Thursday, 23 October 2014

PETITION UNDER SECTION 22A& 22B CR.P.C FOR REGISTRATION OF A CRIMINAL CASE AS PER APPLICATION PETITIONER. DRAFTED BY HUMAN RIGHTS ACTIVIST MIAN ASHRAF ASMI ADVOCATE, CHAIRMAN HUMAN RIGHTS FRONT INTERNATIONAL




IN THE COURT OF DISTRICT & SESSION JUDGE WITH POWERS OF JUSTICE OF PEACE, LAHORE







Petition No………………………/2014





1)xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

                                                                                                Petitioner:


                                                     VERSUS


  1. Station House Officer, Police Station.
Respondents.



PETITION UNDER SECTION 22A& 22B CR.P.C FOR REGISTRATION OF A CRIMINAL CASE AS PER APPLICATION PETITIONER.



Respectfully Sheweth:

1.           That the addresses of the parties have correctly been given in the head note of this petition for effecting  service and notices upon the parties.
2.           That the petitioner is peace loving citizen of Pakistan and he is residing the above mentioned address with his family.
3.           That the petitioner made an application before respondent/SHO also made many visits for registration of hi case against  Respondent No.2. As per application made by the petitioner, the proposed accused person have committed a cognizable offence , but no action has been taken .Copy of application is attached as Annex”A”. However the MLR of  petitioner, hence copy whereof is not available, but public acknowledged the whole situation.
4.           That the provision of  Section 154 Cr.P.C. are mandatory in nature and are binding upon the police officer to lodge a criminal case when received an information about the commission of a cognizable offence and it is also settled law by the  Apex Court of the country that police should register a criminal case of an aggrieved person and to proceed in the matter strictly in accordance with law, but in this case the police will malafide intention has failed to discharge his duties. Reliance is place on   PLD 2007 SC 539.
5.           That if the case of petitioner is not ordered to be registered, as per his application, the petitioner shall suffer an irreparable loss and injury.

PRAYER:

          It is therefore most respectfully prayed that the respondent/SHO may kindly be directed to register a criminal case as per the application of petitioner and to act strictly in accordance with law, in the intrest of justice.

It is also prayed that the life , liberty, person and property of the petitioner may also be ordered to be protected, in the  interest of justice.


Any other relief which this Honourable Court deems fit and proper under the given circumstances of the case, may also be granted to the petitioner.



                                                                   Petitioner



                                      Through


                                                Mian Muhammad Ashraf Asmi
                                                     Advocate High Court
1-Shah Chiragh Chambers Lahore.





CERTIFICATE:

As per instructions of the client , this is first petition before this Honourable Court on subject matter.


                                                                   Advocate
















IN THE COURT OF HONOURABLE DISTRICT & SESSION JUDGE LAHORE.



      





Petition No._____________/2014


Muhammad Kashif Chand VS SHO.
                                               

AFFIDAVIT OF xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx, Tehsil Cantt, Distrtict Lahore.


 I,  the above named deponent do hereby affirm and declare as under.
                  
That the contents of the above titles petition is true to the best of my knowledge and belief and nothing has been concealed therein.                            

                                                                                                                                                                                                                                                          DEPONENT:

VERIFICATION:
Verified on oath at Lahore this 22  day Oct.14 that, contents of the above affidavit are true to the best of my knowledge.


         DEPONENT



No comments:

Post a Comment