IN THE COURT SESSIONS JUDGE GHOTKI

Cr. Misc. Application No. of 2013

Abdul Haleem S/o Sadoro,

Muslim, Adult, by caste Malik,
R/o Village Khoh Minhon, P.O Jarwar,
Taluka Mirpur Mathelo, Distt: Ghotki.………………………Applicant

VERSUS

1. Senior Superintendent of Police,

District Ghotki.

2. Station House Officer,

Police Station Yaro Lund.

3. Station House Officer,

Police Station Khanpur Mahar.

4. Qasim S/o Gohram,

By caste Malik, R/o Village Chak,
Khanpur Mahar, District Ghotki.

5. The State…...……………………………………..……….Respondents

DETENUE

Mai Jameela W/o Shoukat,

(Daughter-in-law & Niece of applicant)
Aged about 25/26 years.

CONFINED AT:-

APPLICATION UNDER SECTION 491 CR.P.C.

That applicant above named respectfully begs to submit

as under:-

Cont’d P/2
 -: 2 :-

1/- That the applicant is a law abiding citizen, and resides

on the above captioned address.

2/- That Shaukat Ali is a son of the applicant and the

detenue is the wedded wife of Shaukat Ali, the marriage was

contracted on 05.12.2009 at village Yaro Lund.

3/- That the respondent No.4 remained upon the applicant

and his family members and was in the search of a chance to teach

them lesson.

4/- That on 26-08-2013 at about 08:00 pm the applicant

along with his relatives each namely Khamiso S/o Ghulam Qadir

and Bahawal S/o Sadoro was present at his house when respondent

No.4 along with four (04) unidentified persons with weapons

entered into the house of applicant and controlled over the applicant

party with deadly weapons and started to search the house of the

applicant, thereafter, the applicant party interrupted into the search

of respondent No.4, on that the respondent No.4 instigated other

persons to teach the lesson to the applicant, therefore, the

unidentified persons kicks and fists blows to the applicant and on

the pointation of weapons the respondent No.4 took away the

detenue along with her baby daughter namely Zarina aged about 06

or 07 months with himself and went away by making aerial firing.

Cont’d P/2
 -: 3 :-

5/- That thereafter, the applicant narrated the above facts to

his relatives, therefore, the applicant and his relatives time to time

approached to the respondent No.4 and requested them to return

the detenue but the respondent No.4 all the time kept the applicant

and his relatives on hollow hopes and finally refused to return the

detenue to the applicant.

5/- That after refusal of the respondent No.4 for the return

of the detenue, the applicant along with witnesses approached to

respondent Nos. 2 & 3 and narrated them above facts and requested

them for recovery of detenue along with baby daughter Zarina but

the respondent Nos. 2 & 3 did not pay any heed to the applicant

party.

6/- That there is no other alternate efficacious remedy

available to the applicant hence he invokes the extra ordinary

criminal jurisdiction of this Honorable Court by filling this Misc:

Applicant.

7/- That prior to this no application like such nature has

been filed.

Cont’d P/4

-: 4 :-
 PRAYER

a) To appoint the Raid Commissioner to visit

the said police stations, where the detenue

is wrongful confinement of respondent

No.1 & 2 and to record the statement of the

detenue before this Honourable Court.

b) Any other relief which this Honourable

Court, deems, fit and proper.

________________
APPLICANT

Note:- Drafted and drafted by me

under the instructions of my applicant.

Ghotki:
DATED : -09-2013 ADVOCATE FOR APPLICANT
 IN THE COURT SESSIONS JUDGE GHOTKI

Cr. Misc. Application No. of 2013

Abdul Haleem………………………...………………………Applicant

VERSUS

SSP Ghotki & others……………….……………………….Respondents

AFFIDAVIT

I, Abdul Haleem S/o Sadoro, Muslim, Adult, by caste

Malik, R/o Village Khoh Minhon, P.O Jarwar, Taluka Mirpur
Mathelo, Distt: Ghotki, do hereby state on oath as under:-

1/- That I am complainant in the above case and well

conversant with all above facts of the case.

2/- That the contents of Cr. Misc. Application has been

drawn and drafted by my Advocate under my instructions and
same may be treated as part and parcel of this affidavit.

3/- That what ever stated is true and correct to the best of
my knowledge and belief.

Verified and signed at Ghotki on this ____ day of September, 2013

Identified by me Deponent

Advocate