IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH

AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022
NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR

Petitioners Respondents

IN THE MATTER OF
INDEX
S.No Particulars Page Fee
01 Memo Of Urgency
02 Memo Of Parties
03 Dates and Events
04 Writ Petition along with affidavit
05 ANNEXURE-I
(The copy of the FIR No 0042/2022 dated 03-03-2022
06 ANNEXURE-II
Copy of order dated 01-11-2019
07 ANNEXURE-III
( Copy of application
17 Application for interim relief along with affidavit
18 Vakalatnama

PETITIONERS
Place: - Jammu THROUGH COUNSEL
DATED: 04-03-2022

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.com

IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH

 AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022

NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR

Petitioners Respondents

IN THE MATTER OF: - Memo of urgency.

MAY IT PLEASE YOUR HONO.UR,

The Petitioners, respectfully submit as under:-

1. That the Petitioners have filed the above titled writ Petitioners
along with application for interim relief which is sure to succeed on
merits.
2. That the matter is of emergent in nature and requires to be taken
up for today itself otherwise the applicants shall suffer an
irreparable loss and injury which cannot be compensated by any
other means.
It is, therefore, respectfully prayed that the above titled writ
Petitioners may very kindly be directed to listed for today itself in
the interest of justice.

PETITIONERS
Place: - Jammu THROUGH COUNSEL
DATED: o4-03-2022

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.com
IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH
AT JAMMU.
CRM(M)No. ______/2021
CrIM. No._____/2021

NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR

Petitioners Respondents

IN THE MATTER OF:-

MEMO OF PARTIES

1. Nafeez Khan Age 28 Years, S/o Mohd Hafiz khan,

2. Mohd Hafiz Khan Age 65 Years S/o Mohd Afzal
3. Zeenat Begum age 62 years W/o Mohd Hafiz Khan
4. Gulfam Khan age 53 years W/o Mohd Hafiz Khan
All Resident Village Dakhi Bhera Tehsil Mendhar District
Poonch.

………… Petitioners

Versus

1. Union Tettitory of J&K through Superintendent of Police

(SSP) Poonch.

2. SHO Police Station Mendhar, District Poonch.

3. Sobia Jahanghir D/o Mohd Jahanghir W/o Nafeez Khan R/o

Dakhi Bhera Tehsil Mendhar District Poonch.

………….. Respondents

PETITIONERS
Place: - Jammu THROUGH COUNSEL
DATED: 04-04-2022.

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.com
IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH
AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022
NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR
Petitioners Respondents

IN THE MATTER OF:- LIST OF DATES AND EVENTS

S No. DATE EVENTS

1. 19-10-2021 That FIR No 0042/2022 dated

2 20-10-2020

3 19-10-2021

4 19-10-2021

5 03-01-2022.

6 11-11-2021
20-11-2021

7 26-02-2020

8 02-12-2021
 PETITIONERS
Place: - Jammu THROUGH COUNSEL
Dated: 04-03-2022

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.com

IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH

 AT JAMMU.

Petition under section 482 Cr.P.C

Matter pertains to District, Poonch.

CRM(M)No. ______/2022
CrIM. No._____/2022

1. Nafeez Khan Age 28 Years, S/o Mohd Hafiz khan.

2. Mohd Hafiz Khan Age 65 Years S/o Mohd Afzal.
3. Zeenat Begum age 62 years W/o Mohd Hafiz Khan.
4. Gulfam Khan age 53 years W/o Mohd Hafiz Khan
All Resident Village Dakhi Bhera Tehsil Mendhar District
Poonch.

………… Petitioners

Versus

1. Union Tettitory of J&K through Superintendent of Police

(SSP) Poonch.
2. SHO Police Station Mendhar, District Poonch.

3. Sobia Jahanghir D/o Mohd Jahanghir W/o Nafeez Khan R/o

Dakhi Bhera Tehsil Mendhar District Poonch.

………….. Respondents
………….. Respondents

IN THE MATTER OF:-

Petition under section 482 of Code of Criminal

Procedure, seeking quashment of F.I.R Bearing
No. 0042/2022 dated 03-03-2022 registered
under sections 494, 498-A and 109 IPC
Registered with Police Station Mendhar,
District Poonch, and the subsequent
proceedings being the abuse of process of law,
same deserves to be quashed.

Any further order or direction which the

Hon’ble Court may deem fit and proper be also
passed in favour of the petitioners against the
 respondent keeping in view the nature and
circumstances of the case into consideration.

MAY IT PLEASE YOUR LORDSHIPS ;

The Petitioners most respectfully submit as under:-

1. That the petitioners are the permanent residents of Union

Territory of Jammu and Kashmir and citizens of India to

whom the Fundamental, legal and statutory rights are

guaranteed by the constitution of India and the laws made

there under.

1. That through the medium of instant petition under section

482 of the Code of Criminal Procedure the petitioners are

challenging the validity of the F.I.R Bearing No. 0042/2022

dated 03-03-2022 registered under section 494, 498-A and

109 IPC Registered with Police Station Mendhar, District

Poonch and subsequent proceedings being the abuse of

process of law. The copy of the FIR No 0042/2022 dated

03-03-2022 is annexed herewith and marked as

ANNEXURE-I.

MATRIX OF THE CASE :-

THAT BEFORE ADVERTING THE GROUNDS OF

CHALLENGES IT IS DESIRABLE TO GIVE THE BRIEF
FACTUAL MATRIX OF THE CASE LEADING TO THE
FILLING OF THE PRESENT PETITION:-
2. That the petitioners are the law abiding and peace loving

citizens of India and have never committed any offence so

far, the petitioner No. 1 is the husband of the respondent

 No.3 (Complainant). The petitioner No. 2 to 4 are the Father

in law and mothers in law of the respondent No.3.

3. That the petitioner No.1 had solemnized the marriage with

respondent No.3 on November 2016 and she left her

matrimonial house in December 2016, as the relationship

between the petitioner no.1 and his wife were not cordial

from the beginning as the behavior of the respondent No.3

was not good, as the wife (Respondent No.3) of the

petitioner no.1 used to quarrel using filthy language

threatening the petitioners for dire consequences without

any reason.

4. That the petitioner No.1 always tried his best to maintain

matrimonial relationship with his wife but she always

threatened seek divorce and solemnized second marriage. It

is submitted that she left the company of the petitioner No. 1

willfully and never returned back since 2016.

5. That petitioner No. 1 also filed suit for decree of restitution of

conjugal rights on __________ in the court of Learned Munsiff

Mendhar which is pending and next date of hearing is fixed on

_________.

6. That respondent No. 3 is a teacher in education Department of

U.T. of J and K Government and presently posted in Govt

Middle School Dhakki. She is drawing salary of about more

than 30,000 per month however suppressing this fact in order

to harass the petitioners, she filed the petition under Sec-488

of CrPC on 04-07-2019 before the court of Learned Judicial

Magistrate 1st Class Munsiff Mendhar.

7. That petitioner appeared in the said case and stated the

correct position as regards the service of respondent No. 3

in Education Department. Once respondent was confronted

by the court with a reply filed by the petitioner No. 1, the

Honble Court asked the respondent No. 3 to explain her

position.

8. That respondent No. 3 appeared before the Learned Judicial

Magistrate 1st Class Munsiff Mendhar on 01-11-2019 and

stated in the open court that she is Govt Employee and she is

getting salary over 30,000/ per month, she further stated that

she does not want maintenance but desolation of marriage

consequently the Honble Court of Judicial Magistrate 1 st Class

Munsiff Mendhar dismissed the petition under Sec – 488 of

CrPC on 01-11-2019. Copy of order dated-01-11-2019 is

enclosed herewith and marked as Annexure-iii.

9. That respondent No. 3 has deserted the petitioner No. 1

voluntarily and does not want to continue the relationship of

husband and wife with petitioner No. 1 with a view to

pressurize the petitioners, she is adopting pressure tactics

so that the marriage is dissolved as per the choice and wish

of respondent No. 3. In order to achieve this objective,

respondent No. 3 has involved all the petitioners in a false

and frivolous case as she filed a false complaint and FIR No.

0042/2022 Dated- 03-03-2022 got registered against the

petitioners in Police Station Mendhar under Section 494,

498A, and 109 of IPC to wreck vengeance, abuse and

misuse the process of law.

10. That based on the said FIR, petitioners are being harassed

and summoned by the police station. It is submitted that

allegations in the FIR are baseless and concocted, petitioner

No. 1 never solemnized second marriage nor he has caused

mental or physical harassment to respondent No. 3 as she

left the company of the petitioner No. 1 after 1 month of the

marriage.

11. That respondent No. 3 just harassed the petitioners, just

managed to registered impugned FIR and now in the garb of

the said FIR the respondent no 2 is unnecessarily harassing

the petitioners for their no fault, so the petitioners are left

with no option except to approach the Hon’ble High Court by

presenting this petition on the facts as stated and the

grounds which are enumerated as under

GROUNDS OF CHALLENGE :-

I) That the criminal proceedings initiated against the

petitioners are manifestly attended with malafide and are
maliciously made with an ulterior motive for wrecking
personal vengeance with a view to spite the petitioner
due to private and personal grudge against them. The
impugned FIR has caused great miscarriage of justice
and is liable to be quashed.

II) That the allegations levelled in the FIR as well as the

complaint are absurd and inherently improbable on the
basis of which no prudent person can ever reach a just
conclusion that there is sufficient ground for proceedings
against the petitioners. Even the criminal proceedings
are manifestly attended with malafide and / or where the
 proceedings are maliciously made with an ulterior
motive for wreaking vengeance on the accused.

III) That if the instant FIR is not quashed, the investigation

will finally culminate into challan which is liable to be

dismissed for want of evidence, hence will lead to the

wasting of time of the investigating agency and precious

time of the Hon’ble Court.

IV) That the Hon’ble Supreme Court has laid down following

guidelines with regard to the quashing of FIR/Complaint

in case titled STATE OF HARYANA & ORS V/S CH

BHAJAN LAL AND ORS REPORTED IN 1992 AIR 604

, 1990 SCR SUPL (3) 259

8.1 In the exercise of the extra- ordinary powers under

section 482 of the code of Criminal Procedure, the
Following categories of cases are given by way of
illustration wherein such power could be exercised
either to prevent abuse of the process of any court
or otherwise to secure the ends of justice, though
it may not be possible to lay down any precise,
clearly defined and sufficiently canalized and
inflexible guide 73 myriad kinds of cases wherein
such power should be exercised:

a/. where the allegations made in the first

information report or the complaint ,even if
they are taken at their face, value and
accepted in their entirety do not prima facie
constitute any offence or make to a case
against the accused;
b/. Where the allegations in the First Information
report and other material if any ,accompanying
the F.I.R do not disclose a cognizable
offence ,justifying an investigation by police
officer s under section 156(1) of the code
except under an order of a Magistrate within
the purview of section 155(2) of the code;

c/. Where the uncontroverted allegations made in the

FIR or complaint and the evidence collected in
support of the same do not disclose the
commission of any offence and make out a
case against the accused:

(d) where the allegations in the FIR do not constitute a

cognizable offence but constitute only a non-
cognizable offence, no investigation is
permitted by the police officer without an
order of a magistrate as contemplated under
section 155(2) of code

(e) where the allegations made in the FIR or compliant

are so absurd and inherently improbable on
the basis of which no prudent person can ever
reach a just conclusion that the is sufficient
ground for proceeding against the accused .

(f) where there is an express legal bar engrafted in any

of the provisions of the code or the concerned
act ( under which a criminal proceeding is
instituted) to the institution and or where there
is a specific provision in the code or the
concerned Act, providing efficacious redress
for the grievance of the aggrieved party.

(g) where a criminal proceeding is manifestly attended

with malafide and / or where the proceeding is
maliciously instated with an ulterior motive for
 wreaking vengeance on the accused and with
a view to spite him due to private and personal
grudge “

12. That the impugned FIR suffers from legal defects as essential

ingredients for constituting the offence mentioned in the same

are lacking. The F.I.R does not mention all the ingredients of

the offence and is based on mere ambiguity.

13. That there is no question of Sec – 494 IPC involved in the

present case as petitioner No. 1 never solemnised second

marriage and otherwise petitioner No. 1 is well within his rights

to solemnise second marriage under Muslim Personal Law,

hence the allegations in the FIR is baseless and deserves to

be quashed.

14. That there is no question of Sec 498-A IPC as respondent No. 3

left the company of the petitioners in the year 2016 after a
period of 1 month of marriage and never returned back and
the said FIR is registered in 2022. There is no question of
cruelty as the basic necessary elements of cruelty mentioned
under law are not being fulfilled as the respondent No. 3 is
living separately since December 2016.
The Section 498-A is reproduced as under-
“498A. Husband or relative of husband of a woman subjecting her to
cruelty.—Whoever, being the husband or the relative of the husband of a
woman, subjects such woman to cruelty shall be punished with imprisonment
for a term which may extend to three years and shall also be liable to fine.
Explanation.—For the purpose of this section, “cruelty” means—

(a) any wilful conduct which is of such a nature as is likely to drive the woman to
commit suicide or to cause grave injury or danger to life, limb or health (whether
mental or physical) of the woman; or

(b) harassment of the woman where such harassment is with a view to coercing
her or any person related to her to meet any unlawful demand for any property
or valuable security or is on account of failure by her or any person related to
her to meet such demand.]”

15. That the Honble Supreme Court in Arnesh Kumar vs. State of

Bihar and Anr reported in (2014) 8 SCC 273, has held that
 Section 498A has a "dubious place of pride amongst the

provisions that are used as a weapon rather than a shield

by disgruntled wives" hence the impugned FIR is baseless,

false, frivolous and deserves to be quashed.

16. That the Honble Supreme Court in Sushil Kumar Sharma v.

Union of India and others , it was held by the Supreme

Court:-

"Provision of S. 498A of Penal Code is not unconstitutional

and ultra vires. Mere possibility of abuse of a provision of
law does not per se invalidate a legislation. Hence plea
that S. 498A has no legal or constitutional foundation is not
tenable. The object of the provisions is prevention of the
dowry menace. But many instances have come to light
where the complaints are not bona fide and have been
filed with oblique motive. In such cases acquittal of the
accused does not in all cases wipe out the ignominy
suffered during and prior to trial. Sometimes adverse
media coverage adds to the misery. The question,
therefore, is what remedial measures can be taken to
prevent abuse of the well-intentioned provision. Merely
because the provision is constitutional and intra vires,
does not give a licence to unscrupulous persons to wreck
personal vendetta or unleash harassment. It may,
therefore, become necessary for the legislature to find out
ways how the makers of frivolous complaints or allegations
can be appropriately dealt with. Till then the Courts have to
take care of the situation within the existing frame-work.”
The respondent is misusing the process of law and
causing unnecessary mental disturbance as well as
monetary loss to the petitioners without sufficient cause
and reason hence the impugned FIR is abuse of process
of law hence deserves to be quashed.

17. That In case titled State of Telangana v Habib Abdullah

Jeelani reported in AIR 2017 SupremeCourt37, it is held as
under:- “11. Once an FIR is registered, the accused
persons can always approach the High Court under
Section 482 CrPC or under Article 226 of the Constitution
for quashing of the FIR. In Bhajan Lal (supra) the two-
Judge Bench after referring to Hazari Lal Gupta v.
Rameshwar Prasad[7], Jehan Singh v. Delhi
Administration[8], Amar Nath v. State of Haryana[9],
Kurukshetra University v. State of Haryana[10], State of
Bihar v. J.A.C. Saldanha[11], State of West Bengal v.
Swapan Kumar Guha[12], Smt. Nagawwa v. Veeranna
Shivalingappa Konjalgi[13], Madhavrao Jiwajirao Scindia
v. Sambhajirao Chandrojirao Angre[14], State of Bihar v.
Murad Ali Khan[15] and some other authorities that had
dealt with the contours of exercise of inherent powers of
the High Court, thought it appropriate to mention certain
category of cases by way of illustration wherein the
extraordinary power under Article 226 of the Constitution
or inherent power under Section 482 CrPC could be
exercised either to prevent abuse of the process of any
court or otherwise to secure the ends of justice. The
Court also observed that it may not be possible to lay
down any precise, clearly defined and sufficiently
channelized and inflexible guidelines or rigid formulae
and to give an exhaustive list of myriad cases wherein
such power should be exercised. The illustrations given
by the Court need to be recapitulated:- “
(1) Where the allegations made in the first information
report or the complaint, even if they are taken at their face
value and accepted in their entirety do not prima facie
constitute any offence or make out a case against the
accused.
(2) Where the allegations in the first information report
and other materials, if any, accompanying the FIR do not
disclose a cognizable offence, justifying an investigation
by police officers under Section 156(1) of the Code except
under an order of a Magistrate within the purview of
Section 155(2) of the Code.
(3) Where the uncontroverted allegations made in the FIR
or complaint and the evidence collected in support of the
same do not disclose the commission of any offence and
make out a case against the accused.
(4) Where, the allegations in the FIR do not constitute a
cognizable offence but constitute only a non-cognizable
offence, no investigation is permitted by a police officer
CRMC No.580/2018 Page 4 of 7 without an order of a
Magistrate as contemplated under Section 155(2) of the
Code.
(5) Where the allegations made in the FIR or complaint are
so absurd and inherently improbable on the basis of
which no prudent person can ever reach a just conclusion
that there is sufficient ground for proceeding against the
accused.
(6) Where there is an express legal bar engrafted in any of
the provisions of the Code or the concerned Act (under
which a criminal proceeding is instituted) to the
institution and continuance of the proceedings and/or
where there is a specific provision in the Code or the
concerned Act, providing efficacious redress for the
grievance of the aggrieved party.
(7) Where a criminal proceeding is manifestly attended
with mala fide and/or where the proceeding is maliciously
instituted with an ulterior motive for wreaking vengeance
on the accused and with a view to spite him due to private
and personal grudge.”
It is worthy to note that the Court has clarified that the
said parameters or guidelines are not exhaustive but only
illustrative. Nevertheless, it throws light on the
circumstances and situations where court’s inherent
power can be exercised. 12. There can be no dispute over
the proposition that inherent power in a matter of
quashment of FIR has to be exercised sparingly and with
caution and when and only when such exercise is
justified by the test specifically laid down in the provision
itself. There is no denial of the fact that the power under
Section 482 Cr.PC is very wide but it needs no special
emphasis to state that conferment of wide power requires
 the court to be more cautious. It casts an onerous and
more diligent duty on the Court.”
18. That the whole accusation/ involvement of the petitioners is

based on mere assumption and there is not even iota of

evidence whatsoever against the petitioners

19. That the journey of the justice through process of law should be

Swift and secure and the respondent No. 2 is arbitrarily

indulging the petitioners as accused, It is further pleaded

petitioners are innocent persons and commands respect in the

society.

20. That there is not even an iota of evidence against the petitioners

and if the impugned FIR is not quashed it would defeat the

ends of justice and will cause harassment to the innocent

petitioners even if the allegation against the petitioners were

accepted they could never be convicted as there is no

sufficient evidence against the petitioners which could prove

them guilty.

21. That the petitioners have not filed any other writ petition on the

same cause of action either in this Hon’ble Court or the

Hon’ble High Court of Srinagar in any other court including

the Hon’ble Supreme Court of India but is presenting this

petition in the Hon’ble court for its adjudication.

22. That no any other alternate efficacious remedy is available to the

Petitioners except the present writ petition.

23. That the petitioners reserve their right to agitate any other

additional or alternative grounds which may be available to

them at the time of hearing

24. That the Annexures appended with this petition from I to XIII
have been compared with original ones and same are correct.

An affidavit support of this petition is enclosed.

IN THE PREMISES OF

It is, therefore, most respectfully prayed that keeping in view the

submissions made hereinabove and those to be urged at the time

of hearing, the Hon’ble Court may very kindly be pleased to allow

the present petition and issue directions or order:

By allowing this petition with a prayer to quash the F.I.R

Bearing No. 0042/2022 dated 03-03-2022 registered under

sections 494, 498-A and 109 IPC Registered with Police

Station Mendhar, District Poonch, and the subsequent

proceedings being the abuse of process of law.

Any further order or direction which the

Hon’ble Court may deem fit and proper be also passed in
favour of the petitioners against the respondents keeping in
view the nature and circumstances of the case into
consideration.

PETITIONERS
Place: - Jammu THROUGH COUNSEL
Dated: o4-04-2022

H.A. SIDDIQUI
ADVOCATE

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.com
IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH
AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022

NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR

Petitioners Respondents

IN THE MATTER OF: - Affidavit in support of writ petition

I, Nafeez Khan Age 28 Years, S/o Mohd Hafiz khan, R/o Village
Dakhi Bhera Tehsil Mendhar District Poonch, do hereby state on
oath/ solemnly affirm that I am the petitioner in the writ petition and is
fully conversant with the facts of the case and is competent to swear
the present affidavit in support of the writ petition and that the
contents of paras 1 to 34 of the writ petition are true to my personal
knowledge which I believe to be true.
I solemnly swear/affirm that this affidavit is true no part of this is
false and nothing has been concealed.

Place: - Jammu
Dated: o4-04-2022
IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH
AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022
NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR
Petitioners Respondents

IN THE MATTER OF

Application on behalf of the petitioner with a prayer to stay

the operation of the impugned F.I.R Bearing No.
0042/2022 dated 03-03-2021 Registered at Police
Station Mendhar, District Poonch.

MAY IT PLEASE YOUR LORDSHIPS;

The applicants/Petitioners most respectfully submit as under:-

1. That this is a Application (CM in short) which has arisen out of the
presented writ petition in which the full details of the case have
exhaustively been enumerated in the main petition and there is no
need for repeating the same, the petitioners seek the indulgence of
the Hon’ble court to treat them as incorporated hereinabove.

2. That the prima facia case is in favour of the petitioners vis-à-vis

respondents which is not only based on probability of rights but is also
based on certainty of the facts as well.

3. That the balance of convenience is in favour of the petitioners vis-à-

vis respondents and granting of exparte interim relief is the need of
the hour, in case of its refusal irreparable loss can be caused to the
petitioners which cannot be later on be compensated by the
respondents to the petitioners.

An affidavit in support of application is enclosed herewith.

IN THE PREMISES: -

It is, therefore, most respectfully prayed that

keeping in view the submissions made hereinabove and those
to be urged at the time of hearing, the Hon’ble Court may very
kindly be pleased to pass the following relief:-
A By allowing this Application with a prayer to stay the operation
of the impugned FIR Bearing No. 0042/2022 dated 03-03-
2022 as per Annexure-I in the writ petition.
B passing of any other further writ, order or direction which the
Hon’ble Court may deem fit and proper be also passed in
favour of the petitioner against the respondents keeping in view
the nature and circumstances of the case into consideration.

APPLICANTS/PETITIONERS
Place:- Jammu THROUGH COUNSEL
DATED: 04-04-2022

H.A. SIDDIQUI
ADVOCATE

SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email:advocateshamas@gmail.co
IN THE HON’BLE HIGH COURT OF JAMMU & KASHMIR AND LAKAKH
AT JAMMU.
CRM(M)No. ______/2022
CrIM. No._____/2022

NAFEEZ KHAN AND ORS VERSUS U.T OF J&K AND ANR

Petitioners Respondents

IN THE MATTER OF: - Affidavit in support of CrIM.

I, Nafeez Khan Age 28 Years, S/o Mohd Hafiz khan, R/o Village
Dakhi Bhera Tehsil Mendhar District Poonch, do hereby state on oath/
solemnly affirm that I am the petitioner in the writ petition and is fully
conversant with the facts of the case and is competent to swear the
present affidavit in support of the CrIM and that the contents of paras 1
to 3 of the CrIM are true to my personal knowledge and those of paras A
to B are true upon legal advice received by me which I believe to be true.
I solemnly swear/affirm that this affidavit is true no part of this is
false and nothing has been concealed
Place:Jammu.
Dated: 04-03-2022