Draft Of Application U/S 22-A Cr. P.C For Registration Of Criminal Case

Legal Discussions Legal Drafting and Templates
1

IN THE COURT OF SESSIONS JUDGE, ISLAMABAD (WEST)

_______ son of _______, resident of House No. _______, Street No. , Sector ­­­­­­­, [city].

…Applicant/Complainant

Vs

  • SSP, ICT Police, [city].
  • The SHO P.S. [city].

…Respondents

APPLICATION U/S 22-A Cr. P.C FOR REGISTRATION OF CRIMINAL CASE AGAINST THE ACCUSED (1) MUHAMMAD AKHTAR SON OF MUHAMMAD ANWAR, RESIDENT OF STREET NO.6, MOHALLAH FAQEER PURA, GUJRANWALA, AND (2) IMRAN SHAH

Respectfully Sheweth:-

  1. That the petitioner is a law-abiding citizen of Pakistan, and entitled to enjoy all the rights, privileges, easements and incidents in terms of the Constitution of Islamic Republic of Pakistan.

  2. That the brief facts of the case are that the petitioner moved an application before the respondents for registration of criminal case against the accused _______. Copies of applications are annexed as Annexure “A” & “B” respectively.

  3. That the accused persons are very influential, and due to the influence of the accused, the concerned respondent/police in league with the accused was reluctant to register a criminal case against them, hence this petition.

  4. That the above mentioned accused persons committed heinous offence, they kidnap the petitioner and also deprived the petitioner from his valuable items and cash, detail mentioned in the applications (annex-A&B) and also committed cognizable offence but the police in league and connivance with the accused did not register the criminal case against the accused.

  5. That the respondent/local police has badly failed to perform his duties according to law. The respondent was/is duty bound to register the case against the accused. That the petitioner has preferred several requests before the respondent/local police to register the case against the accused but they have turned a deaf ear, rather are silent spectators to the miseries being suffered by the petitioner at the hands of the accused.

  6. That the petitioner has great apprehension that the accused in league and connivance with the officials of respondent might go to any extent against the petitioner and the petitioner feels extreme danger to his life at the hands of the culprit.

  7. That the attitude of the police falls within the definition of police access and is amenable to the jurisdiction, vested to this Honourable Court U/S 22-A of Cr.P.C.

  8. That all the ingredients of Section 22-A Cr.P.C. are attracted in the petitioner’s case.

PRAYER :-

In the light of above mentioned circumstances, it is respectfully prayed that instant petition may kindly be allowed and respondent be directed to register a criminal case against said accused (1) Muhammad Akhtar and (2) Imran Shah under relevant Sections of PPC and to proceed further with the matter under the law in the best interest of justice.

Petitioner

Through

Advocate Supreme Court of Pakistan,

Islamabad

Advocate High Court,

Islamabad

CERTIFICATE

Certified as per instructions that this is the first petition

in this Honourable Court.

Counsel

IN THE COURT OF SESSIONS JUDGE, ISLAMABAD (WEST)

Muhammad Jabir

Vs

SSP, ICT Police, Islamabad and others

APPLICATION U/S 22-A Cr. P.C FOR REGISTRATION OF CRIMINAL CASE AGAINST THE ACCUSED (1) MUHAMMAD AKHTAR SON OF MUHAMMAD ANWAR, RESIDENT OF STREET NO.6, MOHALLAH FAQEER PURA, GUJRANWALA, AND (2) IMRAN SHAH

AFFIDAVIT

I, _______ son of _______, resident of House No. , Street No, Sector _______, Islamabad, do hereby solemnly affirm and declare on oath as under:

That the contents of the above captioned petition are true and correct to the best of my knowledge and belief and nothing has been concealed.

Deponent

Further affirmed that the contents of this affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.

Deponent