IN THE COURT OF SESSIONS JUDGE, KASHMORE @ KANDHKOT

Crl.Misc.App.No. _______of 2024

Suleman s/o Piyaro by Caste Malik, Adult,

Muslim, r/o Village Bahadur Khan Chachar Taluka Kandhkot
District Kashmore @ Kandhkot --------------------------- Applicant/Petitioner

VERSUS

1. SSP Kashmore @ Kandhkot

2. SHO P.S A Section Kandhkot
3. I/C PP C Section Kandhkot
4. SHO PS B Section Kandhkot
5. ASI Mir Hassan Malik of PS B Section Kandhkot
6. Ghulam Yasin S/o Fazal Muhammad By Caste Malik, adult, muslim, r/o Mumtaz
Muhalla Kandhkot
7. Qadir Bux s/o Khuda Bux By Caste Malik, adult, muslim, r/o Mumtaz Muhalla Kandhkot
8. Asmatullah s/o Rahmatullah By Caste Malik, adult, muslim, r/o Mumtaz Muhalla
Kandhkot -------------------------------------------------------------------------(Respondents)

APPLICATION U/S 22-A, 22-B, 22(6) Cr.P.C

The petitioner named above begs to submit as under:-

1. That the Petitioner is a law abiding citizen of Pakistan and used to reside at captioned
address along with his brother Nawab Ali, father Piyaro and other family members.

2. That on 20-06-2024 respondent No. 6 lodged a false FIR against petitioner his brother
Nawab Ali and others regarding kidnapping of Mst Rubina daughter of Bashir Ahmed
Malik with PS A Section Kandhkot u/s 452, 365-B, 148, 149 PPC vide crime No.175 of
2024. In which respondent No. 7 and 8 were shown as PWs while respondent No. 5 is a
highly influential person who is supporting respondents No. 6 to 8.

3. That after registration of FIR I.O of Crime No. 175 of 2024 PS A Section Kandhkot
thoroughly investigated the case and came to the conclusion that present petitioner and
his brother Nawab Malik are innocent while accused Rab Nawaz and Ali Mardan both by
caste Jatoi were declared as real culprits of the case. Such report u/s 173-B CrPC was
submitted by I.O before the court of learned 1 st Civil judge and JM Kandhkot while
 putting the names of petitioner and his brother Nawab Ali in column No. 2 of the
chargesheet.

4. That after submission of report u/s 173 B CrPC respondents No. 5 to 8 became annoyed
with the petitioner and his other family members and started harassing the petitioner party
with the help of respondents No. 2 to 4.

5. That respondents no. 6 to 8 with the help of respondents No. 2 to 5 are harassing the
petitioner party and are trying to implicate them in chain of false cases.

6. That respondents No. 2 to 5 called the petitioner and his brother separately in their offices
and directed them to produce the abductee else would face its consequences in shape of
false cases and made lives and liberties of petitioner party as miserable.

7. That petitioner so many times approached to respondent No. 1 for their protection but
neither protection was provided to petitioner party nor any action what so ever was taken
against respondents No. 2 to 8.

8. That there is no any other remedy available with the petitioner excepting knocking the
door of this honorable court with following prayers.

9. That this Honourable Court may be pleased to:-

a. To declare that act of respondents as null, void, illegal, ultra-vires and without any
justification.

b. To direct the respondent No 1 to provide protection to the lives, liberties and properties of
petitioner party as guaranteed under the constitution of Pakistan.

c. That this honorable court may graciously be pleased to direct the respondent No 2 and 5
not to harass the petitioner party at the instance respondents No. 6 to 8.

d. That this honorable cpurt may graciously be pleased to call the respondents No. 6 to 8 in
persons before this honorable court and obtain such PR Bonds from them not to cause
harm to the lives and liberties of petitioner party.
e. To award any other relief which this Honorable court may deem fit and proper under the
circumstances of the petition.

Drafted and filed by me under the instructions from my client,

(SAEED AHMED BIJARANI)

Advocate for petitioner.

UNDERTAKING:-

This is to certify that this is a first Cr. Msl application filed by under signed on
behalf of the petitioner and no such application of similar nature has been filed earlier
before this honorable court or any other court of law having jurisdiction.

Kandhkot (Saeed Ahmed B. Bajkani)

10-07-2024 Advocate for petitioner
 IN THE COURT OF SESSIONS JUDGE, KASHMORE @ KANDHKOT
Crl.Misc.App.No. _______of 2024

Suleman Malik -------------------------------------------------------- Applicant/Petitioner

VERSUS

SSP Kashmore @ Kandhkot and others ---------------------------------- Respondents

AFFIDAVT

I, Suleman s/o Piyaro by Caste Malik, Adult, Muslim, r/o Village Bahadur
Khan Chachar Taluka Kandhkot District Kashmore @ Kandhkot do here by state on oath:

1. That I am petitioner in the above petition, hence well conversant with the facts of the
case.

2. That I adopt all the grounds of accompanying petition for the brevity of this affidavit.

3. That whatever stated above is all true and correct to the best of my knowledge and belief.

KANDHKOT DEPONENT
DATED: 10-07-2024 CNIC No. 43503-0606891-7
Cell No. 0311-3487007

I know the deponent

(SAEED AHMED B. BIJARANI)

Advocate for the Petitioner