Ghulam Farid
This document was uploaded by user and they confirmed that they have the permission to share it. If you are author or own the copyright of this book, please report to us by using this DMCA report form. Report DMCA
Overview
Download & View Ghulam Farid as PDF for free.
More details
- Words: 1,343
- Pages: 8
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No._____________/2002 1.
Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan. Petitioner VERSUS
1. The S.S.P. Multan. 2. The D.S.P. Jlalapur Pirwala, District Multan. 3. The S.H.O. P.S. Saddar, Jalalpur Pirwala, District Multan. 4. Muhammad Nawaz S/o Allah Bakhsh, 5. Nazir Ahmad S/o Allah Bakhsh 6. Saif-ur- Rehman
Sons of
caste Bhatti
7. Zia-ur-Rehman Muhammad Nawaz,
R/o Chak No.
8. Ghulam Abbas S/o Nazir Ahmad
86-M Jalalpur,
9. Mst. Zubaida W/o Nazir Ahmad
Pirwala,
10.Mst. Saima Batool D/o Muhammad Nawaz
District Multan
11.Mst. Allah Wasai W/o Wahid Bakhsh …….Respondents
Writ Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973.
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 brief facts giving rise to the instant petition are that Mst. Humera Batool daughter of respondent No. 4 was married to Muhammad Ramzan son of petitioner and in lieu of that, Mst. Shazia, the daughter of the petitioner was married to one Saif-urRehman the son of the respondent No. 4 in May 2002. Due to some altercation, the petitioner’s daughter Mst. Shazia was expelled and she was also residing with the petitioner. In retaliation, the respondents No. 4 to 11 tried to take away Mst. Humera Batool, but she refused. The respondent No. 4 and his wife Mst. Safia filed to fictitious and frivolous habeas petitions before the Hon’ble High Court, Multan Bench. But both the applications were dismissed on the statement of Mst. Humera Batool. The respondents No. 4 to 11 were aggrieved and under the same motive, on 13.3.2002 at about Maghrib Wela, respondents No. 4 to 11 criminally trespassed into the house of the petitioner, when the petitioner and his sons were not present at home and were away in connection with Janaza prayer in the neighbourhood. The respondents No. 4 to 11 tried to abduct Mst. Humera Batool and on the resistance of Mst. Farhat Shamim and Mst. Rukhsana Parveen, the wife and daughter of the petitioner respectively, all the three ladies were given severe beating by the male accused persons with Sotis and the female accused with fist and kicks blows. On the hue and cry of the petitioner’s family members, the witnesses Haji Abdul Satta and his son Muhammad Siddiq the neighbourers attracted to the scene and save the wife and the daughter of the petitioner from the clutches of respondents No. 4 to 11. The respondents No. 4 to 11 also took away Mst. Humera Batool by force and against her will. The petitioner and his sons came back at Isha Wela and the matter came into their knowledge. 3. That the petitioner informed respondent No. 3 at night, but there was no response at all. On 14.3.2002, the petitioner submitted an application to the respondent No. 2, on which the police referred Mst. Farhat Shamim and Mst. Rukhsana Parveen for the examination, but the doctor present in the hospital refused to
examine both the ladies. The petitioner finding no other way, submitted another application to the respondent No. 1 on 19.3.2002. In response of that, the petitioner’s wife Mst. Farhat Shamim was examined only and Mst. Rukhsana Parveen was not examined. Copies are attached as Annexes “A, B, C & D”. 4. That in the mean time, the other party approached the respondent No. 3; and the respondent No. 3 in connivance with the other party in collusion with each other, concealing the real facts and instead of aggressive party, got registered a case F.I.R. No. 56 on 16.3.2002, under section 334/337Fi & 34 P.P.C. P.S. Saddar, Jalalpur Pirwala on the statement of Mst. Allah Wasai, the respondent No. 11. This respondent No. 11 is a midwife (Dai) working at Rural Health Centre, Jalalpur Pirwala and was a cause for non examination/late examination of the injured victims (wife and daughter of the petitioner). Copy of F.I.R. is Annex “E”. 5. That even the Medical examination of Mst. Farhat Shamim, the petitioner’s wife was conducted on the police request, but the police is not going to register the case against the respondents No. 4 to 11as per version of the petitioner mentioned. 6. That the respondents No. 1 to 3 are duty bound and under statutory obligation to register a case on the receiving of information of a cognizable offence as laid down in 154 Cr.P.C. and Rule 24.5 (c) of Police Rules 1934. 7. That the petitioner is left with no other adequate, efficacious, speedy and alternate remedy in these circumstances, except to invoke the extra ordinary constitutional jurisdiction of this Hon’ble Court.
Keeping in view the above-mentioned facts, it is respectfully prayed that the respondents No. 1 to 3 may please be directed to register a case record a cross version against the respondents No. 4 to 11 and
investigation may please be entrusted to some honest and gazetted officer of the rank of D.S.P. Any other writ, order, direction or relief which this Hon’ble court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. HUMBLE 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
CERTIFICATE: Certified as per instructions of the client, that 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. ______________/2002
Ghulam Fareed
Vs.
S.S.P. Multan, etc.
AFFIDAVIT of: Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned 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 April 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2002 In W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPIES OF ANNEXURES. =========================================
Respectfully Sheweth: That certified copies of Annexures “
” are
not available. However, uncertified/photo state copies of the same have been annexed with the petition, which are true copies of original documents. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copies of documents. 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.
In re: C.M. No. _____________/2002 In W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
DISPENSATION APPLICATION.
AFFIDAVIT of: Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned application 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 April 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
INDEX S. No. NAME OF DOCUMENTS
ANNEXES PAGES
1
Urgent Form.
2
Stamp Paper worth Rs. 500/-
3
Writ Petition.
4
Affidavit.
5
Copy of applications.
A& B
6
Copy of M.L.C.
C&D
7
Copy of F.I.R.
8
Dispensation Application.
9
Affidavit.
10
Vakalatnama
E
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
W.P. No._____________/2002 1.
Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan. Petitioner VERSUS
1. The S.S.P. Multan. 2. The D.S.P. Jlalapur Pirwala, District Multan. 3. The S.H.O. P.S. Saddar, Jalalpur Pirwala, District Multan. 4. Muhammad Nawaz S/o Allah Bakhsh, 5. Nazir Ahmad S/o Allah Bakhsh 6. Saif-ur- Rehman
Sons of
caste Bhatti
7. Zia-ur-Rehman Muhammad Nawaz,
R/o Chak No.
8. Ghulam Abbas S/o Nazir Ahmad
86-M Jalalpur,
9. Mst. Zubaida W/o Nazir Ahmad
Pirwala,
10.Mst. Saima Batool D/o Muhammad Nawaz
District Multan
11.Mst. Allah Wasai W/o Wahid Bakhsh …….Respondents
Writ Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973.
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 brief facts giving rise to the instant petition are that Mst. Humera Batool daughter of respondent No. 4 was married to Muhammad Ramzan son of petitioner and in lieu of that, Mst. Shazia, the daughter of the petitioner was married to one Saif-urRehman the son of the respondent No. 4 in May 2002. Due to some altercation, the petitioner’s daughter Mst. Shazia was expelled and she was also residing with the petitioner. In retaliation, the respondents No. 4 to 11 tried to take away Mst. Humera Batool, but she refused. The respondent No. 4 and his wife Mst. Safia filed to fictitious and frivolous habeas petitions before the Hon’ble High Court, Multan Bench. But both the applications were dismissed on the statement of Mst. Humera Batool. The respondents No. 4 to 11 were aggrieved and under the same motive, on 13.3.2002 at about Maghrib Wela, respondents No. 4 to 11 criminally trespassed into the house of the petitioner, when the petitioner and his sons were not present at home and were away in connection with Janaza prayer in the neighbourhood. The respondents No. 4 to 11 tried to abduct Mst. Humera Batool and on the resistance of Mst. Farhat Shamim and Mst. Rukhsana Parveen, the wife and daughter of the petitioner respectively, all the three ladies were given severe beating by the male accused persons with Sotis and the female accused with fist and kicks blows. On the hue and cry of the petitioner’s family members, the witnesses Haji Abdul Satta and his son Muhammad Siddiq the neighbourers attracted to the scene and save the wife and the daughter of the petitioner from the clutches of respondents No. 4 to 11. The respondents No. 4 to 11 also took away Mst. Humera Batool by force and against her will. The petitioner and his sons came back at Isha Wela and the matter came into their knowledge. 3. That the petitioner informed respondent No. 3 at night, but there was no response at all. On 14.3.2002, the petitioner submitted an application to the respondent No. 2, on which the police referred Mst. Farhat Shamim and Mst. Rukhsana Parveen for the examination, but the doctor present in the hospital refused to
examine both the ladies. The petitioner finding no other way, submitted another application to the respondent No. 1 on 19.3.2002. In response of that, the petitioner’s wife Mst. Farhat Shamim was examined only and Mst. Rukhsana Parveen was not examined. Copies are attached as Annexes “A, B, C & D”. 4. That in the mean time, the other party approached the respondent No. 3; and the respondent No. 3 in connivance with the other party in collusion with each other, concealing the real facts and instead of aggressive party, got registered a case F.I.R. No. 56 on 16.3.2002, under section 334/337Fi & 34 P.P.C. P.S. Saddar, Jalalpur Pirwala on the statement of Mst. Allah Wasai, the respondent No. 11. This respondent No. 11 is a midwife (Dai) working at Rural Health Centre, Jalalpur Pirwala and was a cause for non examination/late examination of the injured victims (wife and daughter of the petitioner). Copy of F.I.R. is Annex “E”. 5. That even the Medical examination of Mst. Farhat Shamim, the petitioner’s wife was conducted on the police request, but the police is not going to register the case against the respondents No. 4 to 11as per version of the petitioner mentioned. 6. That the respondents No. 1 to 3 are duty bound and under statutory obligation to register a case on the receiving of information of a cognizable offence as laid down in 154 Cr.P.C. and Rule 24.5 (c) of Police Rules 1934. 7. That the petitioner is left with no other adequate, efficacious, speedy and alternate remedy in these circumstances, except to invoke the extra ordinary constitutional jurisdiction of this Hon’ble Court.
Keeping in view the above-mentioned facts, it is respectfully prayed that the respondents No. 1 to 3 may please be directed to register a case record a cross version against the respondents No. 4 to 11 and
investigation may please be entrusted to some honest and gazetted officer of the rank of D.S.P. Any other writ, order, direction or relief which this Hon’ble court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. HUMBLE 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
CERTIFICATE: Certified as per instructions of the client, that 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. ______________/2002
Ghulam Fareed
Vs.
S.S.P. Multan, etc.
AFFIDAVIT of: Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned 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 April 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2002 In W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPIES OF ANNEXURES. =========================================
Respectfully Sheweth: That certified copies of Annexures “
” are
not available. However, uncertified/photo state copies of the same have been annexed with the petition, which are true copies of original documents. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copies of documents. 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.
In re: C.M. No. _____________/2002 In W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
DISPENSATION APPLICATION.
AFFIDAVIT of: Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned application 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 April 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________/2002 Ghulam Fareed
Vs.
S.S.P. Multan, etc.
INDEX S. No. NAME OF DOCUMENTS
ANNEXES PAGES
1
Urgent Form.
2
Stamp Paper worth Rs. 500/-
3
Writ Petition.
4
Affidavit.
5
Copy of applications.
A& B
6
Copy of M.L.C.
C&D
7
Copy of F.I.R.
8
Dispensation Application.
9
Affidavit.
10
Vakalatnama
E
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
Related Documents
Ghulam Farid
November 2019 21
Ghulam Dastgir
July 2020 6
Ghulam Shabbir
November 2019 17
Baba Farid
May 2020 23
Ghulam Muhammad
November 2019 17