Rahat Masood

IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rahat Masood Khan S/o Nasrullah Khan, caste Afghan Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan. ……Applicant VERSUS 1.

State.

2.

S.H.O. P.S. Pak Gate, Multan. ……Respondents Application U/s 22-A, 22-B Cr.P.C. restraining the respondent No. 2 from causing any illegal/unlawful harassment to the petitioner, his family members and relatives.

Respectfully Sheweth: 1.

That the applicant is an employee of Khan Bus Service serving his company from 8:00 A.M. till 10:00 P.M. There is only wife of the applicant to look after the children at the home of the applicant. The applicant has two daughters and one son and all are school going.

2.

That an unfortunate incident took place in the area of P.S. Pak Gate on the midnight of 11.6.03 and 12.6.03 in which a boy was murdered while a lady was injured as well. A case U/s 302/324/34 P.P.C. was registered in which one person Umar Ali was nominated who was seen by the witnesses standing in the street while the actual culprits fled away after the occurrence. This Umar Ali happened to be the nephew of the applicant’s wife. Copy of F.I.R. is Annex “A”.

3.

That the said Umar Ali is absconding from the date of occurrence and nobody including myself knows the whereabouts of that Umar Ali. The respondent No. 2 instead of searching the Umar Ali, is pressurising the applicant, other relatives and family members of the applicant for his production, while on the other side, nobody knows about the whereabouts of the said Umar Ali or having any information or connection at present with him.

4.

That the respondent No. 2 is raiding the house of the applicant and calling the applicant time to time at P.S., in lieu of the arrest of the said Umar Ali, which is permanent cause of harassment to the applicant and the act of the respondent No. 2 is unwarranted under the law.

5.

That the applicant, his family and relatives are fully protected under the constitution and the respondent No. 2 has no authority to transgress of his authority, as well as to harm the decency of family life of the applicant.

6.

That the petitioner is left with no other efficacious, speedy, adequate and proper remedy except to invoke the jurisdiction of this Hon’ble Court. Hence, this application. It is, therefore, respectfully prayed that the respondent No. 2 may please be restrained to cause any type of illegal and unlawful harassment to applicant, his family members and his relatives by any means. Any other relief, which this Hon’ble Court deems fit, may please be extended for the sake of justice. Humble Applicant,

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 COURT OF SESSIONS JUDGE, MULTAN.

Rahat Masood Khan

VS.

State etc.

Application U/s 22-A, 22-B Cr.P.C. AFFIDAVIT of: Rahat Masood Khan S/o Nasrullah Khan, caste Afghan Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan. I, the above-named deponent do hereby solemnly affirm and declare as under: 1.

That the applicant is an employee of Khan Bus Service serving his company from 8:00 A.M. till 10:00 P.M. There is only wife of the applicant to look after the children at the home of the applicant. The applicant has two daughters and one son and all are school going.

2.

That an unfortunate incident took place in the area of P.S. Pak Gate on the midnight of 11.6.03 and 12.6.03 in which a boy was murdered while a lady was injured as well. A case U/s 302/324/34 P.P.C. was registered in which one person Umar Ali was nominated who was seen by the witnesses standing in the street while the actual culprits fled away after the occurrence. This Umar Ali happened to be the nephew of the applicant’s wife. Copy of F.I.R. is Annex “A”.

3.

That the said Umar Ali is absconding from the date of occurrence and nobody including myself knows the whereabouts of that Umar Ali. The respondent No. 2 instead of searching the Umar Ali, is pressurising the applicant, other

relatives and family members of the applicant for his production, while on the other side, nobody knows about the whereabouts of the said Umar Ali or having any information or connection at present with him. 4.

That the respondent No. 2 is raiding the house of the applicant and calling the applicant time to time at P.S., in lieu of the arrest of the said Umar Ali, which is permanent cause of harassment to the applicant and the act of the respondent No. 2 is unwarranted under the law.

5.

That the applicant, his family and relatives are fully protected under the constitution and the respondent No. 2 has no authority to transgress of his authority, as well as to harm the decency of family life of the applicant.

6.

That the petitioner is left with no other efficacious, speedy, adequate and proper remedy except to invoke the jurisdiction of this Hon’ble Court. Hence, this application.

7.

That all the contents of the above-titled application are true and correct to the best of my knowledge and belief. Nothing has been kept concealed thereto. DEPONENT

Verification: Verified on oath at Multan this _____ day of June, 2003 that all the contents of this affidavit are true and correct to the best of my knowledge and belief. Nothing has been kept concealed thereto.

DEPONENT

IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rashida Begum widow of Muhammad Anwar Khan, caste Mughal Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan. ……Applicant VERSUS 1. State. 2. S.H.O. P.S. Pak Gate, Multan. ……Respondents

Application U/s 22-A, 22-B Cr.P.C. restraining the respondent No. 2 from causing any illegal/unlawful harassment to the petitioner, his family members and relatives.

Respectfully Sheweth: 1.

That the applicant is a widow having four sons and one daughter. The three sons are doing their own business while one son is running a computer institute. The only daughter is a university student. There are some female relatives living as family members with the applicant due to some domestic problems.

2.

That an unfortunate incident took place in the area of P.S. Pak Gate on the midnight of 11.6.03 and 12.6.03 in which a boy was murdered while a lady was injured as well. A case U/s 302/324/34 P.P.C. was registered in which one person Umar Ali was nominated who was seen by the witnesses standing in the street while the actual culprits fled away after the

occurrence. This Umar Ali is one of the applicant’s sons. Copy of F.I.R. is Annex “A”. 3.

That the said Umar Ali is absconding from the date of occurrence and nobody including myself knows the whereabouts of that Umar Ali. The respondent No. 2 instead of searching the Umar Ali, is pressurising the applicant, other relatives and family members of the applicant for his production, while on the other side, nobody knows about the whereabouts of the said Umar Ali or having any information or connection at present with him.

4.

That the respondent No. 2 is raiding the house of the applicant and calling the applicant and her sons time to time at P.S., in lieu of the arrest of the said Umar Ali, which is permanent cause of harassment to the applicant and the act of the respondent No. 2 is unwarranted under the law. It is assured to the respondent No. 2, as and when the Umar Ali will come to the home or his whereabouts shall be known to the applicant, the same shall be furnished to the respondent No. 2, but the respondent No. 2 is giving a deaf ear to this proposition of applicant.

5.

That the applicant, his family and relatives are fully protected under the constitution and the respondent No. 2 has no authority to transgress of his authority, as well as to harm the decency of family life of the applicant.

6.

That the petitioner is left with no other efficacious, speedy, adequate and proper remedy except to invoke the jurisdiction of this Hon’ble Court. Hence, this application. It is, therefore, respectfully prayed that the respondent No. 2 may please be restrained to cause any type of illegal and unlawful harassment to applicant, his family members and his relatives by any means.

Any other relief, which this Hon’ble Court deems fit, may please be extended for the sake of justice. Humble Applicant, 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 COURT OF SESSIONS JUDGE, MULTAN.

Rashida Begum

VS.

State etc.

Application U/s 22-A, 22-B Cr.P.C. AFFIDAVIT of: Rashida Begum widow of Muhammad Anwar Khan, caste Mughal Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan. I, the above-named deponent do hereby solemnly affirm and declare as under: 1.

That the applicant is a widow having four sons and one daughter. The three sons are doing their own business while one son is running a computer institute. The only daughter is a university student. There are some female relatives living as family members with the applicant due to some domestic problems.

2.

That an unfortunate incident took place in the area of P.S. Pak Gate on the midnight of 11.6.03 and 12.6.03 in which a boy was murdered while a lady was injured as well. A case U/s 302/324/34 P.P.C. was registered in which one person Umar Ali was nominated who was seen by the witnesses standing in the street while the actual culprits fled away after the occurrence. This Umar Ali is one of the applicant’s sons. Copy of F.I.R. is Annex “A”.

3.

That the said Umar Ali is absconding from the date of occurrence and nobody including myself knows the whereabouts of that Umar Ali. The respondent No. 2 instead

of searching the Umar Ali, is pressurising the applicant, other relatives and family members of the applicant for his production, while on the other side, nobody knows about the whereabouts of the said Umar Ali or having any information or connection at present with him. 4.

That the respondent No. 2 is raiding the house of the applicant and calling the applicant and her sons time to time at P.S., in lieu of the arrest of the said Umar Ali, which is permanent cause of harassment to the applicant and the act of the respondent No. 2 is unwarranted under the law. It is assured to the respondent No. 2, as and when the Umar Ali will come to the home or his whereabouts shall be known to the applicant, the same shall be furnished to the respondent No. 2, but the respondent No. 2 is giving a deaf ear to this proposition of applicant.

5.

That the applicant, his family and relatives are fully protected under the constitution and the respondent No. 2 has no authority to transgress of his authority, as well as to harm the decency of family life of the applicant.

6.

That the petitioner is left with no other efficacious, speedy, adequate and proper remedy except to invoke the jurisdiction of this Hon’ble Court. Hence, this application.

7.

That all the contents of the above-titled application are true and correct to the best of my knowledge and belief. Nothing has been kept concealed thereto. DEPONENT

Verification: Verified on oath at Multan this _____ day of June, 2003 that all the contents of this affidavit are true and correct to the best of my knowledge and belief. Nothing has been kept concealed thereto. DEPONENT