In this view of the matter, the question whether the cheque was issued towards fulfilment of an obligation within the meaning of section 489-F P.P.C. is a question, which is to be determined by the learned Trial Court after recording of evidence.

Bail before arrest is an extraordinary relief which cannot be granted unless person seeking it satisfies conditions specified under section 497(2) Cr.P.C. and establishes existence of reasonable grounds leading to believe that there are in fact sufficient grounds warranting further inquiry.

It is a settled principle of law that relief of pre-arrest bail can only be granted to the accused if he establishes the mala fide on the part of complainant or the police.

Crl.P.L.A.619-L/2024
Azhar Pervaiz Bukhari v. The State, etc
Mr. Justice Syed Hasan Azhar Rizvi
01-07-2024