16.  [Omitted].

COMMENTARY

Lady was medically examined after about one year from her statement made before Family Court.--Record showed that lady allegedly abducted, had filed a suit against her husband for dissolution of marriage. Lady had also sought protection from Magistrate who sent her to Darul Amaan from where she was released and it was several days thereafter that she was medically examined and positive report was given. Alleged abductee had stated before Family Court that she had joined her husband and she did not want to pursue the suit. Lady was medically examined after about one year from her statement made before Family Court. Case being of further inquiry, accused was admitted to bail. 2006 PCr.LJ 816.

No evidence was on record to establish defence of accused that direct enmity existed between him and complainant.--Prima facie sufficient material was available on record to connect accused with commission of offence. Court, at bail stage, was merely to examine material on file to see whether, prima facie, evidence was sufficient to connect accused with the crime. Accused was found involved in a heinous offence which was covered with prohibition as contained in S. 497, Cr.P.C. Accused, who had been absconding in the past, was not entitled for any concession. Bail petition having no force was dismissed. 2006 PCr.LJ 1275.

Quashing of FIR.--Brother of alleged enticed lady in his FIR had alleged enticing away of his sister by petitioner and his co-accused. Alleged enticed lady who was the star witness, had not supported case of the prosecution. No likelihood existed of petitioner and his co-accused being convicted of said offence. Circumstances of case had shown that a matrimonial issue had been converted by complainant party into a criminal case so as to bring weight of criminal law to bear upon alleged enticed lady in order to break her resolve and to force her back into the matrimonial fold of her husband as she was married and she had filed suit for dissolution of marriage against her husband. Such utilization of criminal process, was nothing, but an abuse of process of law which could not be allowed to be perpetuated. FIR, was quashed, in circumstances. 2006 YLR 1660.

Set at liberty to look after her matrimonial and other affairs of normal life.--Adult and major woman who is capable to take decision cannot be forced to be lodged in Dar-ul-Amaan to curtail her right of liberty. Petitioner could not be kept in Dar-ul-Amaan for indefinite period against her wishes as a preventive detention in view of the above circumstances. Petitioner was consequently set at liberty to lead a normal life of a free person. Constitutional petition was allowed accordingly. 2006 YLR 35.

Statement u/S. 164, Cr.P.C.--Petitioner had assailed order passed by Judicial Magistrate whereby statement of petitioner was refused to be recorded on ground that same  was  not  in  accordance  with her free-will. Magistrate had misinterpreted provisions contained in S. 164, Cr.P.C. and made an erroneous order for which there was no justification under law. High Court allowed petition and set aside impugned order with direction that statement of petitioner be recorded as prayed by her, if she was willing to make a voluntary statement. 2006 PCr.LJ 130.

Summoning of accused.--Case of complainant was that petitioners took away her daughter as one of the petitioners had illicit relation with her. Respondent got registered FIR, but police found case to be false and prepared cancellation report. Complainant filed petition u/S. 491, Cr.P.C. for recovery of her daughter which was decided by the Court observing that matter was probed in by various authorities at the various levels, but whereabouts of the daughter of complainant could not be known; also that if complainant was able to locate her daughter anywhere in illegal custody of anybody she would be entitled to get her petition restored so as to recover her daughter. Daughter   of   the   complainant   having   not   been   recovered,  it  was  necessary  for complainant to place on record of the trial Court copy of order passed in petition u/S. 491, Cr.P.C. and the trial Court was to consider the same before passing impugned order of summoning accused, but same having not been done, impugned order of summoning accused was not maintainable and being not legal and proper, was liable to be set aside. Impugned order was set aside and trial Court was directed to pass fresh order after considering order passed on petition u/S. 491, Cr.P.C. and after hearing the parties. 2006 YLR 1824.

Marriage will be presumed, in absence of direct proof from, prolonged and continual cohabitation as husband and wife, the fact of acknowledgement by the man of the paternity of the child born to the woman, provided all the conditions of a valid acknowledgement are fulfilled. Fact of the acknowledgement by the man as the woman as his wife. FIR quashed. Petitioners are husband and wife. Petition accepted. PLJ 2004 Lahore 1224

During Iddat period if any woman entered into Nikah that would be against law and also Injunctions of Islam and it would be liable to Ta'zir. If a married non-Muslim woman would embrace Islam, she must inform her husband of said conversion and her husband either would embrace Islam within period of Iddat in which case marriage would continue, or he would remain a non-Muslim even after expiry of Iddat, period, in which case marriage would stand dissolved. Iddat was compulsory after dissolution of marriage of any character. Within Iddat period Nikah would be invalid rather void and during that period co-habitation would come within definition of Zina and would be liable to be punished. Petition for quashing of F.I.R. was dismissed, in circumstances. PLD 2005 Lah. 126.