BEFORE THE LEARNED DISTRICT AND SESSIONS JUDGE

LAHORE

No. /2020

Muhammad umer s/o Muhammad Farooq r/o 559 bahria

homes, bahria town Lahore.

Applicant
VERSUS

1.S.H.O police station sundar Lahore.

Respondent

Application U/S 22-A AND 22-B OF CRPC

Respectfully Sheweth:

i. That brief facts necessitating to the

filing of this instant petition are

that applicant is a law abiding

citizen and do business for his

living.

ii. That the petitioner is doing

construction of his own house in

bahria overseas block B and engaged

pak watan security company located in

64-K commercial phase 1 ghazi road

Lahore for hiring of security guards

for security of his house and

 construction material used in

construction.

iii. The manger pak watan security company

ahamad sultan take full guarantee of

the security guard namely fakhar abbas

s/o Ghulam haider CNIC no 36103-

408892-7 sent him for the security of

the particular house and construction

material.

iv. That the petitioner on 14.04.2021 take

the material consisting AC fitting

copper wire 600 ft costing Rs 3,25,000

and electric wiring of different sizes

costing Rs 4,00,000 and placed it in

the store room and make video of the

material placed in store of his house

and locked the store room and hand

over the keys to the security guard

fakhar abbas.

v. When the petitioner visited the house

for further construction on the very

next day he found out that the

security guard fakhar abbas stole the

construction material and ran away and

left his gun of 12 bor serial no 11333

to the house of the petitioner.

Petitioner was fully assured that

 fakhar abbas stole the construction

material with electrician hafiz usman

because when petitioner asked hafiz

usman he refused and left the

remaining work.

vi. That the petitioner is the only

witness of this criminal act and his

personal guard Muhammad shahbaz which

the petitioner hired from the same pak

watan security company.

vii. When the petitioner went to the

manager ahmad sultan for his event the

manger gave him false consolations

about the recovery of his material and

the registration of criminal case in

the P.S sundar.

viii. That after repeated requests of the

petitioner the manager ahmad sultan

told the petitioner on 01.06.2021 that

the application in the court of hafiz

rizwan aziz dated 21.05.2021 is being

dismissed.

ix. When the petitioner got the

photocopies of the order and got

shocked because of the fabricated

application of the event was submitted

to the police station. For the safety

 of their company and the security

guard they changed the event and make

Muhammad safdar s/o riaz the security

guard of the petitioner and keep me

blindfolded from all the investigation

and court process and rejected the

application of 22-A and 22-B and cause

damaged to the petitioner from their

criminal intent and dishonesty.

PRAYER

It is therefore, respectfully being prayed that

the respondents may kindly be directed to

register criminal against the accused.

Any other relief, which this court deems just

and proper may also be awarded.

PETITIONER

THROUGH

Jawad Jamil Malik

Advocate High Court

Moeen Ahmad Siddiqui

Advocate High Court
 BEFORE THE LEARNED DISTRICT AND SESSIONS JUDGE
LAHORE

No. /2020

Muhammad umer s/o Muhammad Farooq r/o 559 bahria

homes, bahria town Lahore.

VERSUS

S.H.O police station sundar, Lahore.

PETITION UNDER SECTION 22-A AND B OF THE CRPC

Muhammad umer s/o Muhammad Farooq r/o 559

AFFIDAVIT OF
bahria homes, bahria town Lahore.

I the above named deponent do hereby solemnly affirm and declare as

under:
That the contents of accompanied petition for registration of case are
true and correct to the best of my knowledge and belief.

DEPONENT
VERIFICATION
It is verified on oath at Lahore on 7 th day of June 2021 that the contents of above affidavit
are true and correct to the best of my knowledge and belief.

DEPONENT