Harassment Petition Under 22-A and 22-B CrPC

Harassment Petition Under 22-A and 22-B CrPC
Crl. Misc. No:/2020
In Re:
Yasmeen Bibi wife of Muhammad Khan, resident of Gajar Dadi Chak LAle Bhawalnagar, Presently resident at Green Town Lahore
Petitioner
VERSES
1.Station House Officer (S.H.O) Police Station Green Town Lahore.
2.Station House Officer (S.H.O) Police Station District Bhawalnaghar.
3.Muhammad Ali son of Muhammad Bahir Resident Bhawalnaghar.
4.Shamim Bib wife Muhammad Ahmad Resident Bhawalnaghar
Respondents
PETITION UNDER 22-A & 22-B CRPC FOR ISSUANCE OF DIRECTION TO THE RESPONDENTS NOT TO HARASS THE PETITIONERS ILLEGALLY, UNLAWFULLY, IMPROPERLY IN ANY MANNER WHATSOEVER.
Respectfully Sheweth,
1.That the addresses of the parties are correct for issuance of summons/notices for this Honorable Court.
2.That the brief facts leading to the institution of present petition are that the petitioner married with Muhammad Khan son of Ali Share on 24.03.2020 with her own free will and consent according to the Islamic Rites and Rituals.
3.That the respondent No. 3 to 4 is relatives of the petitioner who are against the marriage of the petitioner and not happy with the knot of the petitioner, hence the petitioner contracted marriage with said Muhammad Khan son of Ali Share with her own free will and consent. Copy of Nikkah Nama and Affidavit is attached herewith.
4.That the respondents continuously extending threat of dire consequences and demanding to get divorce from her husband otherwise they will murder the petitioner.
5.That being aggrieved the petitioner approached to the respondents No. 1 to 2 and request them to give protection to the life of the petitioner and her husband but on the instigation of respondents No. 3 to 4 they refused to act in accordance with law and they started to say the petitioner to act upon according to the will of the respondents No. 3 to 4, otherwise they will not help the petitioner and they involve the petitioner and her husband in many cases of heinous nature.
6.That it is pertinent to mention here that the petitioner is major, sui juris and she left her parents’ house in three wearing cloths and not brought anything from her parent’s house and contract marriage with her own free will and consent which she did.
7.That no one can interfere into the peaceful and matrimonial life of the petitioner as she is living with her own free and according to law.
8.That the petitioner has no other efficacious and speedy remedy except to invoke the jurisdiction of the Honorable Court.
PRAYER:-
In the view of above submission, it is, therefore most respectfully prayed that the petition in hand may kindly be accepted and direction to respondents may kindly be directed not to harass the petitioner illegally and unlawfully in any manner whatsoever.
Any other relief which the Honorable Court may deems fit and proper may also be awarded.
PETITIONER
Through
CH. MUHAMMAD SHAHID BHALLI
Advocate High Court
Mob: 0301-6001125
VERIFICATION:
Verified on oath at Lahore, this 25th day of March 2020 that the contents of the above petition is true and correct to the best of knowledge and also correct to the best of my information and belief.
PETITIONER