IN THE COURT OF SESSION JUDGE LAHORE.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Muhammad Saeed son of Mukhtar Ahmed Caste Qazi Resident of Begum Kot Shama Colony Sharaq Pur Road lahore.

                                                                                     (petitioner)                                           

                                        Versus

 

     1.   SHO police Station Shahdara lahore.

     2.   Incharge chowki Muhammad Shafique sub inspector police

           Station Shahdara lahore, and 6/7 other police officials.

3.         Sheikh Sardar son of not known Resident of Nashtar colony

      Street No 1 lahore.

4.         The State .

 

                                                                                    (Respondents)

                              

                                                                                                  

APPLICATION U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA AGED ABOUT 2 YEARS OLD FROM THE ILLEGAL AND IMPROPER CUSTODY OF THE RESPONDENT NO 3.

 

MAY IT PLEASE YOUR HONOUR,

 

1.                 That the abrigdely contents of this application are that the petitioner is a law abiding citizen of Pakistan and has very good antecedent in his credit , and very popular in his community.

 

2.                 That the petitioner was married with the daughter of the respondent No 3 according to Muslim rites and in the presence of the witnesses in the year of 2007 and due to this wedlock one female baby detneu was born .

 

3.                 That it is pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was abnormal and the patient of Epilepti form  by birth and the respondent No 3 with malafide intention and ulterior motive married her with the petitioner.

 

4.                 That on the first day of the marriage the petitioner came to know regarding the illness of the Mst Nargis bibi , but due to the fear of Allah the petitioner accept her with all her illness , and began to her treatment .

 

5.                 That the mental and physical health conditions of the wife of the petitioner became down day by day and at least the respondent No 3 took back her daughter from the house of the petitioner for further treatment about one month ago , while the minor Mst Zahra remained in the house of the petitioner, while the petitioner and his sisters were looking after the minor .

 

6.                 That on  15-05-11 at about 4/5 pm when the petitioner was present at his home at once respondents No 2 with the active convenience of the respondent No3 forcibly entered in the house of the petitioner and forcibly snatched the minor Mst Zahra from the legal custody of the petitioner and handed over to the respondent No 3 and fled away from the spot.

 

7.                 That being aggrieved the petitioner at once approached the respondent No 1 and told him the whole story about the kidnap of the daughter of the petitioner, but the respondent No 1 did not pay any attention to this fact and kicked out the petitioner from the police stations.

 

8.                 That petitioner has no other speedy and educate remedy except to invoke the jurisdiction of this honourable court for the recovery of her minor daughter from the illegal and improper custody of the respondent No 3, hence this petition.

 

             

Prayer

 

It is therefore respectfully prayed that the petition of the petitioner may kindly be accepted and request for  depute a bailiff of this honourable court for the recovery of minor daughter of the petitioner from the illegal and improper custody of the respondent No 3 and oblige.

                                                                                  

                                                            Petitioner.

             Through :                                      

 

16-05-11

                                           Mian Abdul Jabbar Khan

Advocate High Court

 

 

 

 

 

 

 

 

 

 

 

Sample Affidavit

 

 

 

 

 

 

 

 

 

 

 

IN THE COURT OF SESSION JUDGE LAHORE.

 

 

 

 

 

 

 

 

 

 

 

 

Muhammad Saeed son of Mukhtar Ahmed Caste Qazi Resident of Begum Kot Shama Colony Sharaq Pur Road lahore.

                                                                                     (petitioner)                                          

                                        Versus

 

     1.   SHO police Station Shahdara lahore.

     2.   Incharge chowki Muhammad Shafique sub inspector police

           Station Shahdara lahore, and 6/7 other police officials.

5.        Sheikh Sardar son of not known Resident of Nashtar colony

      Street No 1 lahore.

6.        The State .

 

                                                                                    (Respondents)

                               

                                                                                                 

APPLICATION U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA AGED ABOUT 2 YEARS OLD FROM THE ILLEGAL AND IMPROPER CUSTODY OF THE RESPONDENT NO 3.

 

MAY IT PLEASE YOUR HONOUR,

              Affidavite of Muhammad Saeed son of Mukhtar Ahmed  

              Caste Qazi Resident of Begum Kot Shama Colony Sharaq  

              Pur Road lahore do hereby solemnly affirm as under,

 

9.                That the abrigdely contents of this application are that the petitioner is a law abiding citizen of Pakistan and has very good antecedent in his credit , and very popular in his community.

 

10.           That the petitioner was married with the daughter of the respondent No 3 according to Muslim rites and in the presence of the witnesses in the year of 2007 and due to this wedlock one female baby detneu was born .

 

11.           That it is pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was abnormal and the patient of Epilepti form  by birth and the respondent No 3 with malafide intention and ulterior motive married her with the petitioner.

 

12.           That on the first day of the marriage the petitioner came to know regarding the illness of the Mst Nargis bibi , but due to the fear of Allah the petitioner accept her with all her illness , and began to her treatment .

 

13.           That the mental and physical health conditions of the wife of the petitioner became down day by day and at least the respondent No 3 took back her daughter from the house of the petitioner for further treatment about one month ago , while the minor Mst Zahra remained in the house of the petitioner, while the petitioner and his sisters were looking after the minor .

 

14.           That on  15-05-11 at about 4/5 pm when the petitioner was present at his home at once respondents No 2 with the active convenience of the respondent No3 forcibly entered in the house of the petitioner and forcibly snatched the minor Mst Zahra from the legal custody of the petitioner and handed over to the respondent No 3 and fled away from the spot.

 

15.           That being aggrieved the petitioner at once approached the respondent No 1 and told him the whole story about the kidnap of the daughter of the petitioner, but the respondent No 1 did not pay any attention to this fact and kicked out the petitioner from the police stations.

 

16.           That petitioner has no other speedy and educate remedy except to invoke the jurisdiction of this honourable court for the recovery of her minor daughter from the illegal and improper custody of the respondent No 3, hence this petition.

 

 

 

                                                            Deponent

 

 

 

Vereification : -

Verified on oath at Lahore On 16-05-11 that the contents of the said petition are correct to the best of my knowledge and belief.

                          

 

                                                            Deponent