IN THE COURT
OF SESSION JUDGE LAHORE.
Muhammad Saeed son of Mukhtar
Ahmed Caste Qazi Resident of Begum Kot Shama Colony Sharaq Pur Road lahore.
(petitioner)
Versus
1.
SHO police Station Shahdara lahore.
2.
Incharge chowki Muhammad Shafique sub inspector police
Station Shahdara lahore,
and 6/7 other police officials.
3.
Sheikh Sardar son
of not known Resident of Nashtar colony
Street No
1 lahore.
4.
The State .
(Respondents)
APPLICATION
U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA AGED ABOUT 2 YEARS OLD
FROM THE ILLEGAL AND IMPROPER CUSTODY OF THE RESPONDENT NO 3.
MAY
IT PLEASE YOUR HONOUR,
1.
That the
abrigdely contents of this application are that the petitioner is a law abiding
citizen of Pakistan and has very good antecedent in his credit
, and very popular in his community.
2.
That the
petitioner was married with the daughter of the respondent No 3 according to
Muslim rites and in the presence of the witnesses in the year of 2007 and due
to this wedlock one female baby detneu was born .
3.
That it is
pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was
abnormal and the patient of Epilepti form
by birth and the respondent No 3 with malafide intention and ulterior
motive married her with the petitioner.
4.
That on the first
day of the marriage the petitioner came to know regarding the illness of the
Mst Nargis bibi , but due to the fear of Allah the
petitioner accept her with all her illness , and began to her treatment .
5.
That the mental
and physical health conditions of the wife of the petitioner became down day by
day and at least the respondent No 3 took back her daughter from the house of
the petitioner for further treatment about one month ago ,
while the minor Mst Zahra remained in the house of the petitioner, while the
petitioner and his sisters were looking after the minor .
6.
That on 15-05-11 at about
4/5 pm when the petitioner was present at his home at once respondents No 2
with the active convenience of the respondent No3 forcibly entered in the house
of the petitioner and forcibly snatched the minor Mst Zahra from the legal
custody of the petitioner and handed over to the respondent No 3 and fled away
from the spot.
7.
That being
aggrieved the petitioner at once approached the respondent No 1 and told him
the whole story about the kidnap of the daughter of the petitioner, but the
respondent No 1 did not pay any attention to this fact and kicked out the
petitioner from the police stations.
8.
That petitioner
has no other speedy and educate remedy except to invoke the jurisdiction of
this honourable court for the recovery of her minor daughter from the illegal
and improper custody of the respondent No 3, hence this petition.
Prayer
It is therefore respectfully prayed that the petition
of the petitioner may kindly be accepted and request for depute a bailiff of this honourable
court for the recovery of minor daughter of the petitioner from the illegal and
improper custody of the respondent No 3 and oblige.
Petitioner.
Through :
16-05-11
Mian Abdul Jabbar Khan
Sample
Affidavit
IN THE COURT
OF SESSION JUDGE LAHORE.
Muhammad Saeed son of Mukhtar
Ahmed Caste Qazi Resident of Begum Kot Shama Colony Sharaq Pur Road lahore.
(petitioner)
Versus
1.
SHO police Station Shahdara lahore.
2.
Incharge chowki Muhammad Shafique sub inspector police
Station Shahdara lahore,
and 6/7 other police officials.
5.
Sheikh Sardar son
of not known Resident of Nashtar colony
Street No
1 lahore.
6.
The State .
(Respondents)
APPLICATION
U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA AGED ABOUT 2 YEARS OLD
FROM THE ILLEGAL AND IMPROPER CUSTODY OF THE RESPONDENT NO 3.
MAY
IT PLEASE YOUR HONOUR,
Affidavite of Muhammad Saeed son
of Mukhtar Ahmed
Caste Qazi Resident of Begum Kot
Shama Colony Sharaq
Pur Road lahore do hereby
solemnly affirm as under,
9.
That the
abrigdely contents of this application are that the petitioner is a law abiding
citizen of Pakistan and has very good antecedent in his credit
, and very popular in his community.
10.
That the
petitioner was married with the daughter of the respondent No 3 according to
Muslim rites and in the presence of the witnesses in the year of 2007 and due
to this wedlock one female baby detneu was born .
11.
That it is
pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was
abnormal and the patient of Epilepti form
by birth and the respondent No 3 with malafide intention and ulterior
motive married her with the petitioner.
12.
That on the first
day of the marriage the petitioner came to know regarding the illness of the
Mst Nargis bibi , but due to the fear of Allah the
petitioner accept her with all her illness , and began to her treatment .
13.
That the mental
and physical health conditions of the wife of the petitioner became down day by
day and at least the respondent No 3 took back her daughter from the house of
the petitioner for further treatment about one month ago ,
while the minor Mst Zahra remained in the house of the petitioner, while the
petitioner and his sisters were looking after the minor .
14.
That on 15-05-11 at about
4/5 pm when the petitioner was present at his home at once respondents No 2
with the active convenience of the respondent No3 forcibly entered in the house
of the petitioner and forcibly snatched the minor Mst Zahra from the legal
custody of the petitioner and handed over to the respondent No 3 and fled away
from the spot.
15.
That being
aggrieved the petitioner at once approached the respondent No 1 and told him
the whole story about the kidnap of the daughter of the petitioner, but the
respondent No 1 did not pay any attention to this fact and kicked out the
petitioner from the police stations.
16.
That petitioner
has no other speedy and educate remedy except to invoke the jurisdiction of
this honourable court for the recovery of her minor daughter from the illegal
and improper custody of the respondent No 3, hence this petition.
Deponent
Vereification
: -
Verified on oath at Lahore On
16-05-11 that the contents of the said petition are correct to the best of my
knowledge and belief.
Deponent