22 b Application Draft

IN THE COURT OF DISTRICT & SESSESION JUDGE (EAST) AT KARACHI

Cr. M. A. No. /2024

…………

S/o Abdul Sattar Khan Muslim, Adult,

R/o House No. …….., Mohalla Khudadad Colony,

Shahrah-e-Quaideen,

Karachi

……………

S/o Abdul Sattar Khan Muslim, Adult,

R/o House No. …….., Mohalla Khudadad Colony,

Shahrah-e-Quaideen,

Karachi --------------------------------------------------- Applicant

VERSUS

The S.H.O

P. S: Brigade

Karachi.

S.S.P Complaint Cell

District East

Karachi

Ghulam Nabi, S/o Bashir

Moshin Ghulam Nabi,

S/o Ghulam Nabi

Liaquat Ali S/o Bashir

Muhammad Bilal, S/o Liaquat Ali -------------------Respondent(s)

Unknown Persons -------------------- Proposed Accused(s)

APPLICATION U/S 22-B OF THE CODE OF CRIMINAL PROCEDURE 1898

The applicant/Petitioner above named most respectfully submits as under:-

That above named applicant/Petitioner is a law abiding and peace loving citizen of Islamic Republic of Pakistan, who is residing at above-mentioned address.

That the applicant is working as a reputable employee in government services currently residing in Karachi with his family members.

That on dated 22-05-2024 around 12:45 am, Respondent No. 03, 04, 05 and 06 along with the proposed accused(s) armed with heavy weapons forcefully tried to enter into the premises of the house of the complainant and harassed the applicant and his family members.

That the Respondent No. 03, 04, 05 and 06 proposed accused(s) also threatened to harm the applicant and his family as well as extended the threats of lodging false FIR(s) and fabricating the applicant and his family members in the false cases.

That it is also pertinent to mention here that the following accused(s) persons armed with deadly weapons did Ariel and straight firing outside the premises of the house of the applicant.

(Annexure of the site of incident bullet empties )

The applicant being the peaceful citizen timely called on police helpline at 12:48 am from cell-phone No. ……….for immediate security and protection and within thirty minutes of this incident, Police helpline 15 Pol