IN THE COURT OF LEARNED SESSIONS JUDGE/

JUSTICE OF PEACE, OKARA

Petition No._________/2013

Saeed Ahmed
Son of Shahid Rasool
R/o Kot Noor-ul-Hassan
Karamat Khan, Haveli Lakha
Tehsil Depalpur, District Okara

PETITIONER
Versus

1. Station House Officer,

Police Station __________,
Okara.

2. Abidoon Subhani
S/o _______________
R/O _________________

RESPONDENTS
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PETITION under Section 22-A & 22-B Cr.P.C. for registration

of case against the respondent No.2 under Section
489-F PPC.

Respectfully Sheweth:

That the precise facts for the filing of the instant petition before
this Hon'ble Court are hereunder:-

1. That the petitioner is the bonafide and law abiding citizen of

Pakistan.

2. That petitioner was doing a business with respondent no. 2

for last many years. Petitioner used to send bags containing
flour on daily basis or when respondent no 2 demanded.
Petitioner sent almost 6843 bags of flour of amount Rs.
_______________. Respondent promised to pay the said
amount but failed to do so.

3. That the respondent No.2 issued a cheque No.16910950

dated 10.10.2012 drawn at Habib Metropolitan Bank Ltd,
Okara Branch amounting to Rs.5,00,000/-. Copy of the
cheque is attached herewith as ANNEXURE-A for kind
perusal of this Hon'ble Court. Respondent no. 2 promised to
pay the balance amount after sometime to petitioner.

4. That the petitioner deposited the cheque in his Account

maintained at United Bank Limited, Depalpur Road Branch,
Okara.

5. That the abovesaid cheque was dishonoured on 12.10.2012.

Copy of the dishonour slip is attached herewith as
ANNEXURE-C for kind perusal of this Hon'ble Court.

6. That having knowledge of the dishonour of the cheques, the

petitioner agitated the matter before the accused/respondent
No.2 and demanded the return of his money, upon which the
accused/ respondent No.2 requested the petitioner for some
time and the petitioner accordingly given him some time. But
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unfortunately the accused/ respondent No.2 remained failed

to honour his commitment and dragging the matter on one
pretext or the other.

7. That the petitioner alongwith respectables of the vicinity,

approached and exerted pressure on accused/respondent
No.2, for return of the amount of Rs.________________/- to the
petitioner.

8. That a couple of days ago, the petitioner once again

demanded his money from the accused/ respondent No.2 but
instead of paying the same, he extended threats of the dire
consequences, to the petitioner.

9. That the petitioner immediately reported the matter to the

respondent No.1 who paid no heed to the genuine and lawful
grievance of the petitioner. Copy of the application is
attached herewith as ANNEXURE-D.

10. That the petitioner after submission of the application to the

respondent No.1, time and again, approached him and
requested for registration of the case against
accused/respondent No.2, but no heed whatsoever has so far
been paid by him to the request of the petitioner.

11. That the accused/respondent No.2, has committed

cognizable offence, so he is liable to be proceeded against.

12. That under Section 154 Cr.P.C, the respondent/ Station

House Officer is duty bound to register a case against the
accused/respondent No.2 under the relevant provisions of
law whenever an information regarding commission of a
cognizable offence is made out to him.

13. That the learned Apex Court vide its judgment reported as
2007 PLD SC 539 titled Bashir V/s SHO Okara has held
that on receipt of an information regarding the commission of
a cognizable offence, the S.H.O. of a Police Station is duty
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bound to register a case without conducting an inquiry in

respect of the same.
14. That the petitioner has no other adequate, efficacious and
speedy remedy available to him except to invoke the
constitutional jurisdiction of this Hon’ble Court.

In these circumstances it is most humbly and respectfully

prayed that the respondent No.1/Station House Officer, may kindly be
directed to register a case against the accused/respondent No.2, under the
relevant provisions of law, in the interest of justice, equity and fair-play.
Any other relief which may flow from the circumstances be also
awarded to the petitioner.

PETITIONER

Through:

Qazi Waqar Majeed

Advocate High Court

Irfan Aslam Rana

Advocate high Court

Imran A. Mian
Advocate High Court
DATED:- 31.01.2013.

LAWYERS CONSTELLATION
Head Office: 1st Floor Aiwan-e-Auqaf, The Mall Lahore
Branch Office: 20 – Usman Block New Garden Town Lahore

CERTIFICATE:
As per instructions, this is the first petition in this Hon’ble
Court, on the subject.
Advocate
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IN THE COURT OF LEARNED SESSIONS JUDGE/

JUSTICE OF PEACE, OKARA.

In re: Petition No._________/2013.

Saeed Ahmed
PETITIONER
Versus
Station House Officer etc.

RESPONDENTS

AFFIDAVIT of Saeed Ahmed Son of Shahid Rasool R/o Kot Noor-ul-Hassan

Karamat Khan, Haveli Lakha Tehsil Depalpur, District Okara

I, the above named deponent do hereby solemnly affirm and

declare as under:
That the contents of accompanying Petiton under Section 22-A
& 22-B Cr.P.C. are true and correct to the best of my knowledge and belief.

DEPONENT

VERIFICATION:
Verified on oath at Lahore, this 19 th April, 2011, that the
contents of above affidavit are true and correct to the best of my knowledge
and belief and nothing has been concealed therefrom.

DEPONENT
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IN THE COURT OF LEARNED SESSIONS JUDGE/

JUSTICE OF PEACE, LAHORE.

In re: Petition No._________/2011.

Muhammad Shafique.
PETITIONER
Versus

Station House Officer etc.

RESPONDENTS

INDEX

S. Description of Documents. Dated Pages

#
1. Petiton Under Section 22-A & 22-B 19.4.2011 1-6
Cr.P.C.
2. Affidavit. 19.4.2011 7
3. Annex-A & B – Cheques. --- 8-9
4. Annex-C – Dishonour Slip. --- 10
5. Annex-D – Application moved before --- 11
the SHO/respondent.
6. Vakalatnama.

PETITIONER

Through:

[MIAN MUHAMMAD YASIN]

LL.M.
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Advocate High Court,

Room No.11, Second Floor,
Shafqat Plaza, 13-Fane Road, Lahore.
DATED:- 19.4.2011.