IN THE COURT OF DISTRICT AND SESSION JUDGE EAST
AT KARACHI
Cr, Misc No. /2024
Muhammad Atif Siddique
S/o Muhammad Siddiq
R/o Flat No. E-28,
Malir Apartment
Karachi ______________________________________PETITIONER
VERSUS
1) Senior Superintendent of Police
District Korangi, Karachi
2) The station house officer
Police station Khokrapar,
Karachi ______________________________RESPONDENTS
(1) Muhib
S/o Yaseen
R/o Flat No. D- 27,
Malir Apartments, Urdu Nagar,
Karachi.
(2) Namal
S/o Unknown
R/o Flat No. A-22,
Malir Apartments, Urdu Nagar,
Karachi.
1) Ahad
S/o Unknown ____________ Proposed Accused/ Person
PETITION U/S 22-A & 22-B CRIMINAL PROCEDURE CODE
The petitioner above named most respectfully submits as under: -
1. That the petitioner is above named is law-abiding peace-
loving citizen who believes in the rule of law, independence
of judiciary and supremacy constitution which protects the
fundamental and basic rights of every citizen of the Islamic
republic of Pakistan.
2. That the petitioner is resides with his family peacefully in above
mentioned address since long and works as a technician, That on
29-07-2024 the petitioner received an unknown call who called
the petitioner to Pakistan hotel near Muhammad Market for
repairing of water tank when the petitioner reached there, 4 to 5
persons who were already there on motorbikes surrounded the
petitioner one of them started beating him and another person
took his bike and ran away, after that they forcibly put him on
bike and ran away, meanwhile they reached at Saudabad
Chowrangi were the petitioner saw a rangers mobile and he
started shouting for help that the proposed accused persons
want to kidnap me, after listening the petitioner’s voice rangers
officials reached there, after seeing the rangers the petitioner
jumped off the bike and ran towards the rangers who saved him
from the accused persons and arrested the culprits and then they
handed over culprits to the mobile of PS khokhrapar.
3. After that the petitioner reached at PS Khokhrapar along with
police and the police shifted the culprits to the P.S khokhrapar
too. At police station the petitioner demanded to lodge his FIR
against the culprits but the police ignored the petitioner’s
request and after 04 hours they told the petitioner that the SHO
will come tomorrow and after SHO’s instructions they will lodge
the petitioner’s FIR. But unfortunately, the police officials kept
the petitioner in false hopes and didn’t lodge the FIR till today.
4. That on 09-08-2024 the petitioner moved an application to SSP
District Korangi regarding his grievances, in which the petitioner
requested to the SSP Korangi to take legal action the culprits and
direct the SHO to lodge the FIR against the Culprits, but it
couldn’t happen till now.
5. That it is pertinent to mention here that few days ago a baseless
FIR No. 538/2024 has been lodged against the petitioner at P.S
Malir City Karachi and the complainant is the relative of the
proposed accused it is noteworthy that the complainant of such
FIR and her relatives / proposed accused are land grabbers they
want to usurp my Flat.
6. That the petitioner is required protection from the police
and the Hon’ble Court of Law.
7. That the proposed accused persons are criminal minded
and there are serious apprehensions that they can cause
grievance hurt to the petitioner as well as any of his family
member.
8. That the proposed accused committed cognizable offence
by beating, torturing and issuing threats of dire
consequences to the petitioner and his family members
which is not justified in law and the same is totally illegal,
unlawful and liable to be punish with accordance to law.
9. That the petitioner moved application to the respondent
No. 1 & 2 for take legal action and provide protection to the
petitioner from the respondents, but no legal action has
been taken yet nor they taken any interest in this matter.
(Copies of application and other relevant documents are annex as
Annexure A to A )
10. That other grounds shall be urged at the time of hearing of
this petition with kind of permission of this Honorable
Court.
PRAYER
In the light of above-mentioned facts and
circumstances It is most respectfully prayed that this Hon’ble
Court ay graciously be pleased to pass an order as under:
a) To direct the respondent No. 1 & 2 to take legal action
against the proposed accused.
b) To direct the respondent No. 2 to lodge FIR against the
proposed accused.
c) To direct the respondents to give protection to the petitioner.
d) To direct the proposed accused persons not to cause any kind
of harassment to the petitioner and her family in any
manner.
e) Any other or further relief(s) which this Hon’ble Court may
deem property may be pleased grant.
Karachi
Dated:12-08-2024 ADVOCATE FOR THE PETITIONER
VERIFICATION
I, Muhammad Atif Siddique S/o Muhammad Siddiq, Muslim, Adult
residing at Karachi in the above matter do hereby solemnly affirm
and verify on oath that the contents of all the above paras including
prayer clauses are true and correct to the best of my knowledge and
belief.
Karachi
Dated: 12-08-2024 DEPONENT
ADVOCATE FOR THE PETITIONER
