IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

W.P. No._____________/2002

1. Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o

Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District Multan.
Petitioner
VERSUS
1. The S.S.P. Multan.
2. The D.S.P. Jlalapur Pirwala, District Multan.
3. The S.H.O. P.S. Saddar, Jalalpur Pirwala, District Multan.
4. Muhammad Nawaz S/o Allah Bakhsh,
5. Nazir Ahmad S/o Allah Bakhsh
6. Saif-ur- Rehman Sons of caste Bhatti
7. Zia-ur-Rehman Muhammad Nawaz, R/o Chak No.
8. Ghulam Abbas S/o Nazir Ahmad 86-M Jalalpur,
9. Mst. Zubaida W/o Nazir Ahmad Pirwala,
10.Mst. Saima Batool D/o Muhammad Nawaz District Multan
11.Mst. Allah Wasai W/o Wahid Bakhsh

…….Respondents

Writ Petition under Article 199 of

the Constitution of Islamic
Republic of Pakistan, 1973.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
2. That brief facts giving rise to the instant petition are that Mst.
Humera Batool daughter of respondent No. 4 was married to
Muhammad Ramzan son of petitioner and in lieu of that, Mst.
Shazia, the daughter of the petitioner was married to one Saif-ur-
Rehman the son of the respondent No. 4 in May 2002. Due to
some altercation, the petitioner’s daughter Mst. Shazia was
expelled and she was also residing with the petitioner. In
retaliation, the respondents No. 4 to 11 tried to take away Mst.
Humera Batool, but she refused. The respondent No. 4 and his
wife Mst. Safia filed to fictitious and frivolous habeas petitions
before the Hon’ble High Court, Multan Bench. But both the
applications were dismissed on the statement of Mst. Humera
Batool. The respondents No. 4 to 11 were aggrieved and under
the same motive, on 13.3.2002 at about Maghrib Wela,
respondents No. 4 to 11 criminally trespassed into the house of
the petitioner, when the petitioner and his sons were not present
at home and were away in connection with Janaza prayer in the
neighbourhood. The respondents No. 4 to 11 tried to abduct Mst.
Humera Batool and on the resistance of Mst. Farhat Shamim and
Mst. Rukhsana Parveen, the wife and daughter of the petitioner
respectively, all the three ladies were given severe beating by the
male accused persons with Sotis and the female accused with fist
and kicks blows. On the hue and cry of the petitioner’s family
members, the witnesses Haji Abdul Satta and his son Muhammad
Siddiq the neighbourers attracted to the scene and save the wife
and the daughter of the petitioner from the clutches of
respondents No. 4 to 11. The respondents No. 4 to 11 also took
away Mst. Humera Batool by force and against her will. The
petitioner and his sons came back at Isha Wela and the matter
came into their knowledge.

3. That the petitioner informed respondent No. 3 at night, but there

was no response at all. On 14.3.2002, the petitioner submitted an
application to the respondent No. 2, on which the police referred
Mst. Farhat Shamim and Mst. Rukhsana Parveen for the
examination, but the doctor present in the hospital refused to
 examine both the ladies. The petitioner finding no other way,
submitted another application to the respondent No. 1 on
19.3.2002. In response of that, the petitioner’s wife Mst. Farhat
Shamim was examined only and Mst. Rukhsana Parveen was not
examined. Copies are attached as Annexes “A, B, C & D”.

4. That in the mean time, the other party approached the respondent
No. 3; and the respondent No. 3 in connivance with the other
party in collusion with each other, concealing the real facts and
instead of aggressive party, got registered a case F.I.R. No. 56 on
16.3.2002, under section 334/337Fi & 34 P.P.C. P.S. Saddar,
Jalalpur Pirwala on the statement of Mst. Allah Wasai, the
respondent No. 11. This respondent No. 11 is a midwife (Dai)
working at Rural Health Centre, Jalalpur Pirwala and was a cause
for non examination/late examination of the injured victims (wife
and daughter of the petitioner). Copy of F.I.R. is Annex “E”.

5. That even the Medical examination of Mst. Farhat Shamim, the

petitioner’s wife was conducted on the police request, but the
police is not going to register the case against the respondents
No. 4 to 11as per version of the petitioner mentioned.

6. That the respondents No. 1 to 3 are duty bound and under

statutory obligation to register a case on the receiving of
information of a cognizable offence as laid down in 154 Cr.P.C.
and Rule 24.5 (c) of Police Rules 1934.

7. That the petitioner is left with no other adequate, efficacious,

speedy and alternate remedy in these circumstances, except to
invoke the extra ordinary constitutional jurisdiction of this
Hon’ble Court.

Keeping in view the above-mentioned facts, it is

respectfully prayed that the respondents No. 1 to 3 may
please be directed to register a case record a cross
version against the respondents No. 4 to 11 and
 investigation may please be entrusted to some honest
and gazetted officer of the rank of D.S.P.

Any other writ, order, direction or relief which

this Hon’ble court deems fit, may please be extended in
the favour of petitioner to meet the ends of justice.

HUMBLE PETITIONER,

Dated: ___________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No. ______________/2002

Ghulam Fareed Vs. S.S.P. Multan, etc.

AFFIDAVIT of: -
Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o
Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-mentioned petition are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of April 2002 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 In re: C.M. No. _____________/2002
In
W.P. No.____________/2002

Ghulam Fareed Vs. S.S.P. Multan, etc.

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth: -
That certified copies of Annexures “ ” are
not available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
PETITIONER

Dated: __________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 In re: C.M. No. _____________/2002
In
W.P. No.____________/2002

Ghulam Fareed Vs. S.S.P. Multan, etc.

DISPENSATION APPLICATION.

AFFIDAVIT of: -
Ghulam Fareed S/o Wahid Bakhsh, caste Markand, R/o
Mauza Bet Ketch, Tehsil Jalalpur Pirwala, District
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-mentioned application are true and
correct to the best of my knowledge and belief
and nothing has been kept concealed thereto.
DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of April 2002 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No.____________/2002

Ghulam Fareed Vs. S.S.P. Multan, etc.

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form.
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit.
5 Copy of applications. A& B
6 Copy of M.L.C. C&D
7 Copy of F.I.R. E
8 Dispensation Application.
9 Affidavit.
10 Vakalatnama

PETITIONER
Dated: ____________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176