BEFORE HONOURABLE SESSIONS JUDGE/
JUSTICE OF PEACE, ________.
COMPLAINT NO:____________________________/2013
1. _____
2. ___
DAUGHTERS OF ___, RESIDENTS OF HOUSE NO. ___, ______.
V E R S U S
STATION HOUSE OFFICER, POLICE STATION ___, _________.
C O M P L A I N T U/S 22-A(6)(I)
FOR ISSUANCE OF DIRECTIONS TO STATION HOUSE OFFICER, POLICE STATION ____, FOR REGISTRATION OF CRIMINAL CASE AGAINST THE ACCUSED PERSONS.
Respectfully Sheweth:
1. That through the instant complaint, the complainants humbly seek indulgence of this Honourable Court for issuance of direction to S.H.O., Police Station ___, for registration of F.I.R. against persons as mentioned below:
(i) ___
(ii) ____
(iii) Three unknown persons
(Hereinafter referred to as “the accused persons”).
2. That succinctly stated the facts giving rise to the filing of instant complaint are that the complainants are residents of residents of House no. ____,Block__,, Lahore; the complainants purchased the said house from their brothers. The possession of the house was delivered to the complainants after full payment of consideration money.
3. That on ___, the above mentioned accused persons illegally entered into the house of the complainants by breaking the locks of the doors; the accused persons also cut the window down. After trespassing into the house, the accused persons started torturing the complainants. They torn the clothes of the complainants and also stripped off the complainants and exposed them to half nakedness. The accused persons also caused damage and breakage of household things.
4. That a tentative assessment of the occurrence divulges that the accused persons have committed inter-alia following cognizable offences:
→ 149 P.P.C: Every member of unlawful assembly guilty of offence committed in prosecution of common object.
→ 347 P.P.C.: Wrongful confinement to extract property, or constraint to illegal act.
→ 354 P.P.C.: Assault or criminal force to woman with intent to outrage her modesty.
→ 452 P.P.C.: House trespass after preparation for hurt, assault or wrongful restraint.
5. That immediately after the occurrence, the complainants approached the concerned Police Station i.e. P.S. ___, however, no action was taken against the accused persons; on the contrary police officials misbehaved with the complainants. The complainants, thereafter, submitted an application to Capital City Police Officer, Lahore, for registration of case, who directed the concerned police officials to have the matter looked into, take appropriate legal actions on merit and report early, however, the concerned police officials paid no heed to the application of the complainants, on the contrary they have connived with the accused persons. Copies of application for registration of FIR submitted to SHO concerned and application submitted to CCPO Lahore are appended herewith for kind perusal of this Honourable Court as Annex-A & B.
6. That the accused persons have committed heinous cognizable criminal offences and they are liable to be prosecuted in the court of law and for that reason it is necessary that an FIR be lodged against them. Furthermore, concerned police officials including S.H.O. Police Station, ___ have also failed to do as they were required to do in their official capacity. Hence, it is indispensable that necessary directions be issued to S.H.O. for registering a criminal case against the accused officials.
P R A Y E R
In aforementioned circumstances, it is humbly prayed that instant complaint may kindly be accepted and the Respondent/Station House Officer,P.S.____ may graciously be directed to register criminal case against the accused persons.
COMPLAINANTS
Through
Advocate
It is certified that upon instructions of my client it is the 1st complaint u/s 22-A(6)(i) filed before this Honourable Court in the instant matter.
Advocate
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