IN THE COURT OF MUHAMMAD SAEED, ADDL. DISTRICT & SESSIONS JUDGE, LAHORE.
Crl. Misc. No.________________________/2018 Muhammad Shahbaz S/O Muhammad Rafique R/O H # 48, Street No. 56, Toheed Abad Ravi Road, Lahore. PETITIONER VERSUS 1. THE STATE 2. Head Constable/Incharge Police Station Ravi Road, Lahore. RESPONDENTS FIR No. Offence U/S: Police Station:
320/14 302/320, 337/324 PPC Ravi Road, Lahore.
APPLICATION FOR ISSUANCE OF DIRECTION TO REMOVE THE ONE HAND SCUFF OF THE PETITIONER/ACCUSED. Respectfully Sheweth:1. That the petitioner was implicated in the above false criminal case and convicted by this Honorable courts. 2. That the petitioner has severe pain in his right hand wrist due to police torture in police lock-up. 3. That he could not bear the weight of handculf on the right hand wrist due to this reason, it is just and proper that the respondents be
directed to remove the handcuffs from right hand to left hand of the petitioner in the interest of justice, fair play and equity.
That it is within the jurisdiction of this honourbale court to issue direction as prayed for, if the application is not accepted, the petitioner shall bound to suffer with irreparable loss and substantial injury.
It is therefore, respectfully prayer that the respondent No.2 be directed to remove the hand scuffs from right hand to left hand of the petitioner in the light of above circumstances and it would be in the best interest of justice and fair play.
PETITIONER
In Person Muhammad Shahbaz S/O Muhammad Rafique