1

IN THE LAHORE HIGH COURT RAWALPINDI BENCH

RAWALPINDI
CM No. _________/2019
In
Writ petition no. 2341 / 2019

In the matter of

Nouman Munawar

VERSUS

ASJ / Justice of Peace Rawalpindi and others

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC

REPUBLIC OF PAKISTAN READ WITH SECTION 22-A/B CRPC

APPLICATION U/S151 FOR ADDITION OF NECESASRY PARTIES

TO THE WRIT PETITION
Respectfully Sheweth:

1. That the above mentioned Writ is filed by the petitioner, the contents of

which may kindly be read as integral part of this petition.

2. That in the above mentioned writ petition, the petitioner has challenged the

order passed by Learned ASJ Rawalpindi vide order dated 24-07-2019 in

which the learned court dismissed the petition under section 22A/B Cr.P.C.

filed by the petitioner whereby, the SHO PS. Sadiqabad and Superintendent

of Police (Complaint Cell) Rawalpindi (Vide application / Diary No. SCC

3779) took no action and dismissed the application of the petitioner

/applicant.

3. That petitioner seeks to be allowed by this Honorable court to permit him to

add necessary parties, inter-alia on the following

GROUNDS
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i. That due to clerical mistake following accused person were not

made parties in the above titled writ petition.

1. Aqsa Saleem D/o Saleem Ullah r/o Pir Hamayun Colony

House # AD 24/B Street #14 Service Rd. Sadiqabad

Rawalpindi. (Hostel Warden, Girls Castle)

2. Abdullah Saleem s/o Saleem Ullah Pir Hamayun Colony

House # AD 24/B Street #14 Service Rd. Sadiqabad

Rawalpindi.

3. Majid s/o Unknown (Reportedly a relative / Friend of

Hostel Warden)

ii. That the petitioner and his sister were severely beaten by these

three person alongwith 3 x unknown person.

iii. That petitioner categorically mentioned these culprits in the

application alongwith their role in the occurance.

iv. That these individuals / culprits made a heinous crime for they

should be punished in accordance with law.

PRAYER

In view of the above, it is therefore, respectfully prayed that this petition may

kindly be accepted and following individuals may kindly be allowed to made

necessary party to the writ petition.

1. Aqsa Saleem D/o Saleem Ullah r/o Pir Hamayun Colony House # AD 24/B

Street #14 Service Rd. Sadiqabad Rawalpindi. (Hostel Warden, Girls Castle)

2. Abdullah Saleem s/o Saleem Ullah Pir Hamayun Colony House # AD 24/B

Street #14 Service Rd. Sadiqabad Rawalpindi.

3. Majid s/o Unknown (Reportedly a relative / Friend of Hostel Warden)

Petitioner
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THROUGH

(Imran Feroze Malik)

Advocate High Court,
Islamabad
CC No. 22257

Ibrahim Arshad Khan

Advocate High Court,
Islamabad

CERTIFICATE
As per information furnished by the petitioner this is the first petition on the
subject ever moved before this Hon’ble Court.

……COUNSEL
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IN THE LAHORE HIGH COURT RAWALPINDI BENCH

RAWALPINDI
Crl. Misc No. _________/2019
In
Writ petition no. 2341 / 2019

In the matter of
Nouman Munawar

VERSUS

ASJ / Justice of Peace Rawalpindi and others

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC

REPUBLIC OF PAKISTAN READ WITH SECTION 22-A/B CRPC

APPLICATION FOR ADDITION OF NECESASRY PARTIES TO THE WRIT

PETITION NO. 2341/2019
AFFIDAVIT
I, Nouman Munawar son of Muhammad Munawar Ameen Abbasi, Caste Abbasi,
r/o House No. 1, Ameen Manzil, Alen Gone Estate, Abu Dhabi Road, Motor
Agency, Murree, do hereby solemnly affirm and declare that the contents of the
accompanying are true to the best of my knowledge and belief and that nothing has
been kept concealed.

DEPONENT
Verification:
Verified on oath at Rawalpindi this ______ day of August 2019 that the contents of the
above affidavit are correct to the best of my knowledge and belief.

DEPONENT
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IN THE LAHORE HIGH COURT RAWALPINDI BENCH

RAWALPINDI
Crl. Misc No. _________/2019
In
Writ petition no. 2341 / 2019

In the matter of

Nouman Munawar

VERSUS

ASJ / Justice of Peace Rawalpindi and others

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC REPUBLIC OF

PAKISTAN READ WITH SECTION 22-A/B CRPC

APPLICATION FOR ADDITION OF NECESASRY PARTIES TO THE WRIT PETITION

NO.2341/2019

Ser. No. Particulars Annexures Page No.

1. Crl. Misc. Application alongwith Affidavit. 1-4

2. Copy of Application to SHO A 5-6

3. Copy of Application to SP Complaint Cell B 7-8

4. Wakalatnama

PETITIONER

Through

Imran Feroze Malik

Advocate High Court
Islamabad
CC#22257