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IN THE COURT OF JUSTICE OF PEACE ISLAMABAD (WEST)
Mashooq Ali S/o Allah warayo, Resident of Shakriyal Plaza, Flat
No. 01, Street No. 18, Sector F-15/1, Khayaban e Kashmir Society,
Islamabad.
Petitioner…..
Vs.
Station Head Officer, Police Station Kohsar, Islamabad.
Respondent…
PETITION U/S 22-A & B READ WITH SECTION 154 Cr.P.C.
Respectfully Sheweth:
1. The Petitioner is the subject of this State as a law abiding
citizen, a man of noble instinct, profound sincerity and
enjoying the prestigious and respectable status in the
society.
2. That, the accused namely, Muhammad Kamran S/o Gul
Sher Channa issued a cheque in favour of the petitioner,
the same was dishonoured on its presentation, against
which, petitioner on 05.08.2017, moved an application for
the registration of a criminal case against the accused
However, the contents accompanying the Application
may kindly be read as an integral part of this Petition.
(The Copy of the Application is annexed here with).
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3. That, respondent is reluctant to to register the criminal
case and furnished the reason that the matter does not
come under his jurisdiction hence this petition.
4. As per Article 4 of Constitution, this is the inalienable
right of the Petitioner to be dealt with in accordance with
law. By virtue of the aforesaid conduct of the local police,
the petitioner is being deprived from the said right.
5. That petitioner, being a vulnerable class of the society,
grossly ignored by the respondent, rather respondent is
showing leniency towards the accused who has influential
back behind him. The respondent under no authority of
law has any power to refuse the statutory right of the
petitioner envisaged u/s 154 Cr.P.C. rather he is bound by
law to chart down the information received in term of
cognizable offence as it is.
6. That attitude of the respondent towards the non
registration of criminal case comes under the ambit of
neglect, failure and excess of executive power in relation
to his functions and duties.
7. That the petitioner under severe agony and mental anxiety
due to the non cooperative behavior of respondent.
PRAYER
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Under these circumstances, it is humbly prayed that a
direction be issue to the respondent for the
registration of criminal case against the culprits and
direct the Respondents for recording of statement
under section 154 CrPC for commission of an
offence under the relevant sections of penal law, in
the interest of Justice.
Any other relief which this Hon’ble Court thinks just
may also be ordered for the rederassal of the
grievance of the Petitioner.
Petitioner
THROUGH
IMRAN ALI CHHIJAN
Advocate
Note:-
It is Certified, that, this is the first petition U/s 22-A & B and
no other petition is pending before any court, as per
information received by the Petitioner.
The Counsel
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IN THE COURT OF JUSTICE OF PEACE ISLAMABAD (WEST)
Mashooq Ali Vs. S.H.O. Kohsar.
PETITION U/S 22-A & B R/W SEC 154
Cr.P.C.
AFFIDAVIT
I, Mashooq Ali S/o Allah warayo, Resident of Shakriyal Plaza, Flat No.
01, Street No. 18, Sector F-15/1, Khayaban e Kashmir Society,
Islamabad, do hereby solemnly affirm and declare on oath as under:
That the contents of the accompanied Petition along
with the facts and grounds are true and correct to
the best of deponent’s knowledge and belief and
that nothing has been concealed there from.
DEPONENT
Further affirm that the contents of this affidavit are true and correct to
the best of my knowledge and belief and nothing has been suppressed or
withheld.
DEPONENT
