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    22a 22b Against Asi

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    Petition 22a

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    22a 22b Against Asi

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    haiertvsetup
    4 views5 pages
    Petition 22a

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    22a 22b against asi

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    Petition 22a

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    © All Rights Reserved
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    Download as doc, pdf, or txt
    4 views5 pages

    22a 22b Against Asi

    Uploaded by

    haiertvsetup
    Petition 22a

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 5

    IN THE COURT OF SESSION JUDGE, LAHORE

    Petition No._______________/2011

    In re:

    FAISAL JAVAID …………. Vs ………. STATION HOUSE


    OFFICER

    INDEX

    S. No Documents Date Pages

    1. Petition 19.03.2013 1 to 3
    2. Affidavit to above 19.03.2013 4
    3. Annex.”A” Application 18.03.2013 5
    4 Power of Attorney 19.03.2013 6
    ______________________________________________________________

    PETITIONER

    Through

    MUHAMMAD MUDASSAR
    CH
    Advocate

    IMRAN JAVED MUHAMMAD HASEEB


    USAMA
    Advocate Advocate

    003Lawyers Chambers, District Courts, Lahore


    Dated: 13.05.2011
    IN THE COURT OF SESSION JUDGE, LAHORE

    Petition No._______________/2011

    FAISAL JAVAID son of Javaid Iqbal,


    Resident of House No.287/LDA, Street No.2,
    Mohallah Muslim Pura, Baghbanpura, Lahore.

    ……….PETITIONER
    VERSUS
    STATION HOUSE OFFICER,
    Police Station Lohari Gate, Lahore.
    ……….RESPONDENT
    ___________
    PETITION under section 22A and 22B of Cr.P.C.
    seeking a direction to the respondent for
    registration of criminal case against
    nominated accused Khadim Hussain (ASI),
    Presently posted at P.S Lohari Gate, Lahore
    and some unknown.
    ___________

    RESPECTFULLY SHEWETH:
    1. Briefly stated the facts giving rise to the instant
    petition before this Honourable Court are that the petitioner
    is peaceful and law abiding citizen of Pakistan and doing
    business of Medicine. That on 18.03.2013 the petitioner
    along with his servant namely Asad Raouf going to
    medicine market Lohari Gate to by medicine on motor bike
    No.LEP/4586.
    2. That when the petitioner reached at Shah Alam Chowk,
    the accused Khadim Hussain (ASI) along with 3 constables
    stop the petitioner for security check-up, while during the
    search accused Khadim Hussain (ASI) snatched Rs.20,000/-
    from the petitioner, when the petitioner demanded his
    money back the accused start abusing and threaten the
    petitioner, by saying to forget the money otherwise he will
    rope the petitioner in false cases and as resultant the
    accused Khadim Hussain (ASI) took the petitioner’s bike
    into his custody by misusing by transgressing his authority
    without any lawful reason and justification. A copy of the
    application dated 18-03-2013 is attached as Annexure A for
    kind perusal of this Honourable Court.
    3. That on unlawful conducts of the accused persons the
    petitioner moved a written complaint to the respondent for
    registration of criminal case against the aforementioned
    nominated accused but the respondent flatly refused to
    accept the lawful and genuine request of the petitioner. The
    respondent is duty bound under section 154 Cr.P.C. to
    register case on the complaint of the petitioner against the
    nominated accused because the perusal of the complaint
    reveals the commission of cognizable offences.
    4. That failure / refusal of the respondent is not warranted
    by law. The complained act of the respondent is clear
    violation of law and principles laid down by the August
    Supreme Court. The respondent has no lawful authority to
    investigate the matter prior to the registration of FIR.
    Reliance is placed on PLD 2007 SC 539.
    5. That it is quite in the interest of justice, equity and fair
    play that a direction be issued to the respondent for
    registration of criminal case against the culprits on the
    complaint of the petitioner as heinous cognizable offences
    are made out from the said complaint.
    PRAYER
    Under the circumstances, it is most humbly and
    respectfully prayed that by accepting this petition, this
    Honourable Court may be pleased to issue a direction to
    the respondent for registration of criminal case on the
    complaint of the petitioner under the relevant provisions of
    against the culprits, to meet the ends of justice.
    It is also prayed that any other relief found just
    and proper in the circumstances of the case may also be
    granted to the petitioner, in the larger interest of justice.
    PETITIONER
    Through
    MUHAMMAD MUDASSAR
    CH
    Advocate

    IMRAN JAVED MUHAMMAD HASEEB


    USAMA
    Advocate Advocate
    003Lawyers Chambers, District Courts, Lahore
    Dated: 19.03.2013
    CERTIFICATE
    Certified as per instructions, this is the first petition on the
    subject before this Honourable Court.

    COUNSEL

    IN THE COURT OF SESSION JUDGE, LAHORE

    Petition No._______________/2013

    In re:
    FAISAL JAVAID …………. Vs ………. STATION HOUSE
    OFFICER
    ( Petition Under Section 22A & 22B of Cr.P.C)
    __________
    AFFIDAVIT of Faisal Javaid son of Javaid Iqbal,
    resident of House No.287/LDA,
    Street No.2, Mohallah Muslim Pura,
    Baghbanpura, Lahore.
    ___________

    I, the above named petitioner do hereby solemnly

    affirm and declare as under:

    That contents of the accompany


    Petition are true and correct to the
    best of my knowledge and belief
    and nothing material has been
    suppressed from Honourable
    Court.
    DEPONENT
    VERIFICATION

    Verified on oath at Lahore, this the 19th day of March, 2013


    that the contents of above affidavit are true and correct to
    the best of my knowledge and belief.
    DEPONENT

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