IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIRABAD.

Cr Misc: Appln: No. of 2020

Mst. Shahida D/O Muhammad Idrees W/o Ubedullah by

Caste Abro, Muslim, adult r/o Sabzi Market Road Moro,
District Naushahro Feroze.
----------------------------------- Applicant.

Versus

1. Gull Hassan S/O Muhammad Idrees

By Caste Abro,

2. Nawab S/o Abdul Raheem by caste Abro,

By Caste Abro,
Both Muslims, adults resident of Saffan Muhalla Doultpur,
District Shaheed Benazir Abad.
.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C.

FOR RECOVERY OF DETENUE SANIA NAZ D/O MUHAMMAD RAFIQUE.

It is prayed on behalf of the applicant above named that this Honourable court may
kindly be issued Rule Nisi against the opponents may be pleased to issue direction to
SHO PS Doultpur to recover Mst. Sania Naz D/O Muhammad Rafique from the illegal
custody of the opponents and produce the same before Honourable court and custody
of the person of Mst. Shahida may be handed over to the applicant on the facts and
grounds mentioned here in below.

1). That Mst. Sania Naz aged about 19 years residing with her mother on aforesaid

address. That the opponent No.1 is maternal uncle of Mst. Saina Naz. That some 2/3

months back the opponent No.1 came at the house of house of applicant and discussed

about the marriage of Mst. Sania Naz and informed that and he wants to marry Mst.

Saina Naz with the person of his choice on that the applicant and Mst. Saina Naz

refused his proposal on that he become annoyed and want out from the house of

applicant but he was continuously insisting the applicant to get married Mst. Saina Naz
with his chosen person that about fifteen days back when the opponent No.1 again

arrived at the house of applicant and repeated his illegal demand on that the applicant

bluntly refused him on that the opponent No.1 become angry and harsh and went from

there while issuing threats that when he will get opportunity will take Mst. Saina Naz and

get her marriage with the person of his choice.

2. That on 26.05.2020 the third of Eid ul Fitar, the applicant along with Mst. Saina

Naz and with her husband came at Doultpur in the house of her brother (opponent

No.1) where the opponent No.2 was also present there, to resolve the matter as Mst.

Sania Naz is not ready to marry with the choice person of opponent No.1, the applicant

disclosed this fact to opponent No.1 on that opponent No.1 made request to the family

of applicant to make stay in his house for a night as he want some time to understand

the fact on that the applicant stayed in the house opponent No.1 and on next morning

when the applicant awoke and not found her daughter after that the applicant enquired

about her daughter from opponent No.1 on that opponent No.1 firstly asked her that her

daughter did not come in his house but only applicant and her husband came here after

some time he has disclosed that he has with the help of opponent No.2 concealed the

daughter of applicant and refused to returned Mst. Sania Naz to her mother and father

and took out pistol from the folder of his shalwar and on the awe of weapon turned out

the applicant and his husband from his house.

3. Thereafter the applicant and her husband approached the elders of family they

also contacted with opponents but they also refused to return the deteune.

4). That the applicant apprehend that the opponent No.1 will get marry the detenue

with the person of his on choice on money without the consent of detenue for which he

the opponent No.1 is not authorized legally and morally and such act will be against the

law.

5). That the further grounds would be argued at the time of hearing of this applicant

with the kind permission of this Honourable Court. custody of the detenue may be

ordered to be produced so that her statement may be recorded and she may be allowed

to go with the applicant.

It is repectfuly paryed behalf of applicant that his Honourable court may graciously be

peased to the issued writ of Habeas corpus and direct the opponent No.3 to recover the

detenue from the illegal custoy of opponent No. 1 and 2, and produce before this

Honourable court and handover the custody of detenue Mst. Sania Naz to her

mother/applicant.

Prayer is made in the larger interest of justice.

Applicant.
IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIRABAD.

Cr Misc: Appln: No. of 2020

Mst. Shahida ----------------------------------- Applicant.

Versus

Ramesh Mal and others

----------------------------- Opponents.

AFFIDAVIT

I, Mst. Shahida D/O Muhammad Idrees W/o Ubedullah by Caste Abro, Muslim, adult r/o
Sabzi Market road Moro, Naushahro Feroze, do here by state on oath as under:-

1. That I am applicant of accompanying application U/S 491 Cr. P.C and same has
been drafted under my instructions, the contents of same are true and correct.

2. That my daughter Sania Naz is in illegal detention of opponents.

3. That unless the accompanying application is allowed I shall be seriously

prejudiced and suffer irreparable loss.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIRABAD.
Cr Misc: Appln: No. of 2014.

Akbar Ali S/o Ahmed Ali, Arain,

R/o:- Near Farooqi Masjid, Taj Colony, Nawabshah, District
Shaheed Benazir Abad.
----------------------------------- Applicant.

Versus

S H O P.S Daur.
----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

For recovery of detunes Akbar Ali, Muhammad Anwar both sons

of Ali Muhammad Arain, 3). Hakim Ali, Abdul Hameed both sons
of Ahmed Ali and Sajid Ali son of Muhammad Boota.

It is humbly submitted as under:-

1). That on 03.09.2014, early in the morning at about 06:00 Am, I was present in my

house along with my brothers Hakim Ali, Abdul Hameed and niece namely Sajid Ali son

of Muhammad Boota and other family members. My door was knocked and I went at my

door then I saw that five/ six police officials were present and thereafter the same were

entered into my house forcibly, with out any FIR or complaint and took my brothers
named above along with my niece and went out form my house, in presence of me and

my other family members.

2). That thereafter, I went behind them and I saw two police mobiles were lying in

front of my house of PS Daur and I seen that my uncles were also present/ sitting in

one police mobile. P/…2

P/…2

3). That I inquired about the act of police then they replied me that they have not

bound to reply me.

4). Thereafter I went PS Daur along with my brother Qasim Ali and inquired about

the my brothers, uncles and niece but the Police of PS did not disclose my relatives but

police official demanded money for their release and issued threats if the applicant not

full fill their demand they will implicated the detunes in false cases.

5). That since there is no any case against my relatives including my uncles,

brothers and niece, who are respectable and law abiding citizens and they are illegally

detained by opponent with out any reasonable explanation.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the

opponents and any Magistrate may kindly be appointed as Commissioner to conduct

raid at P.S Daur so that the detainees may be recovered and may be produced before

the Honourable court to get their statements recorded and detainees may be set at

liberty as I apprehended that false cases may be registered against the detainees by

the opponent, and action in accordance with law may be taken against the opponents.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIR ABAD.
Cr Misc: Appln: No. of 2014

Akbar Ali.
----------------------------------- Applicant.

Versus

S H O P.S Daur.
----------------------------- Opponent.

AFFIDAVIT

I, Akbar Ali S/o Ahmed Ali, Arain, r/o: Near Farooqi Masjid, Taj Colony,
Nawabshah, District Shaheed Benazir Abad, do here by state on oath as
under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my relatives are in illegal detention of opponent.

3. That I apprehend that opponents may give loss to the detunes.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIRABAD.
Cr Misc: Appln: No. of 2014.

Abdul Jabbar S/o Raheem Bux, Sohu, r/o Village Khar

Taluka Kazi Ahmed, District Shaheed Benazir Abad.
----------------------------------- Applicant.

Versus

S H O P.S Doulat Pur

----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

For recovery of detenue Mian Dad Alias Dado S/o
Allah Jurio Sohu.

It is humbly submitted as under:-

1). That on 01.08.2014 the detune along with Wazeer Umrani and Abdul Ghafoor

Sohu going to his village on auto Chingchi Rakshaw at about 04.00 pm when they

reached near to bye pass Bahadur petrol pump the SHO namely Noor Muhammad

along with his three sub ordinates staff standing there and they stopped chingchi

Rakshaw and asked the detnue that your evidence is required in criminal case so that

the SHO kept the detnue and went away on police mobile, in presence of witnesses.

2). That thereafter, witnesses came at village and disclosed the facts to the applicant

who is the cousin of the detnue. That the applicant along with Abdul Ghafoor went to

P.S and inquired about the detnue but the police official demanded money for his

release and issued threats if the applicant or detnue not full fill their demand they will

implicated the detnue in false cases and asked the applicant he comes tomorrow.

3). That on 02.08.2014 the applicant again approached at P.S Doulat Pur but on that

date the police officials bluntly refused him and asked that neither the detnue is arrested

by them nor they know about the detnue.

4). That since there is no any case against my cousin, who is respectable and law

abiding citizen and he is illegally detained by opponent with out any reasonable

explanation.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the

opponents and any Magistrate may kindly be appointed as Commissioner to conduct

raid at P.S Doulat Pur so that the detainee may be recovered and may be produced

before the Honourable court to get his statement recorded and detainee may be set at

liberty as the opponents have been using technical methods for screening the detainee

in day time and action in accordance with law may be taken against the opponents.

Applicant.

IN THE COURT OF SESSIONS JUDGE, SHAHEED

BENAZIR ABAD.
Cr Misc: Appln: No. of 2014

Abdul Jabbar
----------------------------------- Applicant.
 Versus

S H O P.S Doulat Pur

----------------------------- Opponent.

AFFIDAVIT

I, Abdul Jabbar S/o Raheem Bux, Sohu, r/o Village Khar Taluka Kazi Ahmed,
District Shaheed Benazir Abad, do here by state on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my cousin is in illegal detention of opponents.

3. That I apprehend that opponents may give loss to the detenue.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.

IN THE COURT OF SESSIONS JUDGE, SHAHEED

 BENAZIRABAD.
Cr Misc: Appln: No. of 2014.

Mehrab S/o Muhammad Hassan Zardari, r/o Village Zanwar

Lashkari Zardari, 23 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad.
----------------------------------- Applicant.

Versus

S H O P.S Balu Ja Quba

----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

For recovery of detenue Zulfiqar S/o
Muhammad Sadiq Zardari.

It is humbly submitted as under:-

1). That the opponent along with his subordinate staff namely P.C Ali Nawaz

Zardari, P.C Gada Hussain Zardari and three unknown Police Officials on government

vehicle with dully armed with deadly weapons on 20-06-2014 at about 5 pm illegally and

unlawfully entered into the land of my cousin detune namely Zulfiqar and took him with

them.

2). That I enquired from the SHO P.S Balu Ja Quba, that why my cousin, was being

taken them, on which the opponent replied to me that we have not taken any person, on

next day I along with Sawan S/o Lashkari Khan Zaradri again went to P.S Balu Ja Quba

and seen my cousin was in lockup then I approached the SHO and requested him that

my cousin in your custody without any complaint and release him but concerned SHO

refused us and demanded bribery and in case of failing to compliance his demand he

will made false cases against my cousin.

P/..2

P/..2
3). That since there is no any case against my cousin, who is respectable and law

abiding citizen and he is illegally detained by opponent with out any reasonable

explanation.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the

opponents and any Magistrate may kindly be appointed as Commissioner to conduct

raid at P.S Balu Ja Quba so that the detainee may be recovered and may be produced

before the Honourable court to get his statement recorded and detainee may be set at

liberty as the opponents have been using technical methods for screening the detainee

in day time and action in accordance with law may be taken against the opponents.

Applicant.
IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIR ABAD.
Cr Misc: Appln: No. of 2014

Mehrab Zardari
----------------------------------- Applicant.

Versus

SHO P.S Balu Ja Quba

----------------------------- Opponents.

AFFIDAVIT

I, Mehrab Zardari S/O Muhammad Hassan, r/o Zanwar Lashkari

Zardari, 23 Dad, Taluka Nawabshah, District Shaheed Benazir Abad, do here by state
on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my cousin is in illegal detention of opponents.

3. That I apprehend that opponents may give loss to the detenue.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIRABAD.
Cr Misc: Appln: No. of 2011

Wazir Mal S/O Chattan Mal Oad, r/o Ward No:1, Mohalla
Gulshan e Bhittai, Nawabshah, District Shaheed Benazir
Abad.
----------------------------------- Applicant.

Versus

4. Ramesh Mal S/O Siano Mal

5. Pool Mal S/O Siano Mal
6. Rabail Mal S/O Siano Mal
7. Paroo Mal S/O Siano Mal
8. Naresh S/O Siano Mal
9. Siano Mal S/O Not Known
All residence of village Mumtaz Jamali, near Bandhi, Taluka Daur,
District Shaheed Benazir Abad.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C.

For recovery of detenue shirimati Naseeban
D/O Wazir Mal W/O Ramesh Mal.

It is prayed that this Honourable court may be pleased to issue direction to SHO PS
Bandhi to recover detenue shermati Naseeban D/O Wazir Mal W/O Ramesh Mal from
the custody of the opponents and produce the same before Honourable court and
custody of the person of shermati Naseeban may be handed over to the applicant on
the facts and grounds mentioned here in below.

1). That the detenue shirmati Naseeban is the real daughter of the applicant who

was abducted by the opponents and forcibly married with

P/..2

P/..2

opponent No:1 for which the applicant being poor person tried to his level best to return

her back or the faisla may be held but of not avail.

2). That since a year neither the applicant nor her wife has been allowed to see the

detenue.

3). That the applicant apprehend that the life of detenue is at stake at the hands of

the opponents.

4). That the custody of the detenue may be ordered to be produced so that her

statement may be recorded and she may be allowed to go with the applicant.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIR ABAD.
Cr Misc: Appln: No. of 2011

Wazir Mal
----------------------------------- Applicant.

Versus

Ramesh Mal and others

----------------------------- Opponents.

AFFIDAVIT

I, Wazir Mal S/O Chattan Mal Oad, r/o Ward No:1, Mohalla Gulshan e
Bhittai, Nawabshah, District Shaheed Benazir Abad, do here by state on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my daughter Naseeban is in illegal detention of opponents.

3. That I apprehend that opponents may give loss to the detenue.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

Cr Misc: Appln: No. of 2011

Mst. Lateefan W/O Muhammad Jatoi,

adult, Muslim, r/o: Village Chibhar Jatoi, Taluka Kazi
Ahmed, District Shaheed Benazir Abad.
----------------------------------- Applicant.

Versus

10. DSP, Taluka Nawabshah.

11. SHO Police Station, Taluka, Nawabshah.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That opponents on 15-06-2011 at about 5 am, illegally, unlawfully and forcibly

entered into our house along with Nooro Jatoi, Qadan Jatoi, Mehboob Jatoi, Ghazi Jatoi

and 30/35 police personals dully armed with deadly weapons and took Gul Hassan son

of Baloo, Hubdar son of Chibhar and Baby Zareena D/O Muhammad ( my brother in

law, son of my brother in law and my daughter respectively) with them. They also took

sixteen bags of wheat, gold ornaments, Rs. 50,000/- and a tractor with them.

2). That we enquired from the opponents that why my daughter, my brother in law

and son of my brother in law were being taken them, on which the opponents replied to

approache opponent No. 2 at PS Taluka, then it would be disclosed as a result of which

I approached the opponents at Nawabshah at their respective offices but instead of

telling me truth, they threatened that they would also detain me if I ever enquired about

detainees. P/..2

P/..2
3). That since there is no any case against my daughter, who is minor one and she

is illegally detained along with Gul Hassan and Hubdar by opponents with out any

reasonable explanation.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the

opponents and any Magistrate may kindly be appointed as Commissioner to conduct

raid at P.S Taluka Nawabshah so that the detainees may be recovered and may be

produced before the Honourable court to get their statements recorded and detainees

may be set at liberty as the opponents have been using technical methods for screening

the detainees in day time and action in accordance with law may be taken against the

opponents.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

Cr Misc: Appln: No. of 2011

Mst. Lateefan
----------------------------------- Applicant.

Versus

DSP Taluka, Nawabshah & another

----------------------------- Opponents.

AFFIDAVIT

I, Mst. Lateefan W/O Muhammad Jatoi, adult, Muslim, r/o: Village

Chibhar Jatoi, Taluka Kazi Ahmed, District Shaheed Benazir Abad, do here by state on
oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my daughter baby Zareena, my brother in law Gul Hassan and son of my
brother in law namely Hubdar are in illegal detention of opponents.

3. That I apprehend that opponents may give loss to the detainees.

4. That justice requires that my accompanying application may be allowed.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE, NAUSHEHRO FEROZE.

Cr Misc: Appln: No. of 2011

Muhammad Ismail son of Khuda Bux, Mari, adult, mulsim,

r/o: Taj Colony Nawabshah.
----------------------------------- Applicant.

Versus

12. Aijaz son of Alam Khan Mari.

13. Alam Khan son of Sawan Khan, Mari
14. Saifal son of Laique Mari.
15. Ghulam Hyder son of Ghulam Rasool,Mari.
16. Ghulam Rasool son of Shah Nawaz, Mari
17. Ghulam Muhammad son of Shah Nawaz, Mari.

All r/o: Village Haji Khan Mari, UC Bhorti, Taluka

Kandiaro, District Naushehro Feroze.

18. SHO P.S Tharu Shah.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That my daughter namely Mst. Sajida aged about 13/14 years (minor) was

residing with me at Taj Colony, Nawabshah and was study in class 8 th.
2). That on 07-06-2011 opponents No.1 to 3 forcibly entered into my house and on

awe of the weapons abducted/ kidnapped my minor daughter and took with them.

3). That since my daughter namely Mst. Sajida is minor and can not understand the

good of bad of the life very well but opponents No.1 to 3 are trying to forcibly get my

daughter marry with opponent No. 1.

P/..2

P/..2

4). That I got registered an FIR bearing crime No. 116 of 2011 U/S 365-B and 452

PPC at PS A Section Nawabshah on 08-06-2011 but the said Police did not recover my

daughter from the opponents as yet.

5). That I was searching my daughter and came to know through daily Kawish dated

11th June 2011 that my daughter is under the illegal detention of opponent No 1 to 3 and

from my personal sources I also came to know that my daughter also under illegal

detention of opponents No. 3 to 6.

6). That opponents No. 1 to 6 have illegally detained my daughter and are

pressurizing and threatening her and her life is at stake at the hands of opponents No. 1

to 6.

Therefore, I pray that rule Nisi may kindly be issued against the

opponents No. 1 to 6, directing the opponent No.7, SHO P.S Tharu Shah to recover my

daughter from the illegal detention of opponents No. 1 to 6 and may be produced before

the Honourable Court and beside the application aforesaid in accordance with law.

Photostat copy and News Paper are submitted herewith.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, NAUSHEHRO FEROZE.

Cr Misc: Appln: No. of 2011

Muhammad Ismail, Mari

----------------------------------- Applicant.

Versus

Aijaz & Others

----------------------------- Opponents.

AFFIDAVIT

I, Muhammad Ismail son of Khuda Bux, Mari adult, muslim, r/o: Taj
Colony, Nawabshah, do here by state on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my daughter Mst. Sajida is in illegal detention of opponents No 1 to 6 and

they are not ready to allow her to come to me.

3. That I apprehend that opponents No. 1 to 6 may give loss to my daughter to her
life.

4. That justice requires that opponent No.7 may be directed to recover the custody
of my daughter Mst. Sajida and produce her before the Honourable court so that she
may be allowed to go with me.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE, NAUSHEHRO FEROZE..

Cr Misc: Appln: No. of 2011

Muhammad Ismail son of Khuda Bux, Mari, adult, muslim,

r/o: Taj Colony Nawabshah.

----------------------------------- Applicant.
Versus

SHO P.S Naushehro Feroze.

----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That on 05.10.2009, at about 1:00 pm my son Muhammad Sarwar Bhatti

received a mobile call from one Muhammad Azim Mughal and told me that said

Muhammad Azim Mughal had called him at his Ghulam Jillani Estate Agency, near

Sakoon Hotel, at Court Road Nawabshah.

2). That my son went along with his servant to the Estate Agency aforesaid where

said Muhammad Azim Mughal called the opponent, who came along with his sub-

ordinate staff and took my son at P.S B-Section Nawabshah.

3). That the servant of my son came to me and informed me that opponent has

taken away to my son and has illegally detained with him on the instance of Muhammad

Azim Mughal.

4). That I then rushed to Police Station B-Section Nawabshah and met my son, ,

where the opponent met and I asked him that why my son has been apprehended , on

which he replied that settle the matter with Muhammad Azim Mughal, otherwise he

would not release my son on any costs.

P/2…
 P/2…

5). That I visited my son and the opponent at P.S B-Section Nawabshah, till

yesterday and my son was disclosing that the opponent was removing him from the P.S

in day time and detaining him in Police lockup in the night time, as routin for 05 days.

6). That I requested the opponent to release my son but of no avail, hence this

application.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the opponent

and any Magistrate may kindly be appointed as Commissioner to conduct raid at P.S B-

Section Nawabshah so that the detune may be recovered and may be produced before

the Honourable court to get his statement recorded and he may be set at liberty and

opponent may also be called for producing the custody before the Honourable Court as

he has been using technical methods for screening my son in day time and action in

accordance with law may be taken against the opponent.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIR ABAD.
Jan Muhammad
----------------------------------- Applicant.

Versus

SHO P.S B-Section Nawabshah

----------------------------- Opponent.

AFFIDAVIT

I, Jan Muhammad son of Noor Muhammad Bhatti, adult, muslim, r/o:

Ashraf Colony, Line Par, Nawabshah, do here by state on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That detunes are in illegal detention of opponent and the opponent is not ready
to release them.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.

IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

 Cr Misc: Appln: No. of 2009

Jan Muhammad son of Noor Muhammad Bhatti, adult,

muslim, r/o: Ashraf Colony, Line Par, Nawabshah.

----------------------------------- Applicant.
Versus

SHO P.S B-Section Nawabshah.

----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That on 05.10.2009, at about 1:00 pm my son Muhammad Sarwar Bhatti

received a mobile call from one Muhammad Azim Mughal and told me that said

Muhammad Azim Mughal had called him at his Ghulam Jillani Estate Agency, near

Sakoon Hotel, at Court Road Nawabshah.

2). That my son went along with his servant to the Estate Agency aforesaid where

said Muhammad Azim Mughal called the opponent, who came along with his sub-

ordinate staff and took my son at P.S B-Section Nawabshah.

3). That the servant of my son came to me and informed me that opponent has

taken away to my son and has illegally detained with him on the instance of Muhammad

Azim Mughal.

4). That I then rushed to Police Station B-Section Nawabshah and met my son, ,

where the opponent met and I asked him that why my son has been apprehended , on

which he replied that settle the matter with Muhammad Azim Mughal, otherwise he

would not release my son on any costs.

P/2…

P/2…
5). That I visited my son and the opponent at P.S B-Section Nawabshah, till

yesterday and my son was disclosing that the opponent was removing him from the P.S

in day time and detaining him in Police lockup in the night time, as routin for 05 days.

6). That I requested the opponent to release my son but of no avail, hence this

application.

-: P R A Y E R :-

Therefore, I pray that rule Nisi may kindly be issued against the opponent

and any Magistrate may kindly be appointed as Commissioner to conduct raid at P.S B-

Section Nawabshah so that the detune may be recovered and may be produced before

the Honourable court to get his statement recorded and he may be set at liberty and

opponent may also be called for producing the custody before the Honourable Court as

he has been using technical methods for screening my son in day time and action in

accordance with law may be taken against the opponent.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED
BENAZIR ABAD.
Jan Muhammad
----------------------------------- Applicant.

Versus

SHO P.S B-Section Nawabshah

----------------------------- Opponent.

AFFIDAVIT

I, Jan Muhammad son of Noor Muhammad Bhatti, adult, muslim, r/o:

Ashraf Colony, Line Par, Nawabshah, do here by state on oath as under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That detunes are in illegal detention of opponent and the opponent is not ready
to release them.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

Cr Misc: Appln: No. of 2009

Gul Dahri son of Allah Bachayo Dahri, adult, mulsim, r/o:

Doctor Colony, Nawabshah
----------------------------------- Applicant.

Versus

SHO P.S A-Section Nawabshah.

----------------------------- Opponent.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That on 30.9.2009 at about 0030 hours I was available in the PMC, Hospital

alongwith Kehar Ansari, Imdad leghari and Khadim Leghari ,meanwhile the heard

commotion infront of the canteen of Suhail Lakho S/o Moula Bux Lakho, we rushed

thereto and saw that Suhail Lakho was threatening to Sajid Dahri to take away the Car

parked infront of the canteen, on which Sajid was replying that he came in the hospital

to see his friend/patient and after few mintutes he would take his car away .

2). That there was taken altercation in between them, meanwhile Hussain Bux

Lakho, Abbass Lakho, Sajid Lakho, Hakim Lakho and Ashique Brohi duly armed with

lathies and bottles of glasses, on their arrival Suhail Lakho inflicted Bottle on the head of

Sajid Dahri and other inflicted Sonti blows on his face, head and other parts of the

body, meanwhile we interfered with and other people were gathered, then the accused

aforesaid ,left said Sajid Dahri while issuing threats of dire consequences.

P/2…
 P/3…

3). That we then were taking Sajid Dahri injured to police station A-Section

Nawabshah for registration of case and taking letter for medical treatment and

certificate and when we reached at the outer gate of police station A-Section

Nawabshah, accused aforesaid alongwith 15/20 other persons duly armed with lathies

and Pistols attacked upon us and inflicted lathies as well as butt blows to Imdad

Leghari, Kehar Ansari and Khadim Leghari and issued threats that they did not care

about the registration of case against them.

4). That we approached the opponent to register our case against the accused

persons but due to high handedness of accused, opponent neither registered our case

nor issued letter for medical treatment and certificate, on the contrary he got sit the

injured namely Khadim Leghari, Kehar Ansari, Imdad Leghari and Sajid Dahri at the

police station by illegally detaining them.

5). That I approached repeatedly to the opponent , on which he was not ready to

register the case but later on he referred injured Sajid Dahri and Imdad Leghari to

Hospital and they are getting their treatment in the illegal detention of the police and the

opponent is not ready to show any thing that whether any letter for Medical Treatment

and Certificate has been issued or not.

Therefore, I pray that rule Nisi may kindly be issued against the opponent

and any Magistrate may kindly be appointed as Commissioner to conduct raid at P.S A-

Section Nawabshah as well as in PMCH, Nawabshah, so that the detunes may be

recovered and may be produced before the Honourable court to get their statement

recorded and they may be set at liberty and action in accordance with law may be taken

against the accused persons.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

CR. MISC. APPL: NO. OF 2009

Muhammad
----------------------- Applicant.
….. versus ……

Izzat Khan Lashari

& others
---------------------Opponents.

OBJECTION TO APPLICATION U/S 491-A CR.P.C,

IN SHAPE OF COUNTER AFFIDAVIT

I, Asif son of Izzat Khan Lashari, muslim, adult, r/o: own houses, near
Village Rais Ghulam Hussain Mari, Deh 18 Nuarat, Taluka Daur, District Shaheed
Benazir Abad, do hereby state on oath as under:-

1). That I am opponent No.2 in the application , hence fully conversant with the
facts of the same.

2). That the application U/S 491-A Cr.P.C is not maintainable as such section has
been repealed.

3). That Opponent NO.3, Ghulam Lashari is my brother who has been residing
separately from me and at the moment I do not know about his residence.
4). That the police has unnecessarily been harassing me and my father and is raiding
our houses , whereby our reputation in the locality is being injured.

5). That applicant has unnecessarily implicated me and my son Asif in the
application .

6). That application against us is false , frivolous and the same is liable to be
dismissed with special costs.

Whatever stated above is true and correct to the best of my knowledge

and belief.

Deponent.
I know the Deponent.

Advocate.
 IN THE COURT OF SESSIONS JUDGE, SHAHEED BENAZIR ABAD.

CR. MISC. APPL: NO. OF 2009

Muhammad
----------------------- Applicant.
….. versus ……

Izzat Khan Lashari

& others
---------------------Opponents.

OBJECTION TO APPLICATION U/S 491-A CR.P.C,

IN SHAPE OF COUNTER AFFIDAVIT

I, Izzat Khan son of Ali Nawaz Lashari, muslim, adult, r/o: own houses,
near Village Rais Ghulam Hussain Mari, Deh 18 Nuarat, Taluka Daur, District Shaheed
Benazir Abad, do hereby state on oath as under:-

1). That I am opponent No.1 in the application , hence fully conversant with the
facts of the same.

2). That the application U/S 491-A Cr.P.C is not maintainable as such section has
been repealed.

3). That Opponent NO.3, Ghulam Lashari is my son who has been residing
separately from me and at the moment I do not know about his residence.

4). That the police has unnecessarily been harassing me and my son and is raiding
our houses , whereby our reputation in the locality is being injured.

5). That applicant has unnecessarily implicated me and my son Asif in the
application .

6). That application against us is false , frivolous and the same is liable to be
dismissed with special costs.

Whatever stated above is true and correct to the best of my knowledge

and belief.

Deponent.
I know the Deponent.

Advocate.
 IN THE COURT OF SESSIONS JUDGE, SANGHAR
Cr Misc: Appln: No. of 2009

Shuja Muhammad son of Muhamamd Uris Chandio, adult,

mulsim, r/o: A-20, Mohalla Chandio Colony, Nawabshah
----------------------------------- Applicant.

Versus

19. Waheed son of Kouro Khan Chandio.

20. Kouro Khan son of Peeral Khan Chandio
21. Rato Khan son of Peeral Khan Chandio.
22. Iqbal son of Kouro Khan Chandio.
23. Ibrahim son of Kouro Khan Chandio
24. Mazhar son of Kouro Khan Chandio.

All r/o: Chandia Mohalla, near Bhit Shah Phatak,

Edhi Center Chowk, Tando Adam town, Taluka
Tando Adam, District Sanghar.

25. SHO P.S Taluka Tando Adam.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C.

It is humbly submitted as under:-

1). That my daughter namely Mst. Saira was married with opponent No.1 about one

and half year ago.

2). That the marriage aforesaid was exchanged one as Mst. Sardran was married

with my brother Raja Sakhi Muhammad Chandio.

P/2…
 P/3…

3). That both the girls were allowed to visit their respective relatives for time and

again at the time of need.

4). That for about 6/7 months opponent No.1 restrained my daughter to visit me,

my wife and our children.

5). That about 20 days ago, I again went to visit my daughter at the house of

opponents Nos. 1 to 6 but they neither allowed me to take my daughter with me at

Nawabshah for the purpose of meeting nor allowed me to meet her on the pretext that

Mst. Sardaran might be brought to them then they would allow me to take my daughter

with me for the purpose of meeting with my family members.

6). That resultantly about 15 days ago I took my sister in law namely Mst. Sardaran,

who is the sister of opponent No.1, 4 to 6, daughter of opponent No.2 and niece of

opponent No.3, but even then they did not allow my daughter for the purpose of

meeting with me and since then my sister in law is also restrained by them.

7). That I approached nekmards of the locality so that matter may be settled and my

daughter may be allowed to visit my family members, but of no avail.

8). That opponents No. 1 to 6 have illegally detained my daughter and are

pressurizing and threatening her and her life is at stake at the hands of opponents No. 1

to 6.

Therefore, I pray that rule Nisi may kindly be issued against the

opponents No. 1 to 6, directing the opponent No.7, SHO P.S Taluka Tando Adam to

recover my daughter from the illegal detention of opponents No. 1 to 6 and may be

produced before the Honourable Court so that her statement may be recorded and she

may be allowed to go with me.

Applicant.
 IN THE COURT OF SESSIONS JUDGE, SANGHAR

Cr Misc: Appln: No of 2009

Shuja Muhammad Chandio

----------------------------------- Applicant.

Versus

Waheed Chandio & Others

----------------------------- Opponents.

AFFIDAVIT

I, Shuja Muhammad son of Muhammad Uris Chandio, adult, muslim,

r/o: House A-20, Mohalla Chandia Colony, Nawabshah, do here by state on oath as
under:-

1. That I am applicant in accompanying application U/S 491 Cr. P.C and same has
been drafted under my instruction, the contents of same are true and correct.

2. That my daughter Mst. Saira is in illegal detention of opponents No 1 to 6 and

they are not ready to allow her to come to me.

3. That I apprehend that opponents No. 1 to 6 may give loss to my daughter to her
life.

4. That justice requires that opponent No.7 may be directed to recover the custody
of my daughter Mst. Saira and produce her before the Honourable court so that she
may be allowed to go with me.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF SESSIONS JUDGE,
SHAHEED BENAZIR ABAD.
Cr Misc: Appln: No of 2009

Rashid Ali son of Rab Nawaz Khaskehli,

adult, muslim, r/o: Fouji Colony ,
near Allah Wali mosque, Sanghar Road,
Nawabshah.
----------------------------------- Applicant.

Versus

26. Ghulam Rasool Gori son of not known

27. Shahzad Ali.

28. Abid Ali.
29. Azhar Ali
30. Javed Ali

Nos. 2 to 5 sons of Nazar Muhammad Qureshi,

All R/O : Fouji Colony, behind Nasir Petrol Pump,
Sanghar Road, Line Par, Nawabshah.

31. SHO P.S B-Section Nawabshah.

----------------------------- Opponents.

APPLICATION U/S 49I Cr.P.C

It is humbly submitted as under:-

1. That I entered into marriage with Mst. Uzma d/o Ghulam Rasool Gori, opponent

No 1 on 27.05.2009, after swearing free will affidavit by her on 27-05-2009. Photostat

copies of Nikhanama and free will affidavit are submitted herewith as annexure “A” &

“B”.

2. That after the marriage was taken place, my wife was living with me in my

house situated on the address aforementioned happily.

 P/2…

P/2…

3. That on 01-06-2009, opponent No. 1 came to me and requested for allowing Mst.

Uzma to visit their relatives including mother, brothers and sisters etc.

4. That on 03.06.2009, I went to opponent No.1 to take my wife back to my house,

where opponent No. 1 met me, to whom I requested to allow my wife to go with me but

firstly he avoided to do so and after keeping me on hopes for about 2/3 hours he got

my wife disappeared from his house and took the same to the house of opponents No.

2 to 5.

5. That on my repeated request opponent No.1, became ready to fight with me and

refused at all to leave my wife and detained my wife in collusion with opponents No.2

to 5.

6. That my wife is in illegal detention of opponents No. 1 to 5 in the limits of P.S B-

Section Nawabshah, within the jurisdiction of this Honourable Court.

Therefore, I pray that rule Nisi may kindly be issued against the

opponents No. 1 to 5, directing the opponent No.6, SHO P.S B-Section Nawabshah to

recover my wife from the illegal detention of the opponents No. 1 to 5 and may be

produced before the Honourable Court so that her custody may be handed over to me.

Applicant.
 IN THE COURT OF SESSIONS JUDGE,
SHAHEED BENAZIR ABAD.

Cr Misc: Appln: No of 2009

Rashid Ali
----------------------------------- Applicant.

Versus

Ghulam Rasool Gori & Others

----------------------------- Opponents.

AFFIDAVIT

I, Rashid Ali son of Rab Nawaz Khaskehli, adult, muslim, r/o: Fouji
Colony, near Allah Wali mosque, Sanghar Road, Nawabshah, o here by state on oath as
under:-

1. That I am applicant in application U/S 491 Cr. P.C and same has been drafted
under my instruction, the contents of same are true and correct.

2. That my wife Mst Uzma is in illegal detention of opponents No 1 to 5 and they

are not ready to allow her to come to me.

3. That I apprehend that opponents No. 1 to 5 may give loss to my wife to her life.

4. That justice requires that opponent No.6 may be directed to recover the custody
of my wife Mst. Uzma and produce her before the Honourable court so that she may be
handed over to me.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.
 IN THE COURT OF 1st ADDTIINAL SESSIONS JUDGE,
SHAHEED MOHTARMA BENAZIR BHUTTO.

Cr Misc: Appl: No of 2008

Abdul Jabbar
--------------------------------------------- Applicant.
Versus

Abdul Ghaffar and an other.

-------------------------------------------Opponent

OBJECITONS TO APPLICATION U/S 49I Cr. P. C.

Opponents submit their objections as under:-

1. That the application u/s 491 Cr.PC filed by applicant against his father and uncle
for the recovery of alleged detainees is not maintainable.

2. That Mst. Khan Zadi, Mst. Imam Zadi and Mst. Jam Zadi are real daughters of
opponent No.1, therefore, they are not under his wrongful confinement.

3. That the alleged detainees namely Mst. Khan Zadi, Mst. Imam Zadi are both
majors/ adults while Mst Jam Zadi is aged about 12/13 years.

4. That brother/ applicant has no right to take the custody of his sisters by obtaining
the same from father, and the applicant is neither de-jure nor de-facto guardian.

5. That the applicant has evil eyes on his sisters to get them marry for monetary
consideration and this application is continuation of his intention.

6. That Mst. Imam Zadi, daughter of opponent No. 1 and younger sister Mst. Khan
Zadi has even sworn affidavit of free will and married with Pervez Ali Gorchani.

7. That application is not maintainable and liable to dismiss.

ADVOCATE FOR OPPONENTS.

NAWABSHAH.
DATED: 04.12.2008
 IN THE COURT OF SESSIONS JUDGE, NAWABSHAH.

Cr Misc: Appl: No of 2008

Mst. Malka Bibi W/O Fida Muhammad, adult,

muslim, Awan by caste, r/o: House No. 4177-
94, MOhalla Camp No.2, Kazi Ahmed Road,
Nawabshah.
--------------------------------------------- Applicant.

Versus

SHO P.S A-Section, Nawabshah.

-------------------------------------------Opponent

APPLICATION U/S 49I Cr. P. C

It is humbly prayed that this Honourable Court may be pleased to issue

Writ Rule Nisi against the opponent and to depute a learned Magistrate to conduct raid

at P.S A-Section, Nawabshah to recover detenues Junaid Fida son of Fida

Muhammad Awan (2) Awais Fida son of Fida Muhammad Awan and

Muhammad Arif son of Taj Muhammad Awan all r/o: House No.4177-94, Camp

No.2, Kazi Ahmed road, Nawabshah and to produce them before this Honourable Court

, so that they may be set at liberty after recording their statements, on the consideration

of the following facts and grounds:-

1). That on 15.09.2008, at 8:30 pm the opponent called the detenues at Police
Station A-Section, Nawabshah, in regard to a dispute confirming with a plot and
detained them there at without any case / FIR against them .

2). That I approached the opponent and requested him to release the opponent as
there was no any case/ FIR against them but the opponent bluntly refused to set the
detenues at liberty, therefore, they are under the illegal detention of the opponent.

3). That detenues Nos. 1 and 2 are my sons while detenue No.3, is my true
brother , who have been illegally detained at P.S A-Section, Nawabshah, but seldom
the opponent to avoid from any legal consequences take the detenues with him to keep
them at different police posts under the jurisdiction of his P.S, therefore, Rule Nisi may
kindly be issued as prayed and my sons and brother may be produced before the
Honourable court and they may be set at liberty after getting their statement recorded
by the Honourable Court.

APPLICANT.
NAWABSHAH.
DATED: 26.09.2008
 IN THE COURT OF SESSIONS JUDGE, NAWABSHAH.

Cr Misc: Appl: No of 2008

Mst. Malka Bibi W/O Fida Muhammad,

--------------------------------------------- Applicant.
Versus

SHO P.S A-Section, Nawabshah.

-------------------------------------------Opponent

AFFIDAVIT

I, Malka Bibi W/O Fida Muhammad, adult, muslim, Awan by caste, r/o:
House No.4177-94, Mohalla Camp No.2, Kazi Ahmed Road, Nawabshah, do hereby on
oath as under:-

1). That I am applicant in accompanying application filed under section 491 Cr.P.C
for the recovery of detenues Junaid Fida son of Fida Muhammad Awan (2) Awais Fida
son of Fida Muhammad Awan and Muhammad Arif son of Taj Muhammad Awan , who
are my sons and true brother.

2). That the opponent has illegally detained them at P.S A-Section, Nawabshah,
without registration of any case / FIR.

3). That accompanying application has been drafted as per my instruction and the
contents whereof may be read and treated as party and parcel of this affidavit.
Whatever stated above is true and correct to the best of my knowledge
and belief.

Deponent.

I know the Deponent

Advocate.

Nawabshah.
Dated: 26.09.2008
IN THE COURT OF SESSIONS JUDGE, NAWABSHAH.
Cr Misc: Appln: No of 2008

Mst. Lateefan wd/o Nazeer Ahmed, Muslim,

Adult, inhabitant of village Ghulam Muhammad
Post office, kunri, Taluka Kunri, District
Mirpurkhas Applicant.

Versus

1. Mst. Razia alias Aashi D/o Muhammad Sharif Mughal,

2. Mehboob Ahmed S/o Muhammad Sharif,
3. Naveed Ahmed S/o Mehboob Ahmed,
4. Muhammad Zamran S/o Muhammad Zahid,
All r/o House No. IInd B, 651,
near Wapda House, Manuababd, Nawabshah. Opponent

APPLICATION U/S 49I Cr.PC

It is humbly submitted as under:-

1. That my son namely Ashfaque Ahmed S/o Late Nazeer Ahmed aged about 20
years, inhabitant of village Ghulam Muhammad, Post Office Kunri, Taluka Kunri District
Mirpurkhas was getting education at Agricultural University TandoJam.

2. That about a month ago my son contacted me on mobile phone and apprised
about the facts that opponents were blackmailing him.

3. That my son further told that the opponents came at TandoJam and issued threat
for kidnapping him.

4. That my son was not contacted till yesterday and yesterday, as his mobile phone
remained turn off frequently.
 Page 2

5. That yesterday viz 02-09-2008, my son contacted me and apprised about the
facts that he is under the wrongful confinement of the opponents and the opponents
were not allowing him to go out from their house, therefore, he was not able to take an
opportunity to go out from the house of the opponents viz house No. IInd B-651 near
Wapda House, Manuabad, Nawabshah.

6. That my son is in illegal detention of opponents in the limits of P.S "A" Section
Nawabshah, within the jurisdiction of this honourable court.

Therefore, I pray that rule Nisi may kindly be issued against the opponents so
that my son may be recovered from the illegal detention of the opponents and may be
produced before the honourable so that he is set at liberty.

Advocate for Applicant

IN THE COURT OF SESSIONS JUDGE, NAWABSHAH.
Cr Misc: Appln: No of 2008

Mst. Lateefan Applicant.

Versus

Mst. Razia alias Aashi & others Opponents

AFFIDAVIT

I, Lateefan wd/o Nazeer Ahmed, Muslim, adult inhabitant of village Ghulam

Muhammad Post office, kunri, Taluka Kunri, District Mirpurkhas, at present at
Nawabshah, do here by state on oath as under:-

1. That I am applicant in application u/s 491 Cr.PC and same has been drafted
under my instruction, the contents of same are true and correct.

2. That my son Ashfaque Ahmed is in illegal detention of opponents and they are
not ready to allow him to visit me.

3. That I apprehend that opponents may give loss to the life of my son.

4. That justice requires that opponents may be directed to produce my son before
the honourable court so that he may be set at liberty.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent
Advocate.
IN THE COURT OF SESSIONS JUDGE, SANGHAR
Cr Misc: Appln: No of 2007
Gul Khan S/o Azad Khan Mari,
Muslim, Adult, R/o Chak No 7,
Suhelo, P.O Chak No 7, Taluka Daur,
District Nawabshah. Applicant.
Versus
1. Ashraf Ali S/o Muhammad Rafique Jat by caste
2. Ali Akbar S/o Muhammad Siddique Jat by caste
3. Fazal Hussain S/o not known, Jatt by caste
4. Abid S/o Sadiq Jatt by caste
5. Sajid S/o Sharafat Jatt by caste
All r/o Village Jameel Jat, 22 Chak
P.S Khadhar, Taluka Shahdadpur,
District Sanghar. Opponents….

APPLICATION U/S 49I CrPc

The applicant named above humbly submitted as under:-

1. That the applicant entered into marriage with Mst Rukhsana D/o opponent No 1
on 20-09-2007 after swearing free will affidavit by her on 18-09-2007. Copy of
Nikhanama and free will affidavit are produced herewith.

2. That after the marriage was taken place, the wife of the applicant was living with
the applicant in his house situated on the address aforementioned happily.

3. That on 21-10-2007 opponent No 1 to 5 came to the applicant and requested for

allowing Mst Rukhsana to visit their relatives including brothers and sisters etc.

4. That on consistent requests to the applicant and the elders of the applicant, the
applicant allowed them to take Mst Rukhsana his wife with them for meeting purpose
and they undertook to bring back her within a week.

5. That after the passage of the aforesaid time the applicant came into contact for
taking back his wife but firstly they kept the applicant on false hopes on one or other
pretext and finally refused to do so.
6. That the applicant approached the gentlemen of the opponents but of no avail.
7. That the wife of the applicant is in illegal detention of opponents No 1 to 5 in the
limits of P.S Khadhar Taluka, Shahdadpur, District Sanghar, within the jurisdiction of
this honourable court.
Therefore, the applicant prays that rule Nisi may kindly be issued against the
opponents so that his wife may be recovered from the illegal detention of the opponents
and be produced before the honourable so that her custody may be handed over to the
applicant.

Ali Gul Lund Baloch

Advocate for Applicant
IN THE COURT OF SESSIONS JUDGE, SANGHAR
Cr Misc: Appln: No of 2007

Gul Khan Applicant…

Versus

Ashraf Ali and an Other Opponents…..

AFFIDAVIT

I, Gul Khan S/o Azad Khan Mari Muslim, Adult, R/o Chak No 7,Suhelo, P.O
Chak No 7, Taluka Daur, District Nawabshah, do here by state on oath as under:-

1. That I am applicant in application u/s 491 Cr Pc and same has been drafted
under my instruction, the contents of same are true and correct.

2. That my wife Mst Rukhsana is in illegal detention of opponents No 1 to 5 and a

not ready to allow her to come to me.

3. That I apprehend that opponents may give loss to my wife to her life.

4. That justice requires that opponents may be directed to produce my wife before
the honourable court so that she may be handed over to me.

Whatever stated above is true and correct to the best of my knowledge.

Deponent
I know the deponent

Advocate.