IN
THE COURT OF
IST CIVIL JUDGE
AND JM DADU
Misc. Application
No. of 2012
Essa Khan S/o
Muhammad Moosa
By caste Chandio
R/o Village Ibrahim
Chano, Taluka
K.N Shah……...…….…….……Applicant/Owner.
V E R S U S
The State……………..……………………………..…..Opponent.
Suspect Report
No.02/ 2012
P.S Rajo Dero
U/S 550 Cr.PC.
APPLICATION U/S 523 Cr.PC.
It is respectfully
prayed on behalf the applicant/owner above
named that this honorable court
may be pleased to restore the seized Motorcycle Hi-Speed, bearing
Registration No.DUD-3612, engine No.RMI477624 and chassis No.SR70-810371 to the
above named applicant/owner on the
consideration of following grounds:-
FACTS:-
Facts of the case are
that SHO of PS Rajo Dero submitted report that on 03.04.2012, he alongwith his
subordinate staff left PS under entry No.17 and went to village Jaffar
Khokhrani to capture absconders and when they were returning to PS and reached
near Peer Allahyar, it was about 07:00 hours one person on seeing them in
police uniform tried to turn his motorcycle to fled away, whom the complainant party asked to stop therefore
he left his motorcycle on the road and fledaway towards North. The complainant took
the motorcycle Hi-Speed, Model 2011 bearing Registration No.DUD-3612, engine
No.RMI477624 and chassis No.SR70-810371 into his custody, prepared such memo
and brought the property at the PS and submitted report U/S:550 Cr.P.C to this
effect.
GROUNDS:-
1.
That the applicant/owner is real owner of the seized motorcycle
and none else is claiming to be the owner.
2.
That the applicant/owner has got all necessary
documents of ownership in his favor.
3.
That the motorcycle is lying at police station without
proper care in open sky therefore the same will be damaged and loss its value
if the same remains at the police station.
4.
That the applicant/owner undertakes to produce the
same before this honorable court, whenever required.
5.
That the motorcycle is not required by police in any
other case or investigation.
6.
That the applicant/owner is prepared to furnish required
surety to the satisfaction of this Honorable Court.
7.
That other and more points will be argued on hearing
of this application with the permission of this honorable court.
8.
That the copy of Registration Certificate of
motorcycle in the name of applicant/owner and copy of CNIC of the applicant,
are submitted herewith.
9. That the prayer is made in the interest of
justice.
Dadu.
Dated.
Advocate
For the
applicant/owner
IN THE COURT
OF IST
CIVIL JUDGE AND
JM DADU
Misc.
Application No. of 2012
Essa Khan ……………………...…….…...……Applicant/Owner.
V E R S U S
The State……………..……………………………….…..Opponent.
Suspect Report
No.02/ 2012
P.S Rajo
Dero
U/S 550 Cr.PC.
AFFIDAVIT
I, Essa Khan
S/o Muhammad Moosa By caste Chandio, muslim, adult R/o Village Ibrahim Chano,
Taluka K.N Shah, do hereby state on oath as under:-
1.
That I am applicant in the above matter and know the
facts very well.
2.
That the accompanying application has been drafted and
filed by my counsel under my instructions.
3.
That I am real owner of the seized motorcycle and have
got all necessary documents of ownership in my name.
4.
That whatever stated above is true and correct to the
best of knowledge and belief.
Dadu
Dated: Deponent.
I know the deponent
Advocate Dadu
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