APPLICATION U/S 22-A, 22-B, 22(6) Cr.P.C FOR HARASSEMENT SAMPLE



IN THE COURT OF SESSIONS JUDGE, HYDERABAD 
Crl.Misc.App.No. _______of 2017

Deen Muhammad s/o Rasheed Ahmed By caste Shar, adult, 
Muslim, 

shop keeper by profession, r/o sheedi goth Taluka 

Qasimabad District Hyderabad - - - - - - - - - - - - - - - - - - - - - - - -  Applicant/Petitioner

VERSUS

Superintendent of Police (Operation) Hyderabad,
S.H.O Police Station Qasimabad,
S.H.O Police Station Nasim Nagar,
4. Ahmed s/o Nooral,
5. Siddique s/o Nooral,
6. Lateef s/o Nooral ,
7. Moru s/o Nooral,
8. Fareed s/o Nooral
9. Haji s/o Alif ,
10. Alif s/o Bahawal, All by caste Shar , adults,Muslims r/o Village Haji Khan Shar Taluka & district Kashmore. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - (Respondents)

APPLICATION U/S 22-A, 22-B, 22(6) Cr.P.C


The petitioner named above begs to submit as under:-

1. That the Petitioner is a law abiding citizen of Pakistan and runs a kiryana Shop at Kashmore town just to fulfill the thirst and hunger of his family, and use to reside at captioned address along with his brothers namely Shabeer Ahmed, Abdul Hakeem, Abdul Ghani and other family members.

2. That private Respondents are vagabond and scoundrel type of persons and also highly influential persons and have support of big guns of the locality and used to get Bhatta (extortion money) from various persons, on the other hand petitioner is a poor person and fulfils the hunger and thirst of his children by running a shop.

3. That thereafter respondent No.4 to 10 with the help of respondent No. 2 to 3 are continuously harassing the petitioner and are demanding extortion money from the petitioner.

4. That about one week back at morning time, when petitioner was available at his shop, all of sudden private respondents arrived at the shop of petitioner duly armed with lethal weapons and demanded extortion money, on refusal from the poor petitioner they got annoyed and started shattering the items lying in the shop, and left away on the intervention of persons of the locality by saying that they will come again and if he did not pay the extortion money, then he will face its dire consequences.

5. That again on 08-10-17, when petitioner was available at his house and were looking after the construction work of his house, where labors were working, all of sudden private respondents arrived there, demanded the extortion money from petitioner on refusal started damaging the construction work, and threatened laborers to stop the construction work and directed them not to construct the house of petitioner else will face its consequences by saying so they left away.

6. That Respondent No. 2 and 3 separately called the petitioner in their offices and directed him to fulfill the requirements of private respondents else he would be booked in chain of false cases.

7. That the petitioner also approached to Respondent No.1 for redressal of his grievance, taking action against Respondent No. 2 to 10 and provide protection but neither any action was taken nor protection was provided by Respondent No.1.

8. That under these circumstances there is no any other remedy except approaching this Honorable court. Hence this petition.

9. That this Honourable Court may be pleased to:-

a. To declare that act of respondents No. 2 to 3 for harassing the petitioner party at the instant of respondents No. 4 to 10 as null, void, illegal, ultra-vires and without any justification.

b. To direct the respondents No. 2 to 3 not to cause harassment to the petitioner party directly or indirectly without lawful authority at the instant of private respondents.

c. To direct the respondent No 1 to provide protection to the lives, liberties and properties of petitioner party as guaranteed under the constitution of Pakistan and also direct the respondent No.1 to call the private respondents in his office where they should execute P.R Bonds that they will not cause any harm to the lives and liberties of the petitioner party.

d. To award any other relief which this Honorable court may deem fit and proper under the circumstances of the petition.

H Y D E R A B A D                                                                           (SAJID MIR)       

Dated 00.00.0000                                                                    Advocate for the applicant

CERTIFICATE

                    This is to certify that this is a first application u/s 265-k CRPC and no such application of same nature has been preferred by undersigned on behalf of the present applicant.

H Y D E R A B A D                                                                           (SAJID MIR)       

Dated 00.00.0000                                                                    Advocate for the applicant






IN THE COURT OF SESSIONS JUDGE, HYDERABAD 
Crl.Misc.App.No. _______of 2017


Deen Muhammad Shar ----------------------------------------------------------- Petitioner

V E R S U S.

SP Hyderabad & Others ---------------------------------------------------------- Respondents

A F F I D A V T

I Deen Muhammad s/o Rasheed Ahmed By caste Shar, adult, muslim , r/o Zulfqar Muhalla Kashmore, Taluka & District Kashmore, do here by state on oath:

1. That I am petitioner in the above petition, hence well conversant with the facts of the case.

2. That I adopt all the grounds of accompanying petition for the brevity of this affidavit.

3. That whatever stated above is all true and correct to the best of my knowledge and belief.


Hyderabad                                                                                    D E P O N E N T


DATED: -08-2017                                                                        CNIC No. 
                                                                                                      Cell No.

                                                                            I know the deponent

H Y D E R A B A D                                                                           (SAJID MIR)       

Dated 00.00.0000                                                                    Advocate for the applicant


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