HOW TO WRITE APPLICATION CONTEMPT OF COURT APPLICATION U/S 3, 4 & 5



IN THE COURT OF 1st ADDITIONAL SESSIONS JUDGE HYDERABAD
Misc: Appln: No._______ of 2019

Mohammad Ayoob --------------------------------------- Applicant

V E R S U S

1. Ghulam Yaseen Naseerani S/o Mohammad Younis
By Caste Naseerani R/O Bhittai Town Taluka Qasimabad District Hyderabad.
2. Ghulam Sarwar Buriro S.H.O P.S Nasim Nagar --------Contemnors

CONTEMPT OF COURT APPLICATION U/S 3, 4 & 5 OF THE CONTEMPT OF COURT ORDINANCE 2004 R/W S. 22-A (6) Cr.P.C

                    It is prayed on behalf of applicant/owner named above that this Honorable Court may be pleased to initiate the contempt of Court proceedings against the contemnor named above as they have disobeyed/ floated the orders of this Honorable Court for restoration of Coach/Bus on the consideration of grounds mentioned below:-

G R O U N D S

1. That the applicant/owner has filed above titled application before this Honorable Court which was turned down and was allowed by the honourable High Court of Sindh Circuit court Hyderabad vide order dated 07-1-19, for restoration of Coach/Bus.

2. That he order of honourable high court verified by this honourable court then applicant owner Mohammad Ayoob furnished such solvent surety which was accepted by this honourable court and such release writ was issued to respondent no;2 to release the property viz;Coach/Bus bearing registration No:C-1585 Sawat forth with if not required in any other case.

3. That after receiving release writ applicant owner approached to respondent No:2 for release of his coach who kept him on false hopes and finally directed applicant/owner o come on 15-02-2019 at evening time.

4. That on 15-02-2019 at about 08;00 pm applicant/owner approached to respondent No;2 for release of coach where respondent No:1 along with his other supporters dully armed with lathies were available who restrained applicant/owner not to move coach else would be murdered and in presence of respondent No:2 respondent No;1 with the help of his other accomplices made murderous assault upon him and not allowed him to take his coach despite of request made by applicant/owner neither any action was taken by the respondent No:2 against respondent No:1 and others nor property was restored.

5. That the poor applicant/owner showed them the release order issued by this Honourable court but despite of that respondent No;1 and 2 have violated the orders of this Honorable Court and disobeyed the orders of this Honorable court.

6. That contemnors are duty bound to obey the orders of this Honorable court but the instant petition despite orders of this Honorable Court, the contemnors have violated the orders passed by this Honorable court.

7. That further cogent and strong grounds would be advanced at the time of hearing of this application.

8. That it will be interest justice to allow this application.


HYDERABAD                                          (SAJID MIR)       

DATED:22-02-2019        ADVOCATE FOR APPLICANT/OWNER

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