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265k-application-20112024-101027am

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14 views

265k-application-20112024-101027am

Uploaded by

Uzma Gul
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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IN THE COURT OF REHAN ALAM, LEARNED ADDITIONAL

SESSIONS JUDGE RAWALPINDI

The State Versus Muhammad Zafran

FIR NO. 420/20 dated 01-01-2020 UNDER SECTION 302, 337H(II), 148,149 PPC
P.S WARIS KHAN, RAWALPINDI

APPLICATION UNDER SECTION 265-K CR.PC FOR


ACQUITTAL OF APPLICANT/ACCUSED

Respectfully Sheweth:

1. That the above mentioned case is pending adjudication before this Honorable Court and
fixed for today.
2. That the allegations leveled against the applicant are false, frivolous and ill founded.
3. That the applicant has not committed any offence mentioned in the FIR. Even he cannot
do the offence leveled against him as is suffering from many diseases. (Medial reports are
annexed)
4. That the petitioner is not nominated in the FIR rather he was nominated in supplementary
statement. Furthermore, no Identification Prade was conducted.
5. That no material exists on basis of which the applicant could be convicted. Continuation
of the trial against the applicant is exercise in futility and amount to waste the precious
time of this Honourable court.
6. It is therefore respectfully prayed that the instance petition may kindly be accepted and
the accused be acquitted from the charge

Applicant (Muhammad Zafran)


Through
Mehmood Alam
Advocate High Court
IN THE COURT OF NAVEED RAZA BUKHARI, LEARNED
ADDITIONAL DISTRICT JUDGE, RAWALPINDI.

In the matter of:

The State Vs Muhammad Sharif

CASE FIR NO. ____ DATED _______ U/S 302/324 PPC, P.S. SADIQABAD,
RAWALPINDI.

APPLICATION U/S 265-K Cr.P.C ON BEHALF OF ACCUSED

Respectfully Sheweth,

1. That the petitioner is accused in above mentioned case and the allegations
leveled against the accused petitioner are absolutely false, frivolous,
baseless, concocted in nature, having no truth whatsoever.
2. That a false and frivolous case has been lodged against the petitioner.
3. That the petitioner is facing agony of trial since his arrest, however the
prosecution badly failed to produce any evidence against the petitioner,
hence the petitioner is entitle for acquittal.
4. That even from the contents of the Challan, it is crystal clear that the
allegations against the accused petitioner were absolutely baseless and
charge against him is groundless and there is no chance of conviction of the
petitioner.
5. That even if all the witnesses incorporated in the calendar of witnesses are
recorded even then there is no probability of conviction of the accused
petitioner as there is no material available against the accused petitioner.
6. That both the ingredients of Section 265-K Cr.P.C are available in the case
in hand and further proceeding in the matter in hand would be merely a
futile exercise.
7. That it would be in the interest of justice to safe the precious time of this
Honorable Court by disposing of these types of frivolous cases through
application U/s 265-K Cr.P.C.
8. That in nutshell further proceedings in the matter in hand would only waste
the precious time of this Honorable Court.

Prayer
In view of above, it is most humbly prayed that by considering the application u/s
265-K in hand and taking into account the fact that the charge against the accused/
petitioner is groundless and there is no probability of conviction of the petitioner,
hence the petitioner may kindly be acquitted from the case in hand, in the interest
of justice.
Any other relief which this Honorable Court deems just and proper be awarded.

Petitioner
Through

Name of Counsel
Advocate High Court
Verification

Certified that as per information furnished by accused/ petitioner this is first


application on the subject ever moved before this Honorable Court.

Counsel

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