IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rahat Masood Khan S/o Nasrullah Khan, caste Afghan Pathan, R/o
Mohallah Jandi Whra, O/s Pak Gate, Multan.
……Applicant
VERSUS
1. State.
2. S.H.O. P.S. Pak Gate, Multan.
……Respondents

Application U/s 22-A, 22-B Cr.P.C.

restraining the respondent No. 2
from causing any illegal/unlawful
harassment to the petitioner, his
family members and relatives.

Respectfully Sheweth: -

1. That the applicant is an employee of Khan Bus Service

serving his company from 8:00 A.M. till 10:00 P.M. There is
only wife of the applicant to look after the children at the
home of the applicant. The applicant has two daughters and
one son and all are school going.

2. That an unfortunate incident took place in the area of P.S. Pak

Gate on the midnight of 11.6.03 and 12.6.03 in which a boy
was murdered while a lady was injured as well. A case U/s
302/324/34 P.P.C. was registered in which one person Umar
Ali was nominated who was seen by the witnesses standing in
the street while the actual culprits fled away after the
occurrence. This Umar Ali happened to be the nephew of the
applicant’s wife. Copy of F.I.R. is Annex “A”.
3. That the said Umar Ali is absconding from the date of
occurrence and nobody including myself knows the
whereabouts of that Umar Ali. The respondent No. 2 instead
of searching the Umar Ali, is pressurising the applicant, other
relatives and family members of the applicant for his
production, while on the other side, nobody knows about the
whereabouts of the said Umar Ali or having any information
or connection at present with him.

4. That the respondent No. 2 is raiding the house of the

applicant and calling the applicant time to time at P.S., in lieu
of the arrest of the said Umar Ali, which is permanent cause
of harassment to the applicant and the act of the respondent
No. 2 is unwarranted under the law.

5. That the applicant, his family and relatives are fully protected
under the constitution and the respondent No. 2 has no
authority to transgress of his authority, as well as to harm the
decency of family life of the applicant.

6. That the petitioner is left with no other efficacious, speedy,

adequate and proper remedy except to invoke the jurisdiction
of this Hon’ble Court. Hence, this application.

It is, therefore, respectfully prayed that the

respondent No. 2 may please be restrained to cause any
type of illegal and unlawful harassment to applicant,
his family members and his relatives by any means.

Any other relief, which this Hon’ble Court

deems fit, may please be extended for the sake of
justice.
Humble Applicant,
Dated: ________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
 IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rahat Masood Khan VS. State etc.

Application U/s 22-A, 22-B Cr.P.C.

AFFIDAVIT of: -
Rahat Masood Khan S/o Nasrullah Khan, caste Afghan
Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan.

I, the above-named deponent do hereby solemnly

affirm and declare as under: -

1. That the applicant is an employee of Khan Bus Service

serving his company from 8:00 A.M. till 10:00 P.M. There is
only wife of the applicant to look after the children at the
home of the applicant. The applicant has two daughters and
one son and all are school going.

2. That an unfortunate incident took place in the area of P.S. Pak

Gate on the midnight of 11.6.03 and 12.6.03 in which a boy
was murdered while a lady was injured as well. A case U/s
302/324/34 P.P.C. was registered in which one person Umar
Ali was nominated who was seen by the witnesses standing in
the street while the actual culprits fled away after the
occurrence. This Umar Ali happened to be the nephew of the
applicant’s wife. Copy of F.I.R. is Annex “A”.

3. That the said Umar Ali is absconding from the date of

occurrence and nobody including myself knows the
whereabouts of that Umar Ali. The respondent No. 2 instead
of searching the Umar Ali, is pressurising the applicant, other
 relatives and family members of the applicant for his
production, while on the other side, nobody knows about the
whereabouts of the said Umar Ali or having any information
or connection at present with him.

4. That the respondent No. 2 is raiding the house of the

applicant and calling the applicant time to time at P.S., in lieu
of the arrest of the said Umar Ali, which is permanent cause
of harassment to the applicant and the act of the respondent
No. 2 is unwarranted under the law.

5. That the applicant, his family and relatives are fully protected
under the constitution and the respondent No. 2 has no
authority to transgress of his authority, as well as to harm the
decency of family life of the applicant.

6. That the petitioner is left with no other efficacious, speedy,

adequate and proper remedy except to invoke the jurisdiction
of this Hon’ble Court. Hence, this application.

7. That all the contents of the above-titled application are true

and correct to the best of my knowledge and belief. Nothing
has been kept concealed thereto.

DEPONENT

Verification: -

Verified on oath at Multan this _____ day of June, 2003 that

all the contents of this affidavit are true and correct to the best of my
knowledge and belief. Nothing has been kept concealed thereto.

DEPONENT
 IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rashida Begum widow of Muhammad Anwar Khan, caste Mughal

Pathan, R/o Mohallah Jandi Whra, O/s Pak Gate, Multan.
……Applicant
VERSUS
1. State.
2. S.H.O. P.S. Pak Gate, Multan.
……Respondents

Application U/s 22-A, 22-B Cr.P.C.

restraining the respondent No. 2
from causing any illegal/unlawful
harassment to the petitioner, his
family members and relatives.

Respectfully Sheweth: -

1. That the applicant is a widow having four sons and one

daughter. The three sons are doing their own business while
one son is running a computer institute. The only daughter is
a university student. There are some female relatives living as
family members with the applicant due to some domestic
problems.

2. That an unfortunate incident took place in the area of P.S. Pak

Gate on the midnight of 11.6.03 and 12.6.03 in which a boy
was murdered while a lady was injured as well. A case U/s
302/324/34 P.P.C. was registered in which one person Umar
Ali was nominated who was seen by the witnesses standing in
the street while the actual culprits fled away after the
 occurrence. This Umar Ali is one of the applicant’s sons.
Copy of F.I.R. is Annex “A”.

3. That the said Umar Ali is absconding from the date of

occurrence and nobody including myself knows the
whereabouts of that Umar Ali. The respondent No. 2 instead
of searching the Umar Ali, is pressurising the applicant, other
relatives and family members of the applicant for his
production, while on the other side, nobody knows about the
whereabouts of the said Umar Ali or having any information
or connection at present with him.

4. That the respondent No. 2 is raiding the house of the

applicant and calling the applicant and her sons time to time
at P.S., in lieu of the arrest of the said Umar Ali, which is
permanent cause of harassment to the applicant and the act of
the respondent No. 2 is unwarranted under the law. It is
assured to the respondent No. 2, as and when the Umar Ali
will come to the home or his whereabouts shall be known to
the applicant, the same shall be furnished to the respondent
No. 2, but the respondent No. 2 is giving a deaf ear to this
proposition of applicant.

5. That the applicant, his family and relatives are fully protected
under the constitution and the respondent No. 2 has no
authority to transgress of his authority, as well as to harm the
decency of family life of the applicant.

6. That the petitioner is left with no other efficacious, speedy,

adequate and proper remedy except to invoke the jurisdiction
of this Hon’ble Court. Hence, this application.

It is, therefore, respectfully prayed that the

respondent No. 2 may please be restrained to cause any
type of illegal and unlawful harassment to applicant,
his family members and his relatives by any means.
 Any other relief, which this Hon’ble Court
deems fit, may please be extended for the sake of
justice.
Humble Applicant,
Dated: ________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
 IN THE COURT OF SESSIONS JUDGE, MULTAN.

Rashida Begum VS. State etc.

Application U/s 22-A, 22-B Cr.P.C.

AFFIDAVIT of: -
Rashida Begum widow of Muhammad Anwar Khan,
caste Mughal Pathan, R/o Mohallah Jandi Whra, O/s
Pak Gate, Multan.

I, the above-named deponent do hereby solemnly

affirm and declare as under: -

1. That the applicant is a widow having four sons and one

daughter. The three sons are doing their own business while
one son is running a computer institute. The only daughter is
a university student. There are some female relatives living as
family members with the applicant due to some domestic
problems.

2. That an unfortunate incident took place in the area of P.S. Pak

Gate on the midnight of 11.6.03 and 12.6.03 in which a boy
was murdered while a lady was injured as well. A case U/s
302/324/34 P.P.C. was registered in which one person Umar
Ali was nominated who was seen by the witnesses standing in
the street while the actual culprits fled away after the
occurrence. This Umar Ali is one of the applicant’s sons.
Copy of F.I.R. is Annex “A”.

3. That the said Umar Ali is absconding from the date of

occurrence and nobody including myself knows the
whereabouts of that Umar Ali. The respondent No. 2 instead
 of searching the Umar Ali, is pressurising the applicant, other
relatives and family members of the applicant for his
production, while on the other side, nobody knows about the
whereabouts of the said Umar Ali or having any information
or connection at present with him.

4. That the respondent No. 2 is raiding the house of the

applicant and calling the applicant and her sons time to time
at P.S., in lieu of the arrest of the said Umar Ali, which is
permanent cause of harassment to the applicant and the act of
the respondent No. 2 is unwarranted under the law. It is
assured to the respondent No. 2, as and when the Umar Ali
will come to the home or his whereabouts shall be known to
the applicant, the same shall be furnished to the respondent
No. 2, but the respondent No. 2 is giving a deaf ear to this
proposition of applicant.

5. That the applicant, his family and relatives are fully protected
under the constitution and the respondent No. 2 has no
authority to transgress of his authority, as well as to harm the
decency of family life of the applicant.

6. That the petitioner is left with no other efficacious, speedy,

adequate and proper remedy except to invoke the jurisdiction
of this Hon’ble Court. Hence, this application.

7. That all the contents of the above-titled application are true

and correct to the best of my knowledge and belief. Nothing
has been kept concealed thereto.

DEPONENT

Verification: -

Verified on oath at Multan this _____ day of June, 2003 that

all the contents of this affidavit are true and correct to the best of my
knowledge and belief. Nothing has been kept concealed thereto.

DEPONENT