Ikram Ullah

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

W.P. No._____________/2000 Muhammad Ikram Ullah S/o Mushtaq Ahmad, caste Arain, R/o Chak No. 557/EB, Tehsil & District Vehari. Petitioner VERSUS 1. Assistant Commissioner, Vehari. 2. Deputy Superintendent of Police/S.D.P.O. Saddar Circle, Vehari. 3. S.H.O. Machi Wal (Vehari). 4. Abdul Hameed S/o Haji Yousuf Ali, caste Arain, R/o Chak No. 409, Tehsil Burewala, District Vehari. 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 the daughter of respondent No. 4 submitted an application on 6.7.2000 to the District Monitoring Cell, Vehari. She stated that petitioner and his brother namely Muhammad Inam Ullah have obtained a loan of Rs. 43,000/from her, out of which once Rs. 8,000/- and again Rs. 10,000/- have been returned. The remaining amount is not returned so far. She requested for the return of amount. This application is now pending with the respondent No. 1, who

issued Notice to the petitioner and his brother Muhammad Inam Ullah through respondents No. 2 & 3. 3.

That it is pertinent to point out that the petitioner’s brother namely Muhammad Inam Ullah had some business relations with the respondent No. 4 who is missing since last four months from the home as well as from the business. The petitioner and the respectables of the family and area inquired form respondent No. 4 about the said Inam Ullah, but respondent No. 4 could not satisfy all of them. The petitioner tried to take help of police in this regard, but due to political and social relations, petitioner could not succeed.

4.

That the respondent No. 4, getting avoid from the inquiry about the missing of Muhammad Inam Ullah has submitted the application with malafide intention and ulterior motive. The copy of application and notice from respondent No. 2 are Annexes “A & B”.

5.

That if the contents of the application in hand be admitted as it is, then it will be a case of civil nature and respondents No. 1, 2 & 3 have no authority to interfere in this matter. However, the aggrieved person can avail the remedy for the recovery of loan under the law.

6.

That last time on 24.9.2000, the petitioner was picked up from his home by the respondent No. 3 in a very horrible manner. The family members were being harassed and petitioner was detained whole the night and next day was produced before the respondent No. 1. The respondent No. 1 obtained the thumb impressions and signatures of the petitioner on blank papers. Certainly this practice on the part of respondent No. 1 is not legal and also having no effect on the rights of the petitioner. Now the petitioner is called again by the respondent No. 1, on his behest the respondents No. 2 & 3 after the petitioner.

7.

That the petitioner submitted before the respondents that he has no concern whatsoever with the money matters between Muhammad Inam Ullah and the daughter of respondent No.

4. and even the said Muhammad Inam Ullah is missinig for which the petitioner and his family have serious doubt upon respondent No. 4, but they are not going to accede the submissions of the petitioner. 8.

That there is no other alternate, efficacious, adequate and speedy remedy available to the petitioner except to invoke the Constitutional jurisdiction of this Hon’ble Court. In view of the above submissions, it is respectfully prayed that the respondents No. 1 to 4 may please be restrained to cause illegal and unlawful harassment to the petitioner and his family members and being a matter of civil nature, shall not pressurize the petitioner and his family members to pay the alleged amount through these coercive measures. It is further prayed that any order, direction, writ or relief which this Hon’ble Court deems fit, may graciously be awarded to meet the ends of justice. Humble Petitioner,

Dated: ___________

(Muhammad Ikram Ullah)

Through: Sheikh Muhammad Faheem, Hamad Afzal Bajwa, Advocate High Court, Advocate High Court, C.C. No. 20176 C.C. No. 20959 28-District Courts, Multan. 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.

In re: C.M. No. _____________/2000 In W.P. No.____________/2000 Muhammad Ikram Ullah

Vs

A.C. Vehari, 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. Humble Applicant

Dated: __________ (Muhammad Ikram Ullah) Through: Sheikh Muhammad Faheem, Hamad Afzal Bajwa, Advocate High Court, Advocate High Court, C.C. No. 20176 C.C. No. 20959 28-District Courts, Multan.

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

In re: C.M. No. _____________/2000 In W.P. No.____________/2000 Muhammad Ikram Ullah

Vs

A.C. Vehari, etc.

DISPENSATION APPLICATION. AFFIDAVIT of: Muhammad Ikram Ullah S/o Mushtaq Ahmad, caste Arain, R/o Chak No. 557/EB, Tehsil & District Vehari.

I, the above named deponent do hereby solemnly affirm and declare that the contents of the above 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 October 2000 that the contents of this affidavit are true to the best of my knowledge and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

W.P. No.____________/2000 Muhammad Ikram Ullah

Vs

A.C. Vehari, 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 application.

A

6

Copy of Notice.

B

7

Dispensation Application.

8

Affidavit.

9

Vakalatnama PETITIONER Dated: ____________

Through: Sheikh Muhammad Faheem, Hamad Afzal Bajwa, Advocate High Court, Advocate High Court, C.C. No. 20176 C.C. No. 20959 28-District Courts, Multan.

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

W.P. No.____________/2000 Muhammad Ikram Ullah

Vs

A.C. Vehari, etc.

AFFIDAVIT of: Muhammad Ikram Ullah S/o Mushtaq Ahmad, caste Arain, R/o Chak No. 557/EB, Tehsil & District Vehari.

I, the above named deponent do hereby solemnly affirm and declare that the contents of the above 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 October 2000 that the contents of this affidavit are true to the best of my knowledge and belief.

DEPONENT