22 A-B Drafts Samples



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22 A-B Sample


IN THE COURT OF SESSIONS JUDGE/JUSTICE OF PEACE, _________ 

Crl: Misc: Appln: No.__________ of 2021. 


Aarab S/O Mataro, by caste Malik, adult, muslim, r/o

Rasoolabad, taluka ________, District _____________, -------------------------- Petitioner. 


V E R S U S 


1. S.H.O. of P.S.______ , 

2. S.P ___________ ------------------------------------------------------------- Respondents. 


PROPOSED ACCUSED


1. Javed S/O ________, 

2. Mushataq S/O ________, 

3. Azhar S/O _________, 

4. Mohammad Azeem S/O ____________, 

5. Hadi Bux S/O ________, adults, Muslims R/O      Village ___________ Taluka ________________, 


APPLICATION U/S 22, 22-A, CR.P.C. R/W SECTION 25 CR.P.C. 


The Petitioner named above begs to submit as under:- 

1. That the petitioner is law abiding and peaceful citizen and used to reside at captioned address along with Shoaib, Gohram, Ghulam Murtaza, and other family members. 


2. That previously proposed accused persons leveled false allegation of Karrap upon brother of petitioner namely Gohram but same was compromised and such compensation has been paid by the petitioner party. 


3. That on 13-06-2021 at about pm when petitioner along with Shoaib, Gohram, Ghulam Murtaza, and other family members were available in their house all of sudden proposed accused persons dully armed with Lathies trespassed into the house of petitioner over powered upon petitioner party aimed their weapons upon petitioner party and directed the petitioner party that they will commit he murder of Gohram in revenge of previous karrap matter, by saying so accused Javed Instigated the other accused persons to commit their murder on his onstigation accused Azhar caused lath blow to petitioner which hit him at his right side of hand, accused Javed caused lathy blow to Shoaib which hit him at his back side of head, accused Hadi Bux also caused lathy blow to Shaib which hit him at his right side of hand, accused Hadi Bux caused lathy blwos to Gohram which hit him at his left eye blow, left side of body and back side of head, on which petitioner party raised cries and gave them sake of holy Quran to not to commit murder of innocent persons, on their cries co villagers attracted there on seeing them all the accused persons fled away towards their houses by issuing threats of murder. 


4. That then petitioner after making arrangement of conveyance brought himself and other injured persons at P.S for obtaining letter for treatment and where from obtained letter for treatment went to RHC Tangwani after getting necessary treatment went to P.S for registration of FIR. 


5. That petitioner requested respondent No:1 to register his FIR but due to influence of accused persons FIR of the petitioner was not registered. 


6. That the petitioner also went to respondent No. 2 SP Kashmore at Kandhkot for the same purpose, and requested respondent No. 2 to take action against proposed accused and lodge the FIR but his grievance was not redressed nor any heed was paid over his matter. 


7. That as the serious and cognizable offences were committed by the proposed accused person, therefore, respondent No:1 is duty bound to register the FIR of petitioner at verbatim. 


8. That it is the well settled principles of law that if a police officer refused to register the FIR of Petitioner such police officer would expose himself to prosecution for an offence U/S 166 PPC. 


9. That U/S 154 CR.P.C. if an aggrieved person approaches the officer I/C of Police Station for lodging the report either orally or in writing then the first step which the Officer I/C of P.S. is required to take, is to satisfy himself as to whether from the facts narrated by the aggrieved person or from the written complaint a case of cognizable offence has been made-out or not if he is satisfied that a cognizable offence has been committed then the facts of the case are required to be reduced into writing and recorded in the Book known as 154 Cr.P.C. 


10. That the report of cognizable offence is to be registered in the 154 Cr.P.C. Book and the police officer has no option to refuse to register the FIR. 


11. That the registration of FIR is the requirement and direction of law as provided by section 154 Cr.P.C. which every police officer is required to obey but the respondent No:1 has violated the terms and conditions of section 154 Cr.P.C. by refusing the FIR of petitioner. 


12. That there is no any other alternate and efficacious remedy available with the petitioner excepting knocking the door of this Honourable Court. That the petitioner therefore, prays as under:- 





P R A Y E R. 


A)- This Honourable Court may graciously be pleased to direct the respondent No:1 to register the FIR of petitioner as the serious and cognizable offence have been committed by the proposed accused person. 


B)- That this Honourable court may graciously be pleased to refer petitioner and PW Mujeeb Rahman to concern Medical Officer for treatment and certificate. 


C)- This Honourable Court may graciously be pleased to award the cost of this Petition. D)- This Honourable Court may award any other relief which this Honourable Court may deem fit and proper under the circumstances of the case. 



NAME OF CITY.  P E T I T I O N E R.


DATED:22-06-2021 Drafted by me under the instructions from my client. 




(x, y, z) 

        ADVOCATE. 






IN THE COURT OF SESSIONS JUDGE/JUSTICE OF PEACE, _________ 

Crl: Misc: Appln: No.__________ of 2021. 


Aarab  —------------------------------------------------------------------------------- Petitioner. 



V E R S U S 


S.H.O. of P.S. _______& Others —----------------------------------------- Respondents 



A F F I D A V I T 


Aarab S/O _______, by caste ________, adult, muslim, r/o ___________, taluka __________, District Kashmore do hereby state on oath as under:- 

1. That I am petitioner in the accompanying petition and hence well conversant with its facts. 


2. That the accompanying petition has been drafted and filed by my counsel at my instance and contents thereof are true and correct. 


3. That respondent No:1 has refused bluntly to register the FIR despite of approaching to respondent No:2 but our request was turned down. 


4. That I adopt all the grounds of the accompanying petition for the brevity of this affidavit. 5. That whatever is stated above is all true and correct to the best of my knowledge and belief. 



NAME OF CITY.  D E P O N E N T


DATED:22-06-2021 CNIC No. 

                                                                                Cell No. 


I know the deponent. 

Advocate.




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