IN THE COURT OF VIIth ADDITIONAL DISTRICT & SESSIONS

JUDGE, SOUTH, KARACHI

Cr. Misc. Application No. _____ of 2023

Sessions Case No: ____ of 2023

Yaseen Ahmed
S/o Ahmed Ali
R/o Hyderabad Applicant

Versus

The State Respondent

FIR No:
U/s:
P.S: Ravi

APPLICATION U/S 516-A CR.P.C

It is most respectfully prayed on behalf of the Applicant above named that

this Hon’ble Court may be pleased to grant the custody of the Car Having
Registration No. KDX-918 Cultus Car, Old Model to the Applicant on the
consideration of the following facts and grounds:

1. That the Applicant is the registered owner of the aforementioned car.

(Photocopy of the Car Registration Book is
annexed as Annexure A/1)

2. That the accused had borrowed the car from Applicant for a few
days. The same car has been taken by the Police, from the Accused
Person.
3. That the subject vehicle is in the custody of the Police and is lying
under the open sky at the Police Station and thus remains in the state
of without any care and results in natural decay.

4. That apart from the Applicant, there is no other Claimant of the

subject vehicle.

5. That the Applicant has nothing whatsoever to do with the alleged

crime against the Accused Person, nor is he an Accused person in
relation to the above FIR(s).

6. That due to the seizure of the car by the concerned police, the
Applicant is continuously suffering. The Applicant uses the car to
travel to his office and the local transport is causing him a heavy
amount to pay, meanwhile the Applicant is in dire need of the car.

7. That since the Applicant only gave his car to the accused for a few
days, only to the extent to his office vacations, which are over now,
thus, the seizure of his car is constantly causing him financial loss.

8. That the Applicant has no information related to the FIR registered

against this subject vehicle. Neither, any evidence connects
Applicant in this case in any way.

9. That since the offense involved has been made triable by this
Hon’ble Court, the jurisdiction to entertain this application rests with
this Hon’ble Court.

10. That the Applicant undertake to produce the aforementioned car if

and when required by this Hon’ble Court.

11. That all the investigation is completed and the aforementioned car is
not required further by this Hon’ble Court.
12. That the Applicant is prepared to enter into bond of superdairi to the
entire satisfaction of this Hon’ble Court.

13. That other grounds shall be urged at the time of hearing of this
Application with the permission of this Hon’ble Court.

In light of the above facts and grounds, it is most respectfully prayed on

behalf of the Applicant that this Hon’ble Court may graciously be
pleased to hand over the custody of the aforementioned car to him in
the best interest of justice.

Prayed accordingly.

KARACHI
DATED:____01.2023
ADVOCATE FOR THE APPLICANT
IN THE COURT OF VIITH ADDITIONAL DISTRICT & SESSIONS
JUDGE, SOUTH, KARACHI

Cr. Misc. Application No. ____ of 2023

Yaseen Ahmed
S/o Ahmed Ali
R/o Hyderabad Applicant

Versus

The State Respondent

FIR No:
U/s:
P.S: Ravi
AFFIDAVIT IN SUPPORT OF APPLICATION U/S 516-A CR.P.C

I, YASEEN AHMED S/O Ahmed Ali R/o Hyderabad do hereby state on

Oath as under:-

1. That I am the Applicant and the deponent of this Affidavit I am fully

familiar with the facts of the case as I am the owner of the subject
vehicle.

2. That the Application U/s 561-A has been drafted and registered
under my supervision.

3. That for the sake of compactness the contents of the consequent

application and grounds taken therein may be examined as element
and parcel of this affidavit.
 4. That I say that I, being the registered owner of the subject vehicle,
am authorized to bring back the custody of the subject vehicle which
is presently lying in the custody of Police Station Ravi.

5. That I am ready to follow with the condition if any put and also
make sure the production of the subject vehicle in the Court as and
when required.

6. That unless this Application is granted, I shall tolerate irretrievable

loss and torture.

That whatever is mentioned above is true and correct to the best of

my knowledge and belief.

KARACHI
DATED:____1, 2023 DEPONENT

The deponent above is identified by me.

ADVOCATES

On Oath before me at Karachi on this 1 January 2023 by the deponent

above named who is identified to me by _______Advocate, who is known
to me personally.
COMMISSIONER FOR TAKING AFFIDAVITS.