Académique Documents
Professionnel Documents
Culture Documents
MULTAN.
Abida Parween W/o Ansar Iqbal Caste Chohan R/o Chak No. 96/10-
R Tehsil Jahania District Khanewal.
Petitioner
Versus
1. S.H.O. P/S Jahania District Khanewal.
2. Muhammad Yasin
3. Haji Muhammad Saleem Sons of Nek Muhammad
4. Muhammad Amin
5. Muhammad Munir Sons of Muhammad Saleem.
All Caste Chohan R/o Chak No. 96/10-R Tehsil Jahania District
Khanewal.
Respondents
Respectfully Sheweth: -
1. That the names and address of the parties are given correct for
the purpose of service and citations.
2. That the petitioner was engaged with one Ansar Iqbal S/o
Sanauallah, a resident of the same Village 5/6 years before by the
respondent No. 2 to 5. It was grown up in the mind of the
petitioner that she would finally be married to the said person.
The respondent No. 3 negotiations for the marriage of another
sister of the petitioner, but the other party demanded the hands of
two sisters for their two sons. The petitioner remained taken
aback when the father of the petitioner acknowledged their
demand and offered the hand of the petitioner along with other
sister. Coming to know this fact, the petitioner became mentally
disturbed and also resisted and agitated upon the settlement of the
respondent No. 3. This agitation and resistance of the petitioner
of course could not bear fruit and being SUI JURIS, exercised
her right and contracted marriage with said Ansar Iqbal, to whom
the petitioner was initially engaged. Copy of “Nikah Nama” is
attached as Annexure “A”.
Dated: -6.12.99.
Abida Parween
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
Certificate: -
As per instructions of my client,
no identical Writ Petition has
already been filed in this
Hon’ble Court.
Advocate.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
W.P. No.____________/1999
AFFIDAVIT of:-
Abida Parween W/o Ansar Iqbal Caste Chohan R/o
Chak No. 96/10-R Tehsil Jahania District Khanewal.
DEPONENT
Verification: -
Verified on oath at Multan, this 6th day of
December, 1999 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Dispensation Application.
AFFIDAVIT of:-
Abida Parween W/o Ansar Iqbal Caste Chohan R/o
Chak No. 96/10-R Tehsil Jahania District Khanewal.
DEPONENT
Verification: -
Verified on oath at Multan, this 6th day of
December, 1999 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Respectfully Sheweth:-
That certified copies of Annexures A & B are not
available. However, uncertified/photo state copies of the
same have been annexed with the Petition, which are true
copies of original documents.
Petitioner
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
INDEX
Petitioner
Dated: -6.12.99.
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
W.P. No._________________/1999
Dispensation Application
Affidavit of: -
Malik Qadeer Uddin S/o Malik Shabbir Ahmad Caste
Khokhar, R/o Sughran Haveli Mall Godown Road,
Chowk Shaheedan, Multan.
_______________
Deponent
Verification: -
1. Muhammad Hanif
2. Abdul Khaliq, both sons of Haji Allah Wasaya Caste Sumra, R/o
Chak No. 22/M, Tehsil Kahror Pakka District Lodhran.
Versus
The State
Respectfully Sheweth: -
1. That it is the first petition for the subject cited relief. No such
application or any bail petition is filed before this Hon’ble Court
and any other Court.
2. That as per F.I.R the facts of case are that the complainant is
resident of Chak No. 22/M. On the day of occurrence at 8.30
A.M., he along with his two sons Mumtaz Ahmad, Sajjad Ahmad
and Muhammad Amin son Muhammad Bakhsh Caste Dhudi R/o
the same village were coming to their place of residence through
“Kaccha Road” leading Girls Primary school to Basant Pur
Miner. When they reached Bhani Lodhran Wali, situated in
Square No. 53 Qilla No. 1 on the road, suddenly Abdur-Razzaq
armed with gun 12 bores, Muhammad Siddique armed with 12
bores gun, Abdul Khaliq armed with hatchet, Hanif armed with
iron pipe, Abdul Majeed armed with pistol all sons of Allah
Wasaya Caste Sumra R/o 22/M appeared on Motor Cycles. Hanif
raised “Lalkara” addressing Mumtaz that today all you should be
taught lesson for asking the price of cotton as well as to insult the
brother Abdul Khaliq in today morning. On this, as well as
returned Abdur-Razzaq fired straight which landed on the left
side of chest of my son Sajjad. Muhammad Siddique too fired
with his 12 bore gun which hit on the upper part of arm. We
resiled with fear. Muhammad Sajjad son fell in injured condition
on the ground. On our noise, many people gathered, but on the
threats of Abdul Khaliq, Muhammad Hanif and Majeed no one
could help us. All the accused persons fled away on their motor
cycles along with their respective weapons. My son Muhammad
Sajjad scumed too injuries after some time on the spot. The
motive behind this occurrence is my son Mumtaz early in the
morning tried to settle the rate of cotton and price of 118 monds
cotton on which there was an altercation, in which Mumtaz
slapped Hanif. On this grievance, all these accused persons in
consultation with each other inflicted firearm injuries to my son
Sajjad which resulted his death. I left Mumtaz Ahmad son and
Muhammad Amin Dhudi along with the dead body reported the
matter. Copy of F.I.R is annexed as Annexure “A” and better
copy is annexed as “A/1”.
3. That the petitioners are entitled for the concession of pre-arrest
bail in the shape of protective bail on the following
GROUNDS
a. That the F.I.R is a concocted story which is registered
with the malafide consultation and assistance of the
Police.
b. That the petitioners are innocent and involved in this
case falsely.
c. That the petitioners have not inflicted any injury to the
deceased as per bare reading of F.I.R.
d. That actually Mumtaz the real brother of deceased
Sajjad along with other two committed robbery and
extorted Rs. 100,000/- from the petitioner No. 2. When
Mumtaz and his accomplices chased by the petitioner
No. 2 and his two brothers Mumtaz and Sajjad along
with others from one side and Rafiq, Siddique both by
Caste Dhudi started firing upon the petitioner No. 2 and
brothers. In this cross firing Sajjad received fires from
the guns of Rafiq and Siddique. This matter was also
reported to the Police, but they did not bother to take
any action.
e. That the Police in league with complainant party under
the malafide and ulterior motive are causing harassment
and humiliation to the petitioners. The Police,
complainant party and Police officials surrounded and
guarded the Sessions Court in such a way that the
petitioners cannot approach to avail the right of pre-
arrest bail.
f. That aggrieved by the conduct of complainant
party/Police, the petitioners are forced to file this
petition before this Hon’ble Court for the grant of
protective bail, to approach the proper forum.
It is therefore, humbly prayed that the
petitioners may please be granted pre-arrest bail
in the shape of protective bail, enable the
petitioners to approach the proper forum.
Any other relief which this Hon’ble Court
deems fit may please be extended in favour of the
petitioners.
Humbly Petitioners
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Crl. Misc. No.____________/B/2000
INDEX
PETITIONER
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
Respectfully Sheweth:-
That certified copy of Annexure “A” is not available.
However, uncertified/photo state copy of the same has been
annexed with the Petition, which is true copy of original
document.
Petitioners
Dated: 25.01.2000
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
AFFIDAVIT of: -
Muhammad Hanif son of Haji Allah Wasaya Caste
Sumra, R/o Chak No. 22/M, Tehsil Kahror Pakka
District Lodhran.
DEPONENT
Verification: -
Verified on oath at Multan, this _____day
of January 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
Dispensation Application.
AFFIDAVIT of: -
Muhammad Hanif son of Haji Allah Wasaya Caste
Sumra, R/o Chak No. 22/M, Tehsil Kahror Pakka
District Lodhran.
DEPONENT
Verification: -
Verified on oath at Multan, this _____day
of January 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
Respectfully Sheweth: -
1. That the names and addresses of the parties are given
correct for the purpose of service of the parties and
citations.
GROUNDS
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Crl. Appeal No.____________/2000
INDEX
APPELLANT
Dated: .2.2000
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
C.C. No. 20176.
AFFIDAVIT of: -
Rana Ghulam Mahboob Subhan S/o Rana Ghulam
Gilani, Caste Rajput, R/o Kameer Town, Tehsil &
District Sahiwal.
DEPONENT
Verification: -
Verified on oath at Multan, this _____day
of February 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
Respectfully Sheweth: -
1. That the names and addresses of the parties are given correct
for the purpose of service of the parties and citations.
2. That the facts of the case as mentioned in the F.I.R are that
Fazl-ur-Rehman complained/made statement before the Police
that he has a shop of children school bag in Safdar Market.
His son Irfan Ahmad aged 12 years was student of fifth (5th)
class. On 11.6.96 at 4.30 p.m. Irfan Ahmad went to tuition
from Muhammad Ashraf. At that time, Irfan Ahmad was
wearing grey pent, white shirt and Banyan and light green
chappal in his feet. When Irfan Ahmad did not come back
home then he went to the house of Master Muhammad Ashraf.
He came to know that Master Muhammad Ashraf was not
present in his house. He continued to search for his son Irfan
Ahmad but he found no clue. On 12.9.96 he lodged report No.
13 at P.S. Qutab Pur for missing of his son Irfan Ahmad so
that publicity in T.V and Newspapers, etc. could be made. He
had been receiving telephonic calls on his telephone in which
the caller demanded ransom of Rs. 50,000/- for return of his
son Irfan Ahmad. Then he arranged for an observation on his
telephone No. 582130. After installation of observation,
messages were received form different telephone numbers but
be had been contacted the said telephone numbers but nothing
about Irfan Ahmad could be found. During search Zamir
Abbas S/o Afzal Caste Syed R/o Abuturab Colony and Akbar
Khan S/o Charagh Khan Caste Pathan R/o Chowk Shaheedan,
Mohallah Fareedabad told the complainant two days before
the registration of case that Nadeem Mustafa S/o Ghulam
Mustafa Caste Arain armed with pistol and Shakeel Ahmad
S/o Saeed Ahmad Caste Qureshi were taking Irfan Ahmad on
Motor Cycle when Irfan Ahmad was sitting between both of
them. Shakeel Ahmad was driving the motorcycle and
Nadeem Mustafa was sitting behind Irfan Ahmad. Both of the
above said PW’s had gone out for their work and on return,
they had come to know about the abduction of Irfan Ahmad.
On this information, he along with Nazir Ahmad &
Muhammad Latif inquired from Nadeem Mustafa and Shakeel
Ahmad accused about Irfan Ahmad. After some hesitation,
they told that they had left Irfan Ahmad at about 6 p.m. Irfan
Ahmad has not been found despite great struggle. Accused
had abducted Irfan Ahmad for ransom and had concealed him
somewhere or had murdered him. In this respect, he has got
proofs with him. Hence this case.
3. That the accused were arrested and challaned. At first
instance, the challan of the case was submitted in the Special
Court for Suppression of Terrorist Activities, Multan. As the
case was not one, falling within the jurisdiction of Special
Court as per Schedule, so the same was returned and
thereafter submitted to the Sessions Judge, Multan.
GROUNDS
j. That the PW’s 7 & 8 are the witnesses for the extra
judicial confession. They along with the PW’s 4 & 5
unanimously admitted that it was the joint confessional
statement of the accused persons before all of them.
iii. Recoveries.
Except the last-worn clothes and bones no
recovery alleged to be made on the pointation of
the appellants. As well as the bones are
concerned the evidence of PW1 in this regard,
based upon the presumptions and assessments.
Also, no age of bones is given along with the
time between the death and recoveries. It is
pertinent to point out that the recoveries were
effected by the Police as per record on 21.10.96,
while the appellants were taken into custody by
the Police on 26.10.96. keeping in view this
situation, the appellants could not be connected
with these recoveries.
Dated: .2.2000.
Through: -
1. Ch. Muhammad Akram Waqar,
Advocate High Court,
District Courts, Vehari.
Certificate: -
As per instructions of my client,
no such appeal was filed earlier
in this Hon’ble Court.
Advocate.
AFFIDAVIT of: -
Muhammad Nadeem Mustafa S/o Ghulam Mustafa,
Caste Arain, R/o Gali No. 2 Madina Town, Old
Shujabad Road, Multan.
DEPONENT
Verification: -
Verified on oath at Multan, this _____day
of February 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT
INDEX
APPELLANT
Dated: .2.2000
Through: -
1. Ch. Muhammad Akram Waqar,
Advocate High Court,
District Courts, Vehari.
1. Zaffar Hussain.
2. Ijaz Hussain.
3. Shabbir Hussain all sons of Muhammad Bakhsh, caste Bhatti,
r/o Chak No. 103/15-L Tehsil Mian Channun District
Khanewal.
4. Allah Ditta s/o Sikandar, caste Sipra, r/o 104/15-L Tehsil
Mian Channun District Khanewal.
Petitioners
Versus
The State………………… Respondent
Respectfully Sheweth: -
1. That names and addresses of the parties with other relevant
particulars of case are stated correct for the service and
citations.
3. That all the accused persons applied for pre-arrest bail before
the learned Additional Session Judge, Mian Channun. The
request of the petitioners was turned down vide order dated
20.3.2000. They copy of the bail application along with order
is annexed as Annexure “B”.
4. That the petitioners are entitled for pre-arrest bail inter alia on
the following
GROUNDS
Humble Petitioners
AFFIDAVIT of: -
Zaffar Hussain son of Muhammad Bakhsh, caste Bhatti,
r/o Chak No. 103/15-L Tehsil Mian Channun District
Khanewal.
DEPONENT
Verification: -
Verified on oath at Multan, this ____day of
March 2000 that the contents of this affidavit are true
to the best of my knowledge and belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Respectfully Sheweth: -
That certified copies of Annexures “A to G” are not
available. However, uncertified/photo state copies of the
same have been annexed with the Petition, which are true
copies of original documents.
Dated: _________
Dispensation Application
Affidavit of: -
Zaffar Hussain son of Muhammad Bakhsh, caste Bhatti,
r/o Chak No. 103/15-L Tehsil Mian Channun District
Khanewal.
DEPONENT
Verification: -
Verified on oath at Multan, this _____ day
of March 2000 that the contents of this affidavit
are true to the best of my knowledge and belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
INDEX
RESPECTFULLY SHEWETH: -
1. That the rent appeal at S-1/NO. 1 came up against the order of Rent
Controller Multan Cantonment dated 31.3.1983. During the proceedings
of this appeal, all the parties mentioned in above mentioned 3 cases
agreed on 8.12.1983 to decide all these cases through ARBITRATION.
Sheikh Anwar-ul-Haq the Hon’ble Ex-chief Justice Supreme Court of
Pakistan was appointed as SOLE ARBITRATOR. All the 3 matters were
referred to the Arbitrator vide letter No. 1003/A h 1 (Civil) dated
21.2.83.
2. That on 14.5.1986 the award was announced and was received in this
Hon’ble Court on 19.5.1986. Along with other matters as per para No. 5
of award amount Rs. 815,167/- had to be deposited by two parties and
had to be divided between three parties. The contents of para No. 5 of
award are as under: -
Para No. 5.
(i) Sheikh Imdad Ahmad shall pay Rs. 679,084/-
(ii) Sheikh Sarfraz Ahmad shall pay Rs. 136,083/-
Total: Rs. 815,167/-
The above amount of Rs. 815,167/- will be divided to the following
persons: -
(i) Sheikh Maqbool Ahmad Rs. 495,917/-
(ii) Mst. Shabeeran Rs. 159,625/-
(iii) Mst. Akhtari Begum Rs. 159,625/-
The payments as above were directed to be made
within one month from the date of award (14.5.1986).
5. That the objections filed by Sheikh Sarfraz Ahmad against the award
were turned down by this Hon’ble Court and the award dated 14.5.86
was made RULE OF COURT vide Judgment and decree dated 18.4.92.
This order was assailed in the Hon’ble High Court, Multan bench
through: -
(i) RFA No. 43/1992 Sheikh Sarfraz Ahmad Vs. Balqees Begum etc.
(ii) RFA No. 54/1992 Sheikh Sarfraz Ahmad Vs. Balqees Begum etc.
(iii) RFA No. 55/1992 Sheikh Sarfraz Ahmad Vs. Sh. Imdad Ahmad
etc.
(iv) RFA No. 67/92 Sh. Muhammad Muslim Vs. Sh. Imdad Ahmad
etc.
(v) RFA No. 73/1992 Mst. Nusrat Tasleem Vs. Sh. Imdad Ahmad
etc.
(vi) RFA No. 74/92 Sh. Muhammad Saleem Vs. Sh. Imdad Ahmad
etc.
6. That during the litigation Sheikh Imdad Ahmad late (father) and Mst.
Balqees Begum (mother) of applicants died and the successors/
applicants impleaded as party in the titled matter. However, the
succession certificates were also obtained in this regard and annexed
herewith also.
Any other relief which this Hon’ble Court deems fit may
please be granted to the applicants.
Humble Applicants
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
IN THE COURT OF DISTRICT JUDGE, MULTAN.
RESPECTFULLY SHEWETH: -
1. That the rent appeal at S-1/NO. 1 came up against the order of Rent
Controller Multan Cantonment dated 31.3.1983. During the proceedings
of this appeal, all the parties mentioned in above mentioned 3 cases
agreed on 8.12.1983 to decide all these cases through ARBITRATION.
Sheikh Anwar-ul-Haq the Hon’ble Ex-Chief Justice Supreme Court of
Pakistan was appointed as SOLE ARBITRATOR. All the 3 matters were
referred to the Arbitrator vide letter No. 1003/Ah1 (Civil) dated 21.2.83.
2. That on 14.5.1986 the award was announced and was received in this
Hon’ble Court on 19.5.1986. Along with other matters as per para No. 5
of award amount Rs. 815,167/- had to be deposited by two parties and
had to be divided between three parties. The contents of para No. 5 of
award are as under: -
Para No. 5.
(i) Sheikh Imdad Ahmad shall pay Rs. 679,084/-
(ii) Sheikh Sarfraz Ahmad shall pay Rs. 136,083 /-
Total: Rs. 815,167/-
The above amount of Rs. 815,167/- will be divided to the following
persons: -
4. That objections filed by Sheikh Sarfraz Ahmad upon award were turned
down by this Hon’ble Court and the award dated 14.5.86 was made rule
of Court vide Judgment and Decree dated 18.4.92. This order was
assailed in the Hon’ble High Court, Multan Bench through: -
(i) RFA No. 43/1992 Sheikh Sarfraz Ahmad Vs. Balqees Begum etc.
(ii) RFA No. 54/1992 Sheikh Sarfraz Ahmad Vs. Balqees Begum etc.
(iii) RFA No. 55/1992 Sheikh Sarfraz Ahmad Vs. Sh. Imdad Ahmad
etc.
(iv) RFA No. 67/92 Sh. Muhammad Muslim Vs. Sh. Imdad Ahmad
etc.
(v) RFA No. 73/1992 Mst. Nusrat Tasleem Vs. Sh. Imdad Ahmad
etc.
(vi) RFA No. 74/92 Sh. Muhammad Saleem Vs. Sh. Imdad Ahmad
etc.
6. That the parties are residing at different places, and for their
convenience, the applicants are ready to deposit the amount in shape of
D.D./Pay order as per their share, which could be dispatched on the
expenses of applicants, to the entitled persons or under any other terms
as directed by this Hon’ble Court. A diagram of entitled person is
annexed herewith.
Humble Applicants
Dated: ___________
Through: -
Sh. Muhammad Faheem,
Advocate High Court,
28-District Courts,
Multan.
IN THE COURT OF DISTRICT JUDGE, MULTAN.
AFFIDAVIT of: -
Sheikh Afzaal Ahmad son of Sh. Imdad Ahmad, caste
Sheikh, c/o Al-Hamad Textile Mills Tipu Sultan Road,
Multan.
AFFIDAVIT of: -
Sheikh Sarfraz Ahmad son of Sh. Muahammad Shafi, caste
Sheikh, resident of 105/106 Bohra Road, Multan Cantt.
VERIFICATION: -
Verified on oath that the contents of this
affidavit are true and correct to the best of my knowledge
and belief.
DEPONENT
Sh. Imdad Ahmad Rs. 679,084/- + 136.083/- Sh. Sarfraz Ahmad
Shall be divided
Sh. Maqbool Ahmad (alive) Muhammad Muslim husband of Mst. Shabiran (died)
Rs. 495,917/- Rs. 39,906.25 Rs. 159,625/-
M. Waseem M. Saleem M. Azeem M. Naeem M. Tasleem Nusrat Tasleem Sadaqt Khan Nuzhat Nighat Musarrat Rifaat
Rs. 15,962.50 Rs. 1995.31 (daughter) Rs. 7981.25
REPLY
Respectfully Sheweth: -
1. That the para No. 1 of this application is admitted as correct.
2. That the para No. 2 of this application is admitted as correct.
3. That the para No. 3 of this application is admitted as correct.
4. That the para No. 4 of this application is admitted as correct.
5. That the para No. 5 of this application is admitted as correct.
6. That the respondent (s) has/have no objection if Demand Draft/Pay
order as per entitlement may please be delivered/despatched as the
given address.
It is therefore, prayed that there is no objection, if the
application is accepted as prayed.
Humble Respondent
Through: -
IN THE COURT OF DISTRICT JUDGE, MULTAN.
REPLY
Respectfully Sheweth: -
1. That the para No. 1 of this application is admitted as correct.
2. That the para No. 2 of this application is admitted as correct.
3. That the para No. 3 of this application is admitted as correct.
4. That the para No. 4 of this application is admitted as correct.
5. That the para No. 5 of this application is admitted as correct.
6. That the para No. 6 of this application is admitted as correct.
It is therefore, prayed that the application may please be
accepted as prayed and the certificates may please be released
in favour of applicants/attorney.
Humble Respondent
Through: -
To,
The Deputy Commissioner,
Faisalabad.
Sir,
The above subject case was conducted by me in the Court of Judge,
Suppression of Terrorist Activities, (Special Courts) 1975,
Faisalabald. The learned judge acquitted the accused persons and the
case is fit for appeal against acquittal. Draft of appeal is attached
herewith (in Triplicate). It is humbly requested that the same may
please be forwarded to worthy Advocate General, PUNJAB, Lahore
for filing the same in the competent Courts.