in the court of sessions judge w.ith the power of justice of peace rawalpindi
Muhammad Umar son of Muhammad Usman resident of House No. 48/9-B, satellite
town , Street No. 9, Rawalpindi.
-----Petitioner
versus
1.
The
S.H.O. P.S. New Town, Rawalpindi
2.
City
Police Officer (CPO), Rawalpindi
3.
The State
-----Respondents
application u/s 22-a cr.p.c. for directing to the respondent No. 1 & 2 to register the criminal case u/s 154 cr.p.c.
Respectfully
Sheweth: -
1.
That
the petitioner is a Sub-Inspector, Traffic Warden in the City Traffic Police,
Rawalpindi.
2.
That
on 26-6-2014 at 10:30 a.m. the petitioner, who was on his duty with Traffic
Warden Zohaib on a main artery Akseer Plaza, Chour Chowk, Misrial Road, Rawalpindi,
when many vehicles were parked by the drivers in the NO PARKING AREA. The petitioner’s colleague Traffic Warden Zohaib
challaned five vehicles and when he was challing another vehicle Ghazanfar Butt
reportedly the owner of Makka Clothes House alongwith his servants Abid and
Naseem Shah and another person namely Shamim arrived there started hurling
filthy abuses to me and Traffic Warden Zohaib. Ghazanfar Butt and his
accomplices at the time of abusing also called that by challing the vehicles
their business is destroyed. Traffic Warden Zohaib and myself impleaded
Ghazanfar Butt and his accomplices that they should not take the law into their
hands but they attempted to attack upon the petitioner and Traffic Warden
Naveed. During ongoing of scuffle the SHO of P.S. Westridge Inspector Basharat
also arrived their and who intervened and saved the petitioner and Traffic
Warden Zohaib from the clutches of the above mentioned person. However, the
petitioner immediately wrote an application against the above mentioned persons
making a complaint against the above mentioned persons, who assaulted upon the
petitioner and Traffic Warden Zohaib using criminal force and deterred and
obstructed from discharging our duties as public servant. The SHO took the
complaint of the petitioner and went away.
3.
That
on 27-6-2014 the petitioner was on rest after performing week long duty. The
petitioner’s father, who is a retired Major in Army suffered from acute heart
ailment and for the purposes of surgery, he was to get himself to examined in
AFIC. The petitioner took his father in father’s care to AFIC, where he was
checked up. After that the petitioner’s father told the petitioner to take him
in petitioner’s paternal aunt house, which is situated in the vicinity, where
the occurrence took place on 26-6-2014. On the said date at about 10:30 a.m. when the petitioner and
his father was traveling and were crossing the Akseer Plaza Point, there was a
traffic jam as usual, where the above mentioned persons saw the petitioner
stranded in the traffic. The said persons came out from the shop of Ghazanfar
Butt accused joining with the Saleem Butt another shopkeeper started firing
indiscriminately. The petitioner was dragged out from the car forcibly by the
abovementioned persons. They further gave fists and kicks blows to the
petitioner and started dragging. However, due to the firing of the persons the
petitioner and his father saved unhurt. However, Haji Zafar, Haji Asif, Haji
Shabbir, Malik Kanwar and Fayyaz Raja, who were around there intervened and
saved the petitioner and his father from the clutches of abovementioned
persons.
4.
That
the petitioner’s father reported the occurrence to the police of P.S. New Town
on 27-6-2014 but the police under the influence of above-mentioned persons again
did not register the criminal case.
5.
That
recently three National Assembly Elections were held in the constituency, where
both the occurrences i.e. 26-6-2014 and 27-6-2014 took place and the accused
persons being the key supporters of the political incumbents managed political
and police high ups and got a bogus case registered against the petitioner.
6.
That
the above mentioned persons on 26-6-2014 committed the offence of obstruction,
deterring the petitioner and Traffic Warden Zohaib from discharging their
public duty, extended threats of taking the life of the petitioner and on 27-6-2014 way laid the petitioner
and petitioner’s father by committing the criminal assault and attempting on
the life of the petitioner. The offences which they committed are cognizable,
but the police did not
register the case and did not
perform the obligations under section 154 Cr.P.C. which they are legally bound
to do so.
PRAYER
Under the circumstances, it is respectfully prayed that the application
may graciously be accepted by directing the respondent No. 1 and 2 to register
the criminal case against the above mentioned persons for the heinous crime
they have committed.
Petitioner
Through:
Name of Advocate /Lawyer
Advocate high court,
Advocate high court,
Rawalpindi
Certificate
As per instruction of my client this is the first petition on the subject
being moved in this Honourable Court.
Counsel
in the court of sessions judge with the power of justice of peace. rawalpindi
Muhammad
Umar
vs S.H.O. P.S. New Town, etc
application u/s 22-a cr.p.c. for directing to the respondent No. 1 & 2 to register the criminal case u/s 154 cr.p.c.
AFFIDAVIT
I, Muhammad Umar son of Muhammad
Usman resident of House No. 48/9-B, satellite town , Street No. 9, Rawalpindi, do hereby solemnly affirm and declare that the contents of accompanying
application are true and correct to the best
of my knowledge and belief and nothing has been concealed.
Deponent
Verified on Oath this ____ day of June
2014 that the contents of above Affidavit are true and correct to the best of
my knowledge and belief and nothing has been concealed therefrom.
Deponent
Good effort
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