Bash Iran
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IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________Q/2002 Mst. Bashiran
VS
S.H.O. etc.
INDEX S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES 1
Urgent Form
2
Stamp Paper worth Rs. 500/-
3
Writ Petition.
4
Affidavit
5
Copy of Medico-legal certificate.
6
Copy of F.I.R. & better copy.
7
Power of attorney.
A B & B/1
PETITIONER Dated: __________ Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No._____________Q/2000
Mst. Bashiran W/o Muhammad Farooq (D/o Bahawal Sher), caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari. ……PETITIONER
VERSUS 1.
S.H.O. P.S. Sadar, Burewala.
2.
Muhammad Ashraf 110/S.I. P.S. Sadar, Burewala.
3.
Muhammad Farooq S/o Amir Ahmad, caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari. …RESPONDENTS
Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 read with Sec-561 Cr.P.C. for the quashment of F.I.R. No. 315 dated 27.11.02 registered at P.S. Sadar Burewala, U/s-16 of Zina (EOH) Ordinance, 1979.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was married to respondent No. 3 about 1½ years ago. After marriage, it was disclosed that the respondent
No. 3 had no source of income and always remained in the company of elegants of locality. Some times, respondent No. 3 invited his friends at home, the petitioner was forced to serve them and they always casted amorous glances upon the petitioner. 3. That the conduct and behaviour of respondent No. 3 created a constant fuss and unrest in the home. The petitioner was not ready to make herself a tool of earning for the respondent No. 3. In retaliation, the respondent No. 3 became usual violent towards the petitioner. On 16.11.02, there was exchange of hot words between the spouses and the respondent No. 3, being infuriated given a severe beating and caused injuries with a churri upon the person of the petitioner. The real married sister of the petitioner living two acres away, on information, reached with her husband and the petitioner was got released from the clutches of respondent No. 3. 4. That petitioner reported the matter to respondent No. 1, who recorded the statement of the petitioner and petitioner was sent for medical examination along-with a police official to the hospital. In the meantime, the respondent No. 3 prevailed upon the concerned quarters through his influenced friends, resultantly, neither the petitioner was properly examined nor any case was registered by the respondent No. 1. Copy of Medico-legal Certificate is Annex “A”. 5. That the petitioner was living with her sister; and, was not still recovered physically when respondent No. 2 started raids for the arrest of the husband of the petitioner’s sister. On query, it came to the knowledge of petitioner that respondent No. 3 got registered a case for abduction of the petitioner against the husband of petitioner’s sister namely Iqbal alias Bahawal
and
his brothers namely Abbas and Ashraf. Copy of F.I.R. with better copy are Annexes “B & B/1”. 6. That the F.I.R. is liable to be quashed inter-alia on the following: -
GROUNDS i)
That the said F.I.R. is lodged on the basis of concocted story, having no iota of truth.
ii)
That the F.I.R. is lodged with the malafide and ulterior motive, just to pressurise the petitioner and her wellwishers.
iii)
That the F.I.R. is lodged as a counter-blast against the efforts of petitioner for the registration of case against the respondent No. 3.
iv)
That the petitioner is living with her married sister two acres away from the residence of respondent No. 3 and this fact is in the knowledge of respondent No. 3.
v)
That the petitioner, many a time, visited the respondents No. 1 & 2 to join the investigation and for the recording of statement, but they remained reluctant to do so due to the influence of respondent No. 3 and his friends.
vi)
That the respondents No. 1 & 2, being the public functionaries, are duty-bound to investigate every case honestly and impartially, but in case of the petitioner, they miserably failed to perform their statutory obligations and are playing in the hands of respondent No. 3 & his influential friends.
vii)
That the petitioner is never abducted by anybody, instead, the petitioner has taken shelter in the house of her sister.
7. That the petitioner is left with no other alternate, adequate, efficacious or speedy remedy except to invoke the extraordinary constitutional jurisdiction of this Hon’ble court, for the redressal of her grievances.
In view of the above submissions, it is respectfully prayed that the F.I.R. No. 315/02, registered at P.S. Sadar Burewala, District Vehari, U/s 16-7/79 Islamic Law may please be ordered to be quashed. Any other writ, direction, order or relief, which this Hon’ble court deems fit may graciously be awarded in the interest of justice and equity. Humble petitioner, Dated: ________
Through: Hamad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
CERTIFICATE: Certified as per instructions of the client, this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________Q/2002 Mst. Bashiran
VS
S.H.O. etc.
AFFIDAVIT of: Mst. Bashiran W/o Muhammad Farooq (D/o Bahawal Sher), caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-titled petition are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT
Verification: Verified on oath at Multan, this _____ day of December 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief.
DEPONENT
W.P. No.____________Q/2002 Mst. Bashiran
VS
S.H.O. etc.
INDEX S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES 1
Urgent Form
2
Stamp Paper worth Rs. 500/-
3
Writ Petition.
4
Affidavit
5
Copy of Medico-legal certificate.
6
Copy of F.I.R. & better copy.
7
Power of attorney.
A B & B/1
PETITIONER Dated: __________ Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No._____________Q/2000
Mst. Bashiran W/o Muhammad Farooq (D/o Bahawal Sher), caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari. ……PETITIONER
VERSUS 1.
S.H.O. P.S. Sadar, Burewala.
2.
Muhammad Ashraf 110/S.I. P.S. Sadar, Burewala.
3.
Muhammad Farooq S/o Amir Ahmad, caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari. …RESPONDENTS
Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 read with Sec-561 Cr.P.C. for the quashment of F.I.R. No. 315 dated 27.11.02 registered at P.S. Sadar Burewala, U/s-16 of Zina (EOH) Ordinance, 1979.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was married to respondent No. 3 about 1½ years ago. After marriage, it was disclosed that the respondent
No. 3 had no source of income and always remained in the company of elegants of locality. Some times, respondent No. 3 invited his friends at home, the petitioner was forced to serve them and they always casted amorous glances upon the petitioner. 3. That the conduct and behaviour of respondent No. 3 created a constant fuss and unrest in the home. The petitioner was not ready to make herself a tool of earning for the respondent No. 3. In retaliation, the respondent No. 3 became usual violent towards the petitioner. On 16.11.02, there was exchange of hot words between the spouses and the respondent No. 3, being infuriated given a severe beating and caused injuries with a churri upon the person of the petitioner. The real married sister of the petitioner living two acres away, on information, reached with her husband and the petitioner was got released from the clutches of respondent No. 3. 4. That petitioner reported the matter to respondent No. 1, who recorded the statement of the petitioner and petitioner was sent for medical examination along-with a police official to the hospital. In the meantime, the respondent No. 3 prevailed upon the concerned quarters through his influenced friends, resultantly, neither the petitioner was properly examined nor any case was registered by the respondent No. 1. Copy of Medico-legal Certificate is Annex “A”. 5. That the petitioner was living with her sister; and, was not still recovered physically when respondent No. 2 started raids for the arrest of the husband of the petitioner’s sister. On query, it came to the knowledge of petitioner that respondent No. 3 got registered a case for abduction of the petitioner against the husband of petitioner’s sister namely Iqbal alias Bahawal
and
his brothers namely Abbas and Ashraf. Copy of F.I.R. with better copy are Annexes “B & B/1”. 6. That the F.I.R. is liable to be quashed inter-alia on the following: -
GROUNDS i)
That the said F.I.R. is lodged on the basis of concocted story, having no iota of truth.
ii)
That the F.I.R. is lodged with the malafide and ulterior motive, just to pressurise the petitioner and her wellwishers.
iii)
That the F.I.R. is lodged as a counter-blast against the efforts of petitioner for the registration of case against the respondent No. 3.
iv)
That the petitioner is living with her married sister two acres away from the residence of respondent No. 3 and this fact is in the knowledge of respondent No. 3.
v)
That the petitioner, many a time, visited the respondents No. 1 & 2 to join the investigation and for the recording of statement, but they remained reluctant to do so due to the influence of respondent No. 3 and his friends.
vi)
That the respondents No. 1 & 2, being the public functionaries, are duty-bound to investigate every case honestly and impartially, but in case of the petitioner, they miserably failed to perform their statutory obligations and are playing in the hands of respondent No. 3 & his influential friends.
vii)
That the petitioner is never abducted by anybody, instead, the petitioner has taken shelter in the house of her sister.
7. That the petitioner is left with no other alternate, adequate, efficacious or speedy remedy except to invoke the extraordinary constitutional jurisdiction of this Hon’ble court, for the redressal of her grievances.
In view of the above submissions, it is respectfully prayed that the F.I.R. No. 315/02, registered at P.S. Sadar Burewala, District Vehari, U/s 16-7/79 Islamic Law may please be ordered to be quashed. Any other writ, direction, order or relief, which this Hon’ble court deems fit may graciously be awarded in the interest of justice and equity. Humble petitioner, Dated: ________
Through: Hamad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
CERTIFICATE: Certified as per instructions of the client, this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________Q/2002 Mst. Bashiran
VS
S.H.O. etc.
AFFIDAVIT of: Mst. Bashiran W/o Muhammad Farooq (D/o Bahawal Sher), caste Langrial, R/o Chak No. 148/EB, Tehsil Burewala, District Vehari.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-titled petition are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT
Verification: Verified on oath at Multan, this _____ day of December 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief.
DEPONENT
