Tuesday, 16 August 2016

Application U/S 22 A.B (Vi)



 

 

 

                       IN THE COURT OF SESSIONS JUDGE DADU.

             Crl. Misc Appln NO.       of 2016.


Muhammad Anwar S/O Khair Muhammad Solangi R/O thariri Muhabbat Taluka Mehar District Dadu…………………………………………….Applicant/ Complainant.

Versus

1: SSP Dadu.
2: SHO P.S Thariri Mohabat.……………………………………Opponents

                        NAME OF THE ACCUSED

1: Umed Ali S/O Pathan solangi
2: Munawar Ali s/o Pathan solangi
3: Waheed Ali s/o Pathan solangi
4: Sikander Ali s/o Nabi Bux Solangi
5: Masood s/o Sikander ali Solangi
6: Ameen s/o Bahadur Solangi
7: Saeed s/o  Nazeer Solangi
All resident of village Mitho Machi Taluka Mehar  District Dadu.

                                   Crime No. 18/2016 P.S Thariri Mohabat
                                   U/S. 506/2,337 Ai,337fi, 147, 148,
                                     149, 504,  PPC.

APPLICATION UNDER SECTION 22-A-B(vi) CR.PC.

               
                                It is respectfully prayed on behalf of the above
named applicant / complainant this Honorable court may kindly be pleased to direct the opponent to arrest the above named accused, allegedly involved the above crime and offence and submit charge sheet against them in court to stand their trial, on the consideration of the following grounds.
                Earlier no application has been filed by the undersigned counsel.

GROUNDS
1:        That the name  of accused persons along with the specific role is mentioned in the F.I.R and they are real culprits of the offence.
                2:             That the accused are source able and influential persons having hidden connection with the investigating officer of this case and SHO P.S Thariri Mohabat.
                3:             That the accused are extending threats of of dire consequences to the applicant/ complainant to withdraw from the case.
                4:             That the investigating officer of this case is not conducting the investigation of the case honestly and fairly.

                5:             That the nominated accused have not been arrested nor recorded the statement of witnesses till yet by the investigating officer, as accused are openly saying that the investigating officer of this case has been won over by them, who has given assurance that he will dispose off their case       under “B” Class.
                6:             That the applicant/complainant apprehends that the investigating officer will not do justice with him.
               
                7:             That from the facts & Circumstances of the case, it will be just and proper order that this honorable court may be pleased to direct the IO/SHO P.S Thariri Mohabat to arrest the accused and submit their charge sheet in court to stand their trial.
                8:             That other and more points will be argued at the hearing of this application.

                9:             That the prayer is made in the interest of justice.


                Dadu.                                                   Advocate
                Dated, 07.06.2016               For the applicant/complainant


                                   

                            





 

 

IN THE COURT OF SESSIONS JUDGE DADU.

Crl. Misc Appln NO.       of 2016.


                 Muhammad Anwar……….…………………………………………..Applicant
Versus
1: SSP Dadu and others……..…………….……………….............Opponents

                             A F F I D A V I T

           I, Muhammad Anwar S/O Khair Muhammad by caste Solangi  Muslim, Adult, R/O  Village Thariri Muhabbat  Taluka Mehar District Dadu, do hereby state on oath as under:-
1.                  That I am applicant in the above filed application 22 A-B (vi) and know the facts very well.
2.                   That accompanying application and instant affidavit have been draft by my counsel under my instructions.
3.                    That whatever stated in the accompanying application is true and correct and hence the contents of the same are not repeated in this affidavit.       
4.                     That whatever stated above is true and correct to the best of my knowledge and belief                            

                                                                                                                                                                                                                                                    Deponent
I know the deponent     
                  
                        Advocate

                       
                        On SA bfore me, the deponent id identified by Mr. Mujjan
            Ali Panhwar, Advocate Dadu, who is known to me personaly.



                                COMMISSIONER FOR TAKING AFFIDAVIT.

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