants were thus entitled to the concession of pre-arrest bail, however, mere filing of counter cases or cross cases, without any element of genuineness, could not by itself constitute a valid ground for the grant of bail---Sufficient material was available on the record to connect the applicants/accused with the commission of alleged offence---Offence with which the applicants stood charged fell within the prohibitory clause of S.497, Cr.P.C---Furthermore, no ill-will or mala fide was alleged against the complainant party by the applicants and even otherwise they had been shown in FIR with specific role---Applicants had failed to make out the case for the confirmation of interim pre-arrest bail---Thus, the interim bail granted to the applicants earlier was recalled---Accordingly, the interim bail already granted to the applicants/accused was dismissed. 2019 SCMR 1129 rel. (b) Criminal Procedure Code (V of 1898)--- ----S. 498---Bail---Tentative assessment---Scope---Observations made in bail orders are tentative in nature and would not influence the Trial Court while deciding the case of the applicants on merits. Rao Faisal Ali for Applicants (in Criminal Bail Application No. S-144 of 2025). Ghulam Abbas Dalwani, Deputy P.G for the State (in Criminal Bail Application No. S-144 of 2025). Afzal Karim Virk for the Complainant (in Criminal Bail Application No. S-144 of 2025). Rao Faisal Ali for Applicant (in Criminal Bail Application No. S-151 of 2025). Ghulam Abbas Dalwani, Deputy P.G for the State (in Criminal Bail Application No. S-151 of 2025). Afzal Karim Virk for the Complainant (in Criminal Bail Application No. S-151 of 2025). Date of hearing: 20th August, 2025. Amjad Ali Sahito, J .--- By this single order, I intend to dispose of both aforementioned bail applications, whereby the applicants/ accused seek pre-arrest bail in same Crime No.17 of 2025 for offence punishable under sections 302, 324, 337-H(2), 147, 148 and 149, P.P.C registered at PS Mirwah Gorchani, after their bail plea has been declined by learned Additional Sessions Judge-I/MCTC, Mirpurkhas vide order dated 27.05.2025.