IN THE COURT OF SESSIONS JUDGE DADU
Criminal
Misc:Appln.No. of
2015.
Sohbat
Ali son of Sajan By caste Zangijo ,
Muslim, Adult, R/O Village Paro Ayoob colony, Taluka & District larkana-----------Applicant/owner.
Vs
The
State---------------------------------------------------------------Opponent.
Crime No:4/2015.PS Phulji Village.
U/S 320-279-427-337 H PPC
APPLICATION UNDER SECTION 516-A CR .P.C.
It
is respectfully prayed by the undersigned applicant/owner that this Honourable
court may kindly be pleased to return/restore Bed ford Truck bearing registration No:TKD 225 ,Engine No:734166,
Chasis No:CTD/T-624623 , model 1976, to
the applicant/owner, during pending trial of case, on the consideration of
following grounds:-
G R O U N D S
1) That the applicant purchased
the above mentioned Truck from Bahawal khan S/O Allah wasayo r/o Larkana Town, Taluka larkana ,
District larkana. Hence he is real owner of the alleged Truck and no body can
claim to be his property except the applicant.
2) That
the police has seized the alleged vehicle of the applicant on lost possession
with malafide intention and ulterior motives.
3) That
the police has managed a false story and seized the alleged Truck of the
applicant with malafide intention and ulterior motives.
4) That
the Truck is lying at Police Station Phulji village Taluka Johi without any
proper shed rather in open sky.
5) That
the vehicle in question needs proper care and maintenance, which is not
possible at Police Station.
6) That
if the Truck remains more at Police station Phulji village taluka Johi, it will
lose maintenance and decay its value to nil.
7) That
the applicant undertakes that he will produce the Truck as and when required by
this Honourable court.
8) That
the applicant is prepared to furnish reasonable surety to the satisfaction of
this Honourable court.
9) That
the prayer is made in the interest of justice.
Dadu.
Dated: .
.2015 Applicant/owner
IN THE COURT OF SESSIONS JUDGE DADU
Criminal Misc:Appln.No. of 2015.
Sohbat
Ali son of Sajan By caste Zangijo , Muslim, Adult,R/O Village Paro Ayoob colony,Taluka
& District larkana-------------Applicant/owner.
Vs
The
State---------------------------------------------------------------Opponent.
Crime No:4/2015.PS Phulji Village.
U/S 320-279-427-337 H PPC
A F F I D A V I T
I, Sohbat Ali son of Sajan, By caste
Zangio , Muslim, Adult, Resident of village paro Ayoob colony taluka and
District Larkana , do hereby state on
oath as under:-
1. That I am applicant/owner in the
above matter and know the facts very well.
2. That the accompanying
application and present affidavit have been drafted and filed by my counsel
under my instructions.
3. That the averments of the main
application may be treated as part and parcel of this affidavit.
4. That whatever is stated above is
true and correct to the best of my knowledge and belief.
Deponent
I know the deponent
Advocate Dadu.
Very helpful sir
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