Legal Drafting II

Topic: Private Complaint

Section: A

Submitted by:

Usama Ataullah 4987-BS-LLB-21

Usman Umer 4985-BS-LLB-21
Fahad Bin Tariq 4963-BS-LLB-21
Muhammad Naman 4941-BS-LLB-21
Akif Rasool 4905-BS-LLB-21

Submitted to: Dr. Abida Hasssan (AHC)

Dr. Muhammad Iqbal Law School, GC University Lahore

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 Acknowledgment

We would like to express our sincere gratitude for the successful completion of this project on
“Private Complaint with Relevant Case Laws”. In this regard, I would like to acknowledge the
guidance and expertise of our esteemed teacher Dr. Abida Hassan, which played a crucial role in shaping
the content and analyzing the topic. This piece of writing would not have been possible without the
encouragement from my respected teacher.

April 25, 2025

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 Table of Contents

Sr. No Contents Page

1 Abstract 4

2 Introduction: 5

3 MEANING OF COMPLAINT 5

4 Essentials of a Valid Complaint: 5-6

5 Procedure By Magistrate Not Competent to Take Cognizance of The Case 6-7

6 Whether a Magistrate can issue process based on Material Facts and Direct 7
Investigation by Police?
7 Judicial Pronouncements 8-11

8 Sample of Private Complaint 11-14

9 Landmark Case Laws 15-17

10 Conclusion 18

11 References 19

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Abstract

The Criminal Procedure Code (CrPC) of India provides mechanisms through which individuals
can seek redressal against criminal acts. One such mechanism is the provision for filing a private
complaint, governed primarily by Sections 200 to 204 of the CrPC. Unlike police-reported cases,
a private complaint allows an aggrieved person to directly approach a Magistrate with allegations
of a criminal offense. This provision is essential in upholding access to justice, especially in cases
where the police fail or refuse to register a First Information Report (FIR). The Magistrate, upon
receiving the complaint, may take cognizance of the offense, examine the complainant and
witnesses, and decide whether to issue process against the accused. The process ensures a balance
between preventing frivolous litigation and enabling genuine grievances to be heard. This abstract
explores the legal foundation, procedural steps, judicial interpretations, and practical implications
of private complaints under CrPC, highlighting its significance in empowering individuals and
strengthening the justice delivery system.

Keywords:
Criminal Procedure Code (CrPC), Private Complaint, Section 200 CrPC, Cognizance of Offence,
Magistrate’s Powers, Access to Justice, Non-Cognizable Offence, Judicial Discretion, Complaint
Procedure

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 Private Complaint with Relevant Case Laws

Introduction:
This assignment explains circumstances under which a Magistrate can take an account of the
offence done. The action taken by the Magistrate in the offence implies that the Magistrate shall
have put a thought to the offence mentioned in the police report with the view kept in mind
regarding the further proceedings which are necessary for the trial of the person accused of that
offence. This article also talks about the procedure of action taken by the magistrate and which are
Preparatory to the trial of the case. Section 200 to Section 203 the Criminal Procedure Code
(1898) are important to eliminate or avoid the false, inappropriate and without due cause filed
complaints aimed at harassing. (Chohan)

MEANING OF COMPLAINT
The Complaint is defined in Section 2(d) of CrPC 1898. As per this section, it states that any
allegation made verbally or in writing to a Magistrate, to take action under this Criminal Procedure
Code that some person, whether known or unknown, has committed an offence, but it does not
include a police report or statement. (Ratanlal, 2023)

Essentials of a Valid Complaint:

The following are the essentials of a valid complaint;

• A complaint requires an allegation of commission of an offence by offender.

• The complaint can be orally or in writing.
• The complaint must be made to a Magistrate.
• The complaint should be made to take action by the Magistrate.

A complaint is made to the Magistrate in a view with taking cognizance of the offence, where it
the Magistrate takes cognizance of the offence on a complaint, the first step is to examine the

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complainant and the witnesses present and the matter of such shall reduce to the writing of the
examination and signing it by the complainant and the witnesses and the Magistrate.

In the case Gurudas Balkrishna v. Chief Judicial Magistrate Go, a complaint was filed by the
applicant on 31st July 1992 here the Magistrate has not even recorded his statement for the
verification of the complainant for several months. It was held that the Magistrate to record the
evidence for the complainant and the witnesses, if any, within a week from the date of its order,
and the magistrate is not permitted to delay the verification for months. (Gurudas Balkrishna vs
Chief Judicial Magistrate, 1992)

Procedure By Magistrate Not Competent to Take Cognizance of the Case (Section 201):
If the complaint in writing has been made to Magistrate not competent to take the cognizance of
the offence, he shall;

• The Magistrate can return the complaint about the presentation to the proper Court with
approval to that conclusion.
• If the complaint is not in writing, then the Magistrate shall direct the complainant to
the proper Court.
If an offence has occurred in the presence of the Magistrate, here the Magistrate has the power to
take the Cognizance of offence directly by filing a complaint or he can appoint his subordinate to
file a complaint against accused and it is clearly explained in Section 153(3) of CrPC.

In this case, Rajendra Singh v. State of Bihar the court acquitted the accused under the ground
that the court has no jurisdiction to take action over the complaint. Hence it was helthat the order
of acquittal was illegal as the court can return the complaint about the presentation to the proper
court instead of acquitting the accused. (Rajendra Singh vs The State Of Bihar, 2024)

Section 202 Postponement of Issue of Process:

Any Magistrate on the acceptance of a complaint of an offence which he is authorized to take the
cognizance may, if he thinks suitable, may in this case where the accused is residing at a place
beyond the area of jurisdiction then the postponement of issue of process against the accused, and

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either investigate into the case himself or order an inquiry to be made by the police officer for the
purpose of deciding whether there is sufficient ground for proceeding.

If the complainant is not made by a court, no such direction for investigation shall be made unless
the complainant and the witness present (if any) have been examined under Section 200. If the
complaint is exclusively triable by the Court of Sessions then the Magistrate shall not direct the
complaint about the investigation. (Singh, 2020)

In D Lakshminarayan v. Narayana, the Supreme Court observed that the sub-section (1) of
Section202 CrPc 1898, a Magistrate who receives a complaint disclosing offence exclusively
triable in Sessions Court is not debarred from sending it to the police for investigation. (Devarapalll
Lakshminarayana Reddy & ... vs [Link] Reddy & Ors, 1976)

Whether a Magistrate can issue process on the basis of Material Facts and Direct
Investigation by Police?

The Magistrate can issue process without a police report under the material facts as per the Section
202 CrPc. The issue of process can be in summons or order and it is the power of the Magistrate
to provide it by checking into the facts provided. With the 2006 amendment in Sec 202 CrPc, it is
a duty of Magistrate to hold the inquiry or the investigation as the accused may be residing not
beyond the area where is exercises his jurisdiction.

Effect of Dismissal:
The Magistrate has no power to review the order of dismissal of the first complaint and it leads to
the legal determination of complaint If the complaint is dismissed for the default, it cannot be
revived by order of dismissal

POWERS OF MAGISTRATE
1. Section 200 demands the Magistrate to examine both the Complainant and the Witnesses
present. This obligation being essential, the Magistrate needs to ask the complaint if any
witness is there or not. In the situation of absentee of the witness, the Magistrate should

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 record the following fact in the order sheet.
2. Inquiry or Investigation for Further Examination of the complaint by the Magistrate-
Any Magistrate receiving a complaint of an offence which he is authorized to take action
on or which had been directed to him under Section 192 of CrPC, If a Magistrate thinks
it fit to postpone the issue of proceedings against the accused person and either can inquire
into the case himself or direct an investigation to be made by a police officer or by any
other person which he thinks is fit for the purpose of deciding whether or not there is
sufficient evidence for the proceeding.

3. Section 203 gives the power to dismiss the complaint under this section in every case and
for which he shall briefly record his reasons for the same because it will help in determining
whether the Magistrate while dismissing the complaint made by the complainant applied
his mind to the facts available or whether exercised his discretion properly or not.

JUDICIAL PRONOUNCEMENTS

In Mehmood Ul Rehman v. Khazir Mohammad Tunda (2015) case, Supreme court held that:
According to Section 190(1)(b) of CrPC, the Magistrate has the advantage over the police report
which mentions the relevant facts related to the complaints and further, the Section 190(1)(c) of
CrPC. provides that the Magistrate has the power to take account of the information or knowledge
of the commission of offence received through any other person than the police report. But under
Section 190(1)(a) Magistrate has a complaint as the only option. Therefore, the Magistrate is not
required to take cognizance of the complaint directly and does not reveal the commission of any
offence mentioned in the complaint by the complainant as per the Section 190(1)(a) and complaint
is simply to be dismissed by the Magistrate. The steps taken by the Magistrate followed by Section
204 should make it visible that he has put in his mind the facts and statements and there is a valid
ground for legal proceeding against such offence further by interrogating the accused person on
whom the accusations are made in respect to the offence committed to appear before the court.

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Only on satisfaction on the ground for proceeding would mean that the facts mentioned in the
complaint would comprise an offence and when examined along with the recorded statements
would directly make the accused person answerable before the court. There needs to be a speaking
order passed as per Section 203 of CrPC when the complaint is dismissed by the Magistrate and
reasons needed to be stated briefly regarding the same. Thus, the above- mentioned judgement by
the Supreme Court settles the issue by holding that the Magistrate may dismiss a private complaint
when there are facts mentioned in such complaint does not reveal any offence directly without
making any further legal inquiry in such case. (Mehmood Ul Rehman vs Khazir Mohammad
Tunda, 2015).

In the case Manharibhai Muljibhai Kakadia & Anr Vs. Shaileshbhai Mohanbhai Patel & Ors.
Shaileshbhai Mohanbhai Patel, filed a criminal complaint in the Court of Chief Judicial Magistrate,
Surat against Manharibhai Muljibhai Kakadia and Paresh Lavjibhai Patel. Appellants put charges
against them that they had pre-planned a conspiracy by creating forged documents and achieved
signatures of the complainant, his father and uncle, two sons of his uncle, and his elder brother.
Further, used the said documents as authentic and original by producing the same before the
District Registrar, and obtained the registration of Indoregency Cooperative Housing Society
Limited by making a false representation. By doing so the accused (appellants) have caused
financial loss and physical and mental distress
to the complainant and his family members. He also has deceived the complainant and his family
members by obtaining huge financial advantage by taking possession of the complainant’s
property. Thus, it was considered that the appellants have committed offences punishable under
Sections 420, 467, 468, 471 and 120-B under Pakistan Penal Code (1860).

Decision: Supreme Court held that in a revision petition preferred by the complainant before the
High Court or the Sessions Judge challenging an order of the Magistrate dismissing the complaint
under Section 203 of the Code at the stage under Section 200 or after following the process
examined under Section 202 of the CrPC, the accused or a person who is suspected to have
committed an offence is legally entitled to be heard by the revisional court. In other words, where
a complaint has been dismissed by the Magistrate under Section 203, made by the complainant
can be challenged in a revision petition before the High Court or the Sessions Judge, the persons

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who are accused in the complaint have a right to be heard in such a revision petition. If the
revisional court overrules the order of the Magistrate dismissing the complaint and then the
complaint is restored to the file of the Magistrate and it is sent back for fresh consideration of the
grounds. The persons who are mentioned in the complaint who have committed the offence have
no right to participate in the proceedings nor are they entitled to any hearing of any sort whatsoever
by the Magistrate until the consideration in respect of matter by the Magistrate for issuing of
process. The judgments of the High Courts to the contrary are overruled. (Manharibhai Muljibhai
Kakadia & Anr vs Shaileshbhai Mohanbhai Patel & Or, 2012)

The order passed under Section 203 could be called out in revision. The question whether a suspect
is entitled to hearing by the revisional court in a revision preferred by the complainant challenging
an order of the Magistrate dismissing the complaint under Section 203 has been answered in the
confirmation by the Supreme Court.

In the case of Chandra Deo Singh Vs Prokash Chandra Bose and Anr, the honourable judge
believed that since there is only one offence, i.e., the murder of Nageswar Singh, there can be only
one trial and no further enquiry can be made in respect to the other persons who are being tried for
that offence. As there was no availability of material facts on record by which the court could tell
what happened to the enquiry against Asim Mondal and ArunMondal after the dismissal of their
application for revision by the High Court. That report had been received which shows the High
Court directed that the commitment proceedings against these two persons have stayed pending
which led to the disposal of the present appeal by this court. The Court said that it cannot appreciate
the argument that an enquiry against a different person with reference to the same offence cannot
be undertaken.

In view of what we have stated above, it is not necessary to say very much about the last ground.
Section 203 of the Code of Criminal Procedure provides that where the Magistrate dismisses a
complaint because according to his judgment there is no sufficient ground for proceeding with the
trial, and he should record his reasons for doing so. Here, as already stated the Magistrate pursued
the report of the enquiring Magistrate and then proceeded to dismiss the complaint. In support of
this view, the dependency is placed upon the decision of the court.

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Here, in this case, dismissal of a complaint by the Magistrate at the stage of inquiry under Section
203 was set aside by the Supreme Court by laying down that test was whether there was sufficient
ground for the proceeding and not whether there was sufficient ground for conviction. The Court
further noticed that where there is direct evidence, even though the accused may have a safeguard
that the offence is committed by some other persons, then the matter has to be left to be decided
by the appropriate forum at the appropriate stage and the issue of the process cannot be refused.
Unless the Magistrate finds that the evidence presented before him is self-contradictory or
essentially untrustworthy then the process cannot be refused if that evidence makes out a direct
cause.

Sample of Private Complaint

IN THE COURT OF THE LEARNED AREA MAGISTRATE, LAHORE

PRIVATE COMPLAINT NO:___________/2018

___, RESIDENT OF ____, LAHORE.

….…Complainant
VERSUS

i. ____, SON OF _______

……Respondents

COMPLAINT UNDER SECTION 200 CRPC

RESPECTFULLY SHEWETH,
1. That the addresses of the parties of the purpose of issuance of summons/warrants issued by
this Honorable court have correctly been given above.

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2. That through the instant complaint, the complainant humbly seeks indulgence of this
learned court for summoning and conviction of the respondents/ accused persons for
committing heinous crimes and taking law in their hands

3. That succinctly stated facts giving rise to the filing of complaint in hand are that the
complainant is in peaceful possession of upper portion of the property situated at ______,
Lahore. The complainant is a retired banker and he has been delivering lectures at various
universities and private colleges since his retirement. The complainant obtained above
mentioned property at rent and he has been enjoying the possession of the same as a
peaceful tenant.

4. That respondent/ accused no. 2 dwells at the lower portion/ ground floor of aforesaid
property as tenant. The respondent no. 2 is running an unknown and suspicious business at
the place of her residence and her customers often visit the portion occupied by her even
at odd hours. The complainant and his family members had requested the respondent no. 2
to mend her ways of business because the complainant and his family members were facing
severe problems due to frequent visits of her customers. However, she never paid any heed
to the requests of the complainant. On the contrary, she carried on her suspicious business
and activities.

5. That the married daughter of the complainant, namely _____ resides at ____(out of
Pakistan) with her husband but for the purpose of her education she is living with the
complainant at his residence these days. The daughter of the complainant is doing her MBA
Marketing from Punjab University. On 26th of January 2018 at about 1:00pm when the
daughter of the complainant tried to park her car in the porch she was forbidden by the
respondent no. 2 to do the same because respondent no. 2 wanted one of her customers to
park the car in the porch but the daughter of the complainant refused to let any outsider
park his car inside the house. The complainant also reached the spot and he once again
requested the respondent no. 2 to leave her mysterious activities. The respondent no. 2

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 threatened the complainant and his daughter that she would teach both of them a lesson but
the complainant and his daughter left the spot and went to their residence that is upper
portion of the house.

6. That after half an hour someone knocked at the door of the upper portion of the property,
wherein, the complainant resides; the daughter of the complainant went to open the door.
When the daughter of the complainant opened the door she found respondent no. 1 along
with three unknown persons standing at the door. The moment she opened the door
respondent/accused no. 1 grabbed the daughter of the complainant from her hair, when the
complainant tried to release her from her clutches, Respondent No. 1 kicked the
complainant, snatched his phone and locked the door from outside and took away the
daughter of the complainant to the lower portion of the house. The respondents along with
two unknown persons beat the daughter of the complainant. While respondent no.1 had
grabbed the daughter of the complainant through her hair, respondent no. 2 snatched heavy
gold chain with diamonds from her neck and then after beating her they locked her in a
room and kept her in illegal detention, moreover, they opened the motor vehicle of the
daughter of the complainant Toyota Corolla and took away registration book of the vehicle
along with the Laptop of Apple company of latest model owned by the daughter of the
complainant which was placed at the rear seat of aforesaid vehicle.

7. That the complainant was detained in the upper portion along with his wife, he made much
noise but of no use, therefore, he couldn’t resist while his daughter was being detained and
beaten up. After a while, other daughter of the complainant, namely _______ reached the
premises unlocked the complainant and thereafter the complainant along with other
daughter went to the lower portion and rescued the daughter of the complainant. The
respondent no. 1 flew away with diamond and gold chain, laptop and original documents
of aforesaid vehicle. The police also reached the spot and the complainant also submitted
an application for registration of FIR against the culprits i.e. respondents but due to some
unknown reasons they failed to take any action against the respondents. Copy of
application submitted to police is appended herewith.

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 8. The illegal and unlawful acts of the respondent amount to heinous offences and crimes and
they also took away valuable items of value more than one million, therefore, they are
liable to be prosecuted inter-alia under following sections:
i. 149, PPC-1860: Unlawful assembly
ii. 347, PPC-1860: Wrongful confinement to extort property, or constraint to illegal act
iii. 354, PPC-1860: Assault and criminal force to women with intent to outrage her modesty
iv. 386, PPC-1860: Extortion by putting a person in fear of death or grievous hurt
v. 356, PPC,1860: Assault and Criminal force in attempt to commit theft of property carried
by person

PRAYER
In the aforementioned circumstance, it is humbly prayed the respondents may be summoned and
punished in accordance with the law.
COMPLAINANT
Through
ZEESHAN AHMAD MALIK
Advocate High Court
“THE LEGAL MENTORS”
66/3, HAJVERY COMPLEX, 2-MOZANG ROAD, LAHORE.

CERTIFICATE:
It is certified that upon instructions of our client, it is the first private complaint filed before this
Learned Court.

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 Landmark Judgements

Shahzad v. Ex-Officio Justice of Peace and others (2025 P Cr. L J 447 Lahore)

Facts: Shahzad filed an application under Section 22-A CrPC for registration of an FIR against
his ex-wife and her alleged new husband, claiming she remarried without divorce. A previous
similar application was dismissed.

Issue: Whether a second application under Section 22-A CrPC is barred by the principle of res
judicata, and whether a private complaint is still maintainable.

Judicial Interpretation: The court affirmed that the Ex-officio Justice of Peace exercises quasi-
judicial functions under Section 22-A(6), so res judicata applies to repeated applications. However,
it emphasized that private complaint remains an independent statutory remedy unaffected by res
judicata. The petition was dismissed as the second application was barred, but Shahzad was
advised to pursue a private complaint if he desired. (Shahzad v. Ex-Officio Justice of Peace and
others )

Mohammad Asif v. Umar Billo and others (2020 YLR Note 2 Sindh)

Facts: Asif filed a private complaint alleging forgery concerning a property, despite two earlier
unsuccessful attempts—one via FIR and the other through a direct complaint under the Illegal
Dispossession Act.

Issue: Whether a private complaint was maintainable after failure to prove allegations in earlier
proceedings.

Judicial Interpretation: The court held that without first approaching police for FIR and
exhausting that remedy, a private complaint is not maintainable under Section 200 CrPC.
Additionally, the repeated allegations based on the same documents amounted to an abuse of

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process. Appeal against acquittal was dismissed; the private complaint was found to be frivolous
and barred in law. (Mohammad Asif v. Umar Billo and others )

Ghulam Hyder v. Special Judge, Anti-Corruption (P) Hyderabad and others (2020 MLD
634 Sindh - Hyderabad Bench)

Facts: The complainant, a contractor, alleged non-payment by government officials and filed a
direct private complaint before the Anti-Corruption Court, which was dismissed based on an
inquiry report showing no dues.

Issue: Whether the complaint disclosed sufficient grounds to summon accused under Sections
200–203 CrPC.

Judicial Interpretation: The court emphasized that material suppression and lack of mens rea or
actus reus made the complaint baseless. It reaffirmed that private complaints must satisfy the court
on all legal ingredients before process is issued. The revision was dismissed; complaint was
rightfully rejected due to concealment of facts and absence of criminal intent. (Ghulam Hyder v.
Special Judge, Anti-Corruption (P) Hyderabad and others)

Muhammad Jawad Hamid v. Mian Muhammad Nawaz Sharif and others (2019 P Cr. L J
665 Lahore)

Facts: A private complaint was filed against political figures after dissatisfaction with a State
FIR concerning the Model Town incident. The trial court declined to summon some high-profile
respondents.

Issue: Whether dismissal of private complaint against specific respondents was valid and
whether private complaints can supplement state investigations.

Judicial Interpretation: The court ruled that orders under Sections 203 and 204 CrPC are judicial
in nature. A private complaint can be filed even after an FIR, provided new facts or evidence are
presented. However, exaggerated or conjectural accusations without direct knowledge were
discouraged. Majority upheld non-summoning order; however, dissenting judge remanded case

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for further inquiry. The court reaffirmed discretion of trial court in assessing sufficiency of material
in private complaints. (Muhammad Jawad Hamid v. Mian Muhammad Nawaz Sharif and others )

Zahoor Hussain v. The State (PLD 2007 SC 9)

Facts: This case was cited for general principles governing private complaints, particularly the
limited right of audience for the accused during pre-process stages.

Issue: When and how a person complained against in a private complaint can be heard before
summoning.

Judicial Interpretation: Supreme Court clarified that before issuance of process under Section
204 CrPC, the accused has no locus standi to appear. Inquiry under Section 202 is meant to
verify truthfulness without full trial, ensuring protection from false and vexatious complaints.
The ruling provided authoritative guidance applied by other courts to limit misuse of private
complaints and regulate summoning procedures. (Zahoor Hussain v. The State )

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CONCLUSION

When a complaint is filed in writing before the Court, the Magistrate, upon examining the contents
of the complaint, registers it. In accordance with Section 200 of the Code of Criminal Procedure,
1973, the statement of the complainant is recorded on oath, typically on the same day. If the
Magistrate considers it necessary to inquire further before issuing process, especially in cases
where the accused resides outside the jurisdiction of the court or the nature of the complaint
requires additional verification, the matter is then posted for recording the evidence of witnesses
under Section 202 CrPC on a subsequent date. The purpose of this inquiry is to determine whether
there exists sufficient ground to proceed against the accused.
After the examination of the complainant and any witnesses, the Magistrate undertakes a careful
evaluation of the material on record. If the Magistrate is satisfied that there is a prima facie case
and sufficient grounds exist, process is issued under Section 204 CrPC, thereby summoning the
accused to face trial. Conversely, if the evidence does not disclose any grounds for proceeding, the
Magistrate may dismiss the complaint under Section 203 CrPC, providing succinct reasons for
such dismissal. (Sharma, 2021)
This structured mechanism reflects the careful balance maintained by the criminal justice system—
safeguarding the rights of individuals against frivolous litigation while ensuring that genuine
grievances are addressed at the threshold. The preliminary scrutiny by the Magistrate acts as an
important filter, preventing misuse of the process of law and ensuring that only those complaints
which disclose a clear case are permitted to proceed to trial.

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References
1. Chohan, M. N. (n.d.). In Code of Criminal Procedure 1898. Lahore: Lords Law Book House.
2. Devarapalll Lakshminarayana Reddy & ... vs [Link] Reddy & Ors (Supreme Court of India
May 4, 1976).
3. Ghulam Hyder v. Special Judge, Anti-Corruption (P) Hyderabad and others, (2020 MLD 634 Sindh
- Hyderabad Bench) (Sindh High Court -Hyderabad Bench).
4. Gurudas Balkrishna vs Chief Judicial Magistrate (Panji-Goa October 16, 1992). Retrieved from
Indiankanoon.
5. Manharibhai Muljibhai Kakadia & Anr vs Shaileshbhai Mohanbhai Patel & Or (Supreme Court of
India October 1, 2012).
6. Mehmood Ul Rehman vs Khazir Mohammad Tunda (Supreme Court-Daily Orders March 31,
2015).
7. Mohammad Asif v. Umar Billo and others , (2020 YLR Note 2 Sindh) (Sindh High Court).
8. Muhammad Jawad Hamid v. Mian Muhammad Nawaz Sharif and others , (2019 P Cr. L J 665
Lahore) (Lahore High Court Lahore).
9. Rajendra Singh vs The State Of Bihar (Patna High Court July 20, 2024).
10. Ratanlal, T. &. (2023). The Code of Criminal Procedure. LexisNexis.
11. Shahzad v. Ex-Officio Justice of Peace and others , (2025 P Cr. L J 447) ( Lahore High Court-
Lahore).
12. Sharma, G. K. (2021). Role of Magistrate in Private Complaint Cases under CrPC. Journal of
Indian Law and Society, 45-58.
13. Singh, A. (2020). Understanding Preliminary Enquiry under Section 202 CrPC. . National Law
Review.
14. Zahoor Hussain v. The State , (PLD 2007 SC 9) (Supreme Court of Pakistan).

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