IN THE COURT OF SESSIONS JUDGE LAHORE.

Cr. Misc. No. _______________ / 2016

Mst. Humaira Kausar wife of Ali Raza resident of

House No.558, Block No.4, Sector A/2, Township,
Lahore.
PETITIONER

VERSUS

STATION HOUSE OFFICER, Police Station,

Township, Lahore.

RESPONDENT

PETITION UNDER SECTION 22-A & 22-B CR.PC FOR

ISSUANCE OF DIRECTION TO THE RESPONDENT NOT
TO HARASS THE PETITIONER AND HER HUSBAND
FAMILY MEMBERS ILLEGALLY, UNLAWFULLY,
IMPROPERLY IN ANY MANNER WHATSOEVER.

Respectfully Sheweth:

1. That the addresses of the parties given in the

head of petition are correct and notices can

easily be served.

2. That the brief facts leading to the institution

of present petition are that the petitioner

independently with free will married with Ali

Raza son of Muhammad Riaz on dated

15.11.2016 according to Shariat Muhammadi

and residing with him happily at the above

mentioned address. Copy of Nikah Nama is

 attached herewith for the kind perusal of this

honorable court.

3. That the respondent on the instigation of the

petitioner’s relatives creating the illegal

harassment and threatening for dire

consequences and pressurizing to the

petitioner for divorce from her husband

otherwise, the respondent involved petitioner

and his family members in false criminal

cases.

4. That the petitioner also approached to the

respondent and requested him to stop the

illegal harassment and cursive measures

adopted by the relatives of the petitioner, but

the respondent also refused to do so on

behalf of petitioner’s relatives, hence this

petition.

5. That the petitioner has no other efficacious

and speedy remedy except to invoke the

jurisdiction of this Honourable Court.

PRAYER

It is therefore, most respectfully prayed that

the petition in hand may kindly be accepted and

direction to respondent may kindly be issued not

to harass the petitioner, her husband and family

members of the petitioner’s husband, in any

manner whatsoever.

It is further prayed that respondent may

kindly be restrained to involve the petitioner and

the in laws of the petitioner in any false and

frivolous criminal case.

Any other relief which this Honourable Court

may deems fit and proper may also be awarded.

PETITIONER
DATED: 22.12.2016
Through
CH. MUBASHAR IQBAL
Advocate High Court,
Office No.1, 3rd Floor, Aftab Tower,
A.G, Office Chowk, Lahore.
Note:
As per instructions of my client this is petition on
the subject matter before this Honourable Court.

Advocate
IN THE COURT OF SESSIONS JUDGE LAHORE.

Cr. Misc. No. _______________ / 2016

Mst. Humaira Vs SHO

(PETITION UNDER SECTION 22-A & 22-B Cr.PC)

AFFIDAVIT OF: Mst. Humaira Kausar wife of Ali

Raza resident of House No.558,
Block No.4, Sector A/2,
Township, Lahore.

I, the above named deponent do hereby solemnly

affirm and declare as under:

That the contents of the petition are correct to the

best of my knowledge and belief and nothing has been

concealed therein.

DEPONENT
Verification:

Verified on oath at Lahore on this 22nd day of

December, 2016 that the contents of the affidavit are
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT