BEFORE THE HONOURABLE SESSIONS JUDGE/ JUSTICE
OF PEACE, ISLAMBAD
_______________________________
Petitioner
VERSUS
SHO, Police Station Kohisar, Islamabad.
Respondent
PETITION U/S 22-A OF THE CR.P.C. FOR
REGISTRATION OF FIR
Respectfully Sheweth:-
1. That the accused _____________son of _____________was liable
to pay an amount of Rs. 23,40,000/-to the petitioner, the
detail whereof is mentioned in the Agreement dated 19-06-
2021. For the payment of above said amount, the accused
Saqlain Abbas issued two cheques (1) Cheque No.
000003000 amounting to Rs. 11,70,000/-, dated 19-09-
2021, the Bank of Punjab, Kuram Agency (2) Cheque No.
0000037652, amounting to Rs. 11,70,000/- dated 19-12-
2021, the Bank of Punjab, Kuram Agency to the petitioner.
2. That the petitioner presented the above said cheque No.
000003000 amounting to Rs. 11,70,000/-, dated 19-09-2021,
to Bank of Punjab, Kuram Agency in Bank of Punjab, F-7
Branch Islamabad but same was got dishnoured. (copy of
Cheque along with dishonour slip is annexed).
3. That after dishonouring the above said cheque, the
petitioner contacted the accused person and requested him
to pay the said amount but he started delaying the matter
and till today, he has not paid the said amount to the
petitioner.
4. That the petitioner reported the matter to respondent by
way of written application dated 13-10-2021, the concerned
police promised to lodge the FIR but till today the local
police has not registered an FIR on the application of
petitioner despite of the fact that the petitioner has visited
the police station for two days, hence this petition.
2
5. That the word “shall” has been employed in section 154 of
the Cr.P.C., which is mandatory in its operation and made it
obligatory on the local police to register the case, if any
cognizable offences has been made out.
6. That this court is competent under the law to direct the
respondent to register the case, if some obduracy,
reluctance has been shown proven or action of the
respondent is glaringly contrary to law.
PRAYER:
In the wake of above, it is, therefore, respectfully prayed that
the instant petition be accepted and respondent be directed to
register the FIR against the accused person Saqlain Abbas, on the
application already submitted by the petitioner, to meet the ends of
justice.
Petitioner
Through
_____________
Advocate High Court
CERTIFICATE
As per information received, it is certified that this is the first
petition on the subject matter being moved before this Honourable
Court.
Counsel