harassment petition format / draft

IN THE COURT OF LEARNED SESSIONS JUDGE/EX-OFFICIO JUSTICE OF PEACE, RAHIM YAR KHAN.

Sumaira  bibi w/o Muhammad Imran, Caste Khosa, r/o Tehsil & District Rahim Yar Khan.

……PETITIONER

Versus

  

1. The State.

2. S.H.O. Police Station Airport , Rahimyar Khan.

3. Ghulam Muhammad (Father of Petitioner).

4. Shokat s/o Ghulam Muhammad, Caste Darkhaan r/o Basti Amir Bux, Rahimyar Khan. (Brother of Petitioner)

5. Naveed, Hameed, Jameel, Amjad, Rasheed, Shahnawaz s/o Allah Wasaya, Caste Darkhaan, Tehsil Sadiqabad District Rahim Yar Khan. (Maternal Uncle of Petitioner).

......RESPONDENTS

APPLICATION UNDER SECTON 22-A/B Cr.P.C.

 READ WITH SECTION 25 Cr.P.C. FOR PROTECTION OF LIVES OF PETITIONER AND HER HUSBAND FROM ABOVE CAPTIONED PERSONS.

The Petitioner submits as under: -

1. That the Petitioner is a law-abiding citizen of Islamic Republic of Pakistan and is a person of profound sincerity and enjoying the prestigious and respectable status in the society.

2. That, succinctly, on 10.12.2019, the petitioner married with Muhammad Imran s/o Muhammad Saleem, Caste Khosa Baloch r/o chak 111/p tehsil & district Rahimyar Khan with her free consent. Afterwards she was residing in the house of her husband in tehsil Rajan Pur, on 30.12.2019, she was present at her home situated Long Colony Rajan Pur with her husband, Ilyas and Mitho sons of Hafeez, Caste Khosa, r/o KandayWali tehsil Sadiqabad alongwith Shokat Ali s/o Ghulam Muhammad, Caste Darkhaan, r/o basti Amir Bux tehsil Sadiqabad broke into her home with fire weapons. They dragged her from her home and tried to kidnap her in the meantime husband showed resistance than they aimed them with fire weapon, upon their hue and cry the witnesses namely Muhammad Saleem and Abdul Jabbar attracted to the place of occurrence, they seen whole of the occurrence by their naked eye. After that occurrence petitioner approached local police but they had not took any action against accused person due to this un professional behavior, she approached Learned Judicial Magistrate Rajan Pur and filed private complaint under section 200 CrPC under offences ----------- and recorded my statement on 01.012020. In result of aforesaid complaint accused persons approached honorable of vicinity they decided the matter amicably.    

3. That afterwards, petitioner along with her husband left the home and start resides in Rahim yar khan, on different occasion several persons visited us several times and harassed her and her husband upon instigation of father of petitioner named Ghulam Muhammad, brother Shokat s/o Ghulam Muhammad, Caste Darkhaan r/o Basti Amir Bux and my maternal uncles Naveed, Hameed, Jameel, Amjad, Rasheed, Shahnawaz s/o Allah Wasaya, Caste Darkhaan, Tehsil Sadiqabad District Rahim Yar Khan. 

4. On 03.03.2020 she was sitting in home with her husband at 8 pm. At that juncture, aforesaid her father, brother and maternal uncle came to her home in Rahimyar Khan and tried to broke into house with the intention of killing her, husband raised voice and said stop here I am calling the Police, consequently they left by raising threats of dire consequences. Application presented to Police, Police neither took any action nor give protection to the lives of complainant and her husband. Police officials are joining hands with the culprits and culprits are trying to harass husband to divorce her, petitioner is happy with her husband in her legal wedded relationship. Prior to this her father forced her to marry a man who is older than her father, therefore she left and married with abovementioned Muhammad Imran, now they are disturbing their life by using different means. Father of petitioner and maternal uncles killed her elder sister, she married with a boy by her free will after the marriage father approached her and took her to his home by convincing her in laws that we will rukhsat her from our house with honor but father killed elder sister and they are in same intention to do the same with petitioner. Life of petitioner and her husband is in danger; in fact Police is backing them.

5. That backing the culprits by the police, culprits are harassing petitioner and her husband. This will be of high import to mention here that the unprofessionalism and omission from obligation of the local police touched to its heights against the petitioner and her husband when petitioner said I would give application against Police.

6. That persons mentioned above bribed Police and Police is silent upon their illegal interference in life of petitioner. They raised threats to her husband to divorce me or otherwise to be ready to face dire consequences.

7. That the petitioner is an innocent citizen. Culprits have harassed petitioner and her husband. Police rather taking any action against culprits or making arrangement for the protection of lives of petitioner and her husband is silent spectator in this matter.

8. That it is an inalienable right of the Petitioner, which has been protected by the constitution of Pakistan, 1973 in its art. 4, which explicitly reveals that every person shall be dealt in accordance with law and by no other baton.

PRAYER: -

In the above circumstances, it is therefore respectfully prayed that direction may kindly be passed to Respondent no. 1 & 2 to protect the life of the petitioner and her husband moreover, take legal action against the culprits, otherwise petitioner along with her husband killed by the culprits.

Any other relief, which this Honourable Court thinks just, may also be ordered for the rederassal of the grievance of the petitioner.

PETITIONER

Through

Counsel:

Dated:  ___ March, 2020

SARDAR M. ADNAN AKHTAR CHANDIO

 Advocate High Court

NOTE:

As per information furnished by the Petitioner this is the first petition on the subject matter is being instituted before this Honourable Court. 

COUNSEL