Sample Section 491 Application

IN THE COURT OF DISTRICT AND SESSIONS JUDGE AT KARACHI

EAST

CR. MISC APP. ______________/2024

[PETITIONER NAME]

S/O [FATHER NAME]

MUSLIM, ADULT, R/O

REHMAN COLONY GHAZALI ROAD

MAHMOODABAD FLAT NO. B-66

KARACHI………………………………………………….. PETITIONER

VERSUS

1. STATION HOUSE OFFICER

[POLICE STATION REDACTED]

SUB INSPECTOR

2. [RESPONDENT 2 NAME]

[POLICE STATION REDACTED]

3. S.S.P COMPLAINT CELL

[DISTRICT REDACTED]

KARACHI.

4. THE STATE ………………………………………………….. RESPONDENT

[DETENU NAME]

S/O MUHAMAMD BASHEER ……………………… DETENU

APPLICATION UNDER SECTION 491 OF THE CODE OF THE CRIMINAL PROCEDURE 1898

That the petitioner respectfully submits as under:-

That the petitioner is a respectful and law abiding citizen of the Islamic republic of Pakistan and the petitioner is a poor person residing at the above mentioned titled address along with his family

That the petitioner runs a family business of garments/ clothes and is the owner of a garment shop situated at [BUSINESS LOCATION REDACTED]. That the detenue is the real brother of the petitioner and on dated 21-12-2024 the petitioner along with the detenue was present at the shop when some unknown persons who claimed themselves to be the police officers dressed in police uniform along with respondent no.1 and respondent no.2 came to the shop of the petitioner and detenue and abducted kidnapped/ illegally arrested the brother of the petitioner and shifted him to P.S Awami Colony.

(Cctvs recording of the detenue being forcefully abducted by the respondent(s) is marked herewith as an annexure A)

That the next day respondent no.2 made a telephonic call to the petitioner and called him in the police station. Petitioner along with his father went to the police station Awami Colony. Upon arrival at the police station the petitioner was threatened by the respondent no.1 and respondent no.2 for grave consequences if the petitioner did not pay twenty five lac rupees to the respondent no.1 and respondent no.2 for the release of the detenue.

That it is pertinent to mention here that the detenue is being held illegally detained and being subjected to torture at the Awami colony police s