Title: Seeking Justice: A Case Before the Session Judge in Malir, Karachi
In the Court of Session Judge/Ex-Officio Justice of Peace Malir at Karachi
Crl. Petition No. /2023
Name: [Your Name]
Son of: [Your Father's Name]
Muslim, Adult, Resident of: [Your Complete Address]
Petitioner
Versus
The Senior Superintendent of Police
District Malir, Karachi
The Station House Officer
PS: [Police Station Name], Malir, Karachi
Respondents
[Name]
Son of [Father's Name]
[Name]
Son of [Father's Name]
Proposed accused persons
PETITION UNDER SECTION 22-A CR.P.C
The petitioner, named above, most respectfully submits as follows:
1. That no criminal petition has been filed prior to this before in any court of law.
2. That the above-named petitioner is a law-abiding, peace-loving citizen and derives all fundamental rights under the Constitution of the Islamic Republic of Pakistan, 1973.
3. That the petitioner is residing at the above-mentioned address along with his family members.
4. That the proposed accused No.1 is the sitting Union Chairman, and the petitioner is regularly paying maintenance according to the terms and conditions of the Union for the purpose of cleaning. However, the proposed accused No.1 & 2 do not clean the petitioner's street as required.
5. That when the petitioner inquired from the proposed accused No.1 about the cleaning, he became very annoyed and started to use filthy language with the petitioner.
6. That when the petitioner resisted, proposed accused No.1 called the proposed accused No.2, who came there on the call and started to beat the petitioner, causing internal injuries.
7. That the above-named proposed accused persons did not even consider the petitioner's age and tortured him mercilessly without any justified reason.
8. That afterward, the petitioner moved applications to the respondents regarding the illegal act and conduct of the proposed accused persons through courier services, but no fruitful result came out. (Copies of Applications and courier receipts are enclosed herewith and marked as annexure “A” to “A/3”).
9. That there is no alternative remedy except to seek justice in this Honorable Court, where the petitioner files this instant petition and prays for legal action against the proposed accused persons.
10. That in these circumstances, the respondent/SHO has also shown negligence in his duty and violated the mandatory provisions of the law, depriving the petitioner of his fundamental rights. Therefore, the petitioner requests that action be taken against the proposed accused persons, and appropriate directions be issued regarding the commission of such offense.
11. That the incident took place within the local limits of [Police Station Name: AIRPORT], DISTRICT MALIR, KARACHI, which falls within the territorial jurisdiction of this Honorable Court, hence this Honorable Court is empowered to entertain the matter.
12. That other grounds shall be urged at the time of hearing of this application with the kind permission of this Honorable Court.
PRAYER
In view of the above facts and circumstances, it is most respectfully submitted that this Honorable Court may be pleased to pass the following orders:
(a) To direct the respondent No.2 to register an FIR against the proposed accused persons.
(b) Any other relief(s), which this Honorable Court may deem fit and proper.
Karachi
Dated: [Date]
ADVOCATE FOR PETITIONER
This petition before the Session Judge/Ex-Officio Justice of Peace in Malir, Karachi, serves as a testament to the importance of the justice system in upholding the rights and safety of law-abiding citizens. The petitioner seeks redress for an incident that has left them physically and emotionally injured, and the court now plays a crucial role in ensuring that justice is served.
