IN THE COURT OF SESSIONS JUDGE TANDO ALLAHYAR
Cr. Misc. APPLICATION NO: of 2022
Sajjad Ali S/o Muhammad Bux,
Adult, Muslim by caste Rajput,
R/o. Shahbaz Colony,
Taluka and District Tando Allahyar…..………………….APPLICANT
VERSUS
1. SSP Complain Cell Tando Allahyar
2. S.H.O Police Station (A-Section)
3. Imran S/o Salam Udin
4. Danish S/o Salam Udin
5. Kashif S/o Salam Udin
6. Salam udin S/o Unknown
Respondent No 3 to 6, all
Adult Muslim, By Caste Arain,
R/o. Shahbaz Colony,
Taluka and District Tando Allahyar
…………..RESPONDENTS
APPLICATION U / S 22 A (6)(i) Cr. P. C
That the Applicant above named respectfully submits his
grievances as under;
1. That the Applicant above named is law abiding and peace
loving citizen of Pakistan having been endowed with
certain fundamental rights envisaged under the
constitution of Islamic Republic of Pakistan 1973.
2. That Applicant is the poor Labor, who earns bread by
working hard whole the day and whole the family of
applicant depends upon him.
3. That, the respondents No 3 to 6 are the high approached
persons and the said respondents are the neighbors of the
applicant.
4. That, few days before, a motor bike of respondent No.6
was Stolen from our neighborhood Shahbaz Colony, and
the respondent No. 06, without any proof alleged the said
offence on the Applicant.
5. That, the applicant is one of the poor person in his
neighbor, that’s why, the respondent No 3 to 6 use to
threat, harass and tease the applicant from time to time.
6. That, the applicant tried to explain his innocence before
the respondent No 3, but he listened nothing.
7. That, thereafter the respondent No.03 along with
respondent No 4 to 6, entered into the house of the
applicant, and started to beat applicant and his wife
hardly. And respondent No. 05 issued the threats of dire
consequences to the applicant and his family, and threated
to enter again in the house of the Applicant.
8. That, then applicant along with his sister approached the
Police station A-section, where the police lodged N.C of the
said incident, and kept the applicant and his sister whole
the night in the station.
9. That, the Respondent No.3 to 6 are high approached at
police station. And they had great influence over the police
station.
10. That, then thereafter applicant went to police station (A-
section) and file a complaint but no result came out.
11. That the Applicant is residing under the shadow of fear of
respondents No.3 to 6 as they have made the life of the
applicant miserable due to which the applicant is even
unable to spend a single day happy.
12. That the Applicant for redressal of his grievance and have
run from pillar to post but yet no protection was given to
them.
13. That the Applicant have serious apprehension that if any
prompt action is not taken at any time an unwanted
incident can take place that might destroy the life of
applicant and his family.
14. That the abovenamed Applicant have no any other
efficacious alternative remedy except to knock the door of
this Honorable Court.
15. That the cost of the application is saddled upon the
Applicant.
16. That the Applicant are residing within the jurisdiction of
P.S. (A-Section), Hence, this Honorable Court has got
jurisdiction to entertain the instant petition.
That the Applicant respectfully pray as under:-
PRAYER
a. That this Honorable court may be please to pass the
order to Respondent No.1 and 2 to provide Protection
the Applicant and his family.
b. That this Honorable Court may be please to pass the
order to the Respondent No.3 to 6 not to cause the
harassment to the applicant and his family.
c. That any other prayer may deem fits and proper may
also be granted.
Tando Allahyar
Dated Applicant
Advocate for Applicant
IN THE COURT OF SESSIONS JUDGE TANDO ALLAHYAR
Cr. Misc. APPLICATION NO: of 2022
Sajjad Ali………………….……………………..…………….….Applicant
VERSUS
S.S.P complain Cell & others…………..…………..…….Respondents
AFFIDAVIT
I,Sajjad Ali S/o Muhammad Bux, Adult, Muslim By Caste Jatoi, R/o.
Shahbaz Colony Tando Allahyar Taluka and District Tando
Allahyar, do here by oath as under:-
1. That I am applicant in the above matter, hence well
conversant with the facts of the case.
2. That the accompanying application U/S 2 2 –A (6)(i) Cr.
P.C, has been drafted under my instructions and contents
thereof are true and correct read and explained to me in
Urdu language.
3. That whatever stated above is true and correct to the best
of my knowledge and belief.
Tando Allahyar
DATED DEPONENT
The deponent is known to me and is identified by me to the
commissioner for taking affidavit.
ADVOCATE
Solemnly affirmation on oath this ----- day of August, 2022,
by the deponent above named who has been identified by
Mrs.Naheed Akhtar, Advocate to whom I know personally.
COMMISSIONER FOR TAKING AFFIDAVIT
The contents of this affidavit were truly audibly and legibly
explained in a language to which the deponent is well versed,
who appears to have understood the same perfectly put
signature in my presence.
COMMISSIONER FOR TAKING AFFIDAVIT
