COURT DAIRY (01-06-23 TO 11-08-23)

INTERNSHIP REPORT

UNIVERSITY OF MULTAN

BAHAUDDIN ZIKRIYA UNIVERSITY

GILLANI LAW COLLEGE
BY
JAVERIA TOOR
LLBSA-1901 (2019-2024)

SUPERVISED BY COORDINATED BY

ADVOCATE MASOOD ARIF BUTT DR. NAUREEN AKHTAR

1
 COURT DAIRY (01-06-23 TO 11-08-23)

INTERNSHIP REPORT

UNIVERSITY OF MULTAN

BAHAUDDIN ZIKRIYA UNIVERSITY

GILLANI LAW COLLEGE

UNDER THE GUIDANCE AND SUPERVISION OF

ADVOCATE MASOOD ARIF BUTT

ADVOCATE ON THE RECORD

DISTRICT AND HIGH COURT MULTAN

SUBMITTED TO SUBMITTED BY

DR. NAUREEN AKHTAR JAVERIA TOOR

INTERNSHIP COORDINATOR LLBSA-19-01

ASSISTANT PROFESSOR 2019-2024 (A)

2
 ACKNOWLEDGEMENT

First of all, I would like to express my gratitude to Almighty Allah to enabling me to

complete this internship report.
Successful completion of any type of report or project requires helps from a number of
persons. I have also taken from different people for the preparation of this report. Now, there is a
little effort to show my deep gratitude to those persons.
I convey my sincere gratitude to my senior associate “Advocate Masood Arif Butt,
Advocate High Court Multan”, who accepted me as an intern and helped me to complete this
internship report. Without his kind direction and proper guidance this internship would have been
a little success. In every phase of this internship, his supervision and guidance shaped this report
perfectly.
I would also like to express my special thanks to other senior associates Advocate
Shahzad Qaiser Dammar sb, Advocate Nighat Yasmeen Shiekh, Advocate Hafiza Rabia
Rasheed. All of them had supported me effortlessly and sincerely to complete my internship.
Secondly, I would like to express my gratitude to Associate Professor Dr. Samza Fatima,
Head of Department, Gillani Law College, B.Z.U. she established this internship program for law
students so they are able to succeed when they join practical field of law.
Thirdly, I would like to express my thanks to Assistant Professor, Dr. Naureen Akhtar,
Gillani Law College, as she being our internship coordinator, helped us maintaining our weekly
internship reports and fulfilling the objectives behind this internship.
Fourthly, I want to express my thanks to Syed Waheed Raza Bhukari, President Multan Bar
Association and Syed Ali Altaf Gillani, secretary Multan Bar Association. They gave
opportunity and acceptance to the new students as intern so that the new lawyers can meet the
demands of the changing society.
In the end, I would like to express my thanks to my parents and friends who helped me a
lot in finishing this internship within the limited time. Just because of them, I was able to create
my internship report and make it good and enjoyable experience due to their financial and mental
support.
Thanking again to all who helped me during this whole internship.

3
 DECLARATION

The declaration is made regarding the internship report which has been prepared and
drafted by Javeria Toor under the supervision of Advocate Masood Arif Butt, Advocate on
Record at District Courts and High Court Multan, Seat No. 129 & 130, Arif Law Associates,
District Court Multan, +923009631600. It contains the work accomplished during the internship
which was assigned during the internship with reference to Letter No. ULCD-404/Law, Dated
29.05.2023. This work was done in respect of the partial fulfillment of the requirement for the
award of degree of L.L.B.
This internship report has not been submitted either in whole or in part to any other Law
University or affiliated Institute under the University of Multan, Baha Uddin Zakariya University,
recognized by the Bar Council of Pakistan for the award of any Law degree or diploma within the
territory of Pakistan.

Javeria Toor Dated: August 15, 2023

2019-2024, Section-A
Roll No. LLBSA-19-01
Gillani Law College
Baha Uddin Zakariya University
University of Multan

4
 ARIF LAW ASSOCIATES
Masood Arif Butt Ref No._______
DTL-DLL-DSL-LLB Date _________
Advocate High Court

INTERNSHIP CERTIFICATE
TO WHOMSOEVER IT MAY CONCERN
This is to certify that Ms. Javeria Toor, daughter of Asghar Ali Toor, regular 4th year
student of L.L.B., studying in Gillani Law College, BZU, Multan University, Roll No.
LLBSA-19-01, session 2019-2024, section A has worked with Advocate Masood Arif Butt, as
an intern during the months of June, July and August 2023 (w.e.f. 01st June, 2023 to 11th
August, 2023). During this period, she actively participated in the team working on cases.
In tenure of her internship, she dealt with all family matters\disputes as well as some
of the criminal matters and has attended court proceedings on daily basis. During her
internship, she was found to be punctual, well dressed as an advocate, and had oriented
performance.
She is diligent competent, hardworking, disciplined, and enthusiastic worker. I have
found her receptive of new ideas and concepts which she adopts and absorbs effortlessly. I am
impressed by her communication skills, both verbal and written as well as her desire to learn.
She has contributed positively as a valuable member of team in the varied discussion by
combining logic and initiative. She works well in a team and has the ability to get along with
different people. Her ability to settle comfortably within this period and work with dedication
is impressive. She will be an asset to any organization that she will work in future. Our best
wishes are with her in her career and academic pursuit.

Advocate Masood Arif Butt

Advocate High Court, Multan
_________________________________________________________________________________________________
Seat No. 129 & 130 Distt. Courts office: Rex Multiplex
Multan, +923009631600 O\P GPO Multan

5
 INTRODUCTION

Clinical education program for law students have been available for many years in some
Pakistan Law Schools. The objective of such programs is to provide an understanding of the
human, social & policy contexts of Law and legal practice.
Internship fulfill an important component of both academic and practical education in law.
The integration of professional experience into the learning process is highly effective in
developing your understanding of law in actions, as you are able to observe and perceive the
relevance and application of theoretical law to practical law. Consequently, the program is not
simply ‘work experience’ but a significant educational experience.
In a workspace setting you will be exposed to the reality of the practice of law in all its
dimensions – the integration of different areas of law, policy issues; the application and
development of skills to analysis and resolution of client concerns; ethical responses to situations
which arises unexpectedly and spontaneously; issues of professional responsibility including
responsibility to clients and case management; and the operation of government and court system
in legal process.
the inception of LLB program at the Gillani Law College, Baha Uddin Zakariya University
Multan, a practical experience component i.e., internship has been part of the compulsory subject
and thus of the LLB degree. The Legal Internship Program is not designed to teach students how
to be good lawyers (or how to be lawyers at all) it takes more than study at university to do that.
The objectives are to
• Expose you to the law in operation in contexts where you will come to perceive aspects of
law which cannot be learned from reading or hearing about it.
• Allow you to perceive ways in which the formal learning you acquire at university may be
applied in practice and thereof to develop an application of the practical dimensions of
legal principles;
• Enable you to relate the different areas of legal practice to the importance of developing
the skills of legal research, communication, drafting, practice management and problem-
solving; and
• Enable you to observe and reflect upon the values, ethical standards and conduct of the
legal profession in practice and to develop your own attitudes of professional responsibility.
The classroom study and practical training in the field of law is considered as two sides of coin.
The legal profession is one of the professions which are considered incomplete without the
practical training. An additional benefit of the internship program is that it provides you with an
opportunity to observe the way in which law operates in practical milieu, and so may assist you in
making future career choices.

6
 DAILY BASIS COURT WORK
Dates Work Done Learning
01-06-23 Marking attendance of our party in daily case list in How to find cases
courts mentioned in daily
dairy and find them
in the daily case list
shown outside the
court and to mark
attendance in court
by telling the
respective READER
in that specific court
02-06-23 Maintaining daily dairy + location of different courts, How to maintain
office of clerks etc. daily dairy
Noting down the
respective dates
given for daily cases
in diary
03-06-23 General proceedings of a family suite ‫دائری‬
‫اخبار اشتہار‬
‫سمن اگر مدعا علیہ پیش ہو‬
‫جائے تو مصالحت کی‬
‫پیشی ڈال دی جاتی ہے ۔‬
‫اور اگر مصالحت ناکام ہو‬
‫ جائے تو پھر‬evidence
‫کے لیے رکھ دیا جاتا ہے۔‬
‫اگر مدعا علیہ پیش نہ ہو تو‬
‫ثبوت یکطرفہ کی پیشی‬
‫ڈال دی جاتی ہے ۔‬
04-06-23 ….Sunday… ………
05-06-23 How to deal with clients Noting down facts by
putting different
questions to the
clients
And collecting
different documents
required for the filing
of the suite
06-06-23 Draft sample of ‫دعوی دالپانے خرچہ نان و نفقہ‬ Drafting suite for
‫دعوی دالپانے حق المہر‬ maintenance and
dower
07-06-23 Draft sample ‫دعوی دالپانے واپسی سامان جہیز‬ Drafting of suite for
‫دعوی تنسیخ نکاح‬ dowry articles

7
 Drafting suite for
dissolution of
marriage
08-06-23 Draft sample ‫دعوی اعادہ حقوق زن آشوئ‬ Drafting suite for
restitution of
conjugal rights
09-06-23 Draft sample ‫مرمع کے لیے درخواست‬ Drafting application
‫بیان حلفی‬ for amendment in a
suite and affidavit
10-06-23 ‫وارنٹ گرفتاری بال ضمانتی‬ Proceedings for
‫عبوری ضمانت‬ availing interim and
‫روبکار بنوانا‬ pre-arrest bail and
NBW
11-06-23 Draft sample habeas corpus u\s 491 CRPC Drafting of habeas
corpus, what are the
facts involved in
drafting
12-06-23 489F PPC +CAST STUDY (state v Zeeshan) Studied amendment
of 489F PPC
Studied and prepared
final arguments for
the case “state vs.
Zeeshan”
13-06-23 Draft sample pre-arrest bail Drafting pre-arrest
bail
And understanding
the section involved
in pre-arrest bail and
facts involved
14-06-23 Draft sample post-arrest bail Drafting post-arrest
bail
Understanding the
provision involved
Facts involved
15-06-23 ‫حسینہ مائی۔ بنام۔۔ محمد اکرم‬ Filed a family suite
(Family suits filed) by completing the
‫سمیرا رمضان۔ بنام مرید حسین‬ documents
In court Compromise between parties in family In court compromise
disputes had taken place
between the parties
and case withdrawn
16-06-23 1- ‫ثمرین ارشاد وغیرہ۔ بنام۔ محمد طارق‬ Non-bailable
Non bailable arrest warrant submitted in the court of law warrant form filing
2- ‫راحت عابد۔ بنام۔ محمد سہیل‬ Sending summons
Summons to defendant (M. Sohail) has been sent through through UMS and
UMS affixed the receipt of

8
 UMS on a blank
paper for submission
in the court
17-06-23 Habeas petition under 491 CRPC for the recovery of minors Drafting of habeas
Naseem Bibi vs. SHO Police station Gulgasht petition for the
recovery of minors.
Facts involved
18-06-23 …Sunday…….. …………
19-06-23 ‫الئبہ ظفر بنام۔ محمد ثاقب‬ Filed a family suite
Filed family suit for dissolution of marriage for dissolution of
‫نسرین۔ بنام۔ محمد اسلم‬ marriage
‫بال ضمانتی وارنٹ گرفتاری جمع کروائے‬ Non-bailable
warrant submitted in
the court
20-06-23 ) ‫دعوی دالپانے سامان جہیز‬
ٰ ( ‫حنزہ سبحانی۔۔ بنام۔ فرزند علی‬ Filed suite for the
‫رحمت مائی۔ بنام۔ محمد یعقوب‬ restitution of
‫دعوی اعادہ حقوق زن آشوئ‬
ٰ ( conjugal rights

21-06-23 Sidra Maqsood vs. Muhammad Adeel (family suit for Filed suite for the
dissolution of marriage and family suit for recovery of dissolution of
dowry articles) marriage and
recovery of dowry
articles
22-06-23 ‫شمیم بی بی۔ بنام۔ غالم محمد ( بیان حلفی بنایا‬ Drafting of affidavit
‫ثبوت یکطرفہ‬/ and ex-party
Bushra Bibi vs. Faisal (conciliation) ‫مصالحت‬ evidence
Asia Bibi vs. Muhammad Usman ( )‫ثبوت یکطرفہ‬/‫بیان حلفی‬
23-06023 ‫زیتون بی بی۔ بنام۔ اعجاز حسین‬ Case reported to
‫رپورٹ ایلمد‬ almad
Laiba Zafar vs Muhammad Saqib ( notice ) Notice to defendant
24-06-23 Masooma Nazir vs. Shehroz Saleem (family suite Filed for Filed family suite for
dowry articles) recovery of dowry
Irsa Naaz vs. Muhammad Ramzan (report to almad that the articles
case has been decided)
25-06-23 …Sunday……….. ……..
26-06-23 Kalsoom Bibi vs. Muhammad Ishfaq ‫مصالحت‬ Conciliation
‫محمد ندیم‬ ‫عائشہ بی بی۔ بنام۔‬ between parties has
‫ دستاویزی شہادت‬+‫ثبوت یکطرفہ‬ been failed
Documentary
evidence has been
submitted in the
court
27-06-23 Rukhsana Bibi vs. Muhammad Saghir NBW submitted
Non bailable arrest warrant submitted to almad
28-06-23 EID ……
29-06-23 HOLIDAYS …..
30-06-23 FROM 28th June, 2023 …..
9
01-07-23 TILL …..
02-07-23 2ndJuly,2023 …...
03-07-23 )‫محمد رمضان بنام ثناء۔ (حضانت‬ Conciliation has
‫مصالحت‬ been failed between
the parties
04-07-23 )‫سعدیہ بنام محمد کامران (نان و نفقہ‬ Conciliation has
‫مصالحت‬ been failed
05-07-23 ‫سندس نواز بنام اظہر حسین‬ Advertisement in the
)‫اخبار اشتہار (اعالن ملتان‬ newspaper
06-07-23 ‫حسینہ مائی بنام محمد اکرم‬ Compromise done
‫دعوی واپس شد۔۔۔۔۔۔‬
ٰ between the parties
Out of court Compromise done Case withdrawn
07-07-23 ‫شائلہ بی بی بنام محمد علی‬ Non-bailable
NBW warrant
‫فوزیہ رانی بنام محمد احمد‬ Advertisement in the
‫اخبار اشتہار نان و نفقہ‬ newspaper
08-07-23 ‫ساجدہ بی بی بنام محمد اقبال‬ Advertisement in the
)‫اخبار اشتہار (آفتاب‬ newspaper
09-07-23 ……..Sunday…… …….
10-07-23 ‫حنزہ سبحانی بنام فرزند علی‬ Advertisement in the
)‫اخبار اشتہار (روزنامہ اسالم‬ newspaper
‫علیشہ بنام ایس ایچ او‬ Filed habeas petition
Habeas petition under 491 CRPC
11-07-23 ‫ّٰللا نواز‬
‫نصرت فاطمہ بنام وغیرہ بنام ہ‬ Advertisement in the
‫ایکسپریس اخبار اشتہار‬ newspaper
12-07-23 )‫سائرہ بنام ارشاد (گارڈین‬
‫شہادت‬
13-07-23 ‫فرخندہ شاہین بنام عبد الصبور‬
BW
14-07-23 ‫فوزیہ بی بی بنام حیدر سلطان‬
‫اجراء وارنٹ‬
15-07-23 ‫رانی انجم بنام محمد شیخ‬
‫اجراء ادائیگی‬
16-07-23 ………….Sunday……….
17-07-23 Sofia etc. vs SHO etc. (harassment petition under 22-A)
Farzana Bibi vs. Javed etc. Ex-party ... (Family suit)
18-07-23 Sajida Bibi vs. Ibrahim NBW
19-07-23 Habeas petition under section 491 CRPC (Sofia vs SHO
cantt)
20-07-23 Akeela Shehzadi vs. Nazir Ahmed (maintenance) ‫ثبوت‬
‫یکطرفہ‬
21-07-23 ‫طاہرہ بتول بنام اطہر حسین‬NBW
‫خدیجہ بنام ابوبکر۔ وارنٹ گرفتاری جمع کروائے ایلمد کے پاس‬
22-07-23
Shamim Bibi vs. Muhammad Sajid maintenance (final
arguments)

10
23-07-23 ……..Sunday,…….
24-07-23 Sundas Nawaz vs. Azhar Husain
Newspaper (Aelaan Multan)
25-07-23 )‫رقیہ بی بی بنام حنیف (نان و نفقہ‬
‫عبوری خرچہ‬5000/-
26-07-23 )‫دعوی‬
ٰ ‫شائستہ بنام محمد ساجد (جواب‬
27-07-23 Holidays
28-07-23 For 9th and 10th and 11th
29-07-23 Muharam
30-07-23 ………….Sunday……………….
31-07-23 ‫پروین وغیرہ بنام محمد حنیف‬
)‫اخبار اشتہار آفتاب (نان و نفقہ‬
01-08-23 State vs. Muhammad Zeeshan (462-J)
Decided case bail confirmed. accused acquitted
02-08-23 State vs Malik Kashif 462J pre arrest bail arguments
03-08-23 Pre arrest bail draft before arrest pre arrest bail during
investigation
04-08-23 Post arrest bail draft
05-08-23 Habeas petition draft
06-08-23 ………..Sunday……….
07-08-23 Protection order draft
08-08-23 FIR challan report...
09-08-23 ‫حاضری معافی کی درخواست‬
10-08-23 ‫درخواست لکھنے کا طریقہ‬FIR ‫درج کروانے کے لیے اس‬
11-08-23 Application for creating medical board
‫درخواست برائے کروائے جانے ڈاکٹری مالحظہ‬

11
 INDEX
S.NO. WORK
PAGE
NO.
1. Title page 01
2. Acknowledgement 02
3. Declaration 03
4. Internship certificate 04
5. Introduction 05
6. Table of daily court work 06
7. Index 11
8. PART-I STUDY OF SOME CASES 14
9. Mashal Gulzar etc. Vs Fahad Hussain 15
10. State vs Zeeshan (pre-arrest bail in 462J PPC) 18
11. PART-II DRAFTED DOCUMENTS 24
12. Family suite for maintenance 26
13. Family suite for dower and dowry articles 28
14. Family suite for dissolution of marriage 30
15. Written statement for dissolution of marriage 32
16. Family suite for restitution of conjugal rights 34
17. PRE-ARREST BAIL U\S 498 CRPC 37
18. POST-ARREST BAIL U\S 497 CRPC 38
19. PETITION U/S 497(5) Cr.P.C. FOR THE 42
CANCELLATION OF BAIL
20. HABES PETITON U\S 491 CRPC 45
21. Writ petition Under Section 22 /A ,22 / B cr.p.c for the 51
registration of a criminal case
22. APPLICATION FOR STAY OF SUIT U\S 10 CPC 55
23. APPLICCATION U\S 12(2) READ WITH SECTION 57
151 CPC
24. PAT-III PICTURES OF SOME FORMS USED IN 59
COURT
25. F.I.R. 62
26. CHALLAN FORM 63
27. ‫روبکار‬ 65
28. ‫وکالت نامہ فوجداری‬ 67
29. Charge sheet 69
30. Death Registration Certificate 71
12
‫‪31.‬‬ ‫‪FRC‬‬ ‫‪75‬‬
‫‪32.‬‬ ‫عبوری ضمانت فارم‬ ‫‪78‬‬
‫‪33.‬‬ ‫مچلکہ و ضمانت نامہ واسطے حاضری عدالت‬ ‫‪80‬‬
‫‪34.‬‬ ‫وارنٹ گرفتاری‬ ‫‪81‬‬
‫‪35.‬‬ ‫فرد طلبانہ‬ ‫‪82‬‬
‫‪36.‬‬ ‫درخواست اجرا ڈگری‬ ‫‪83‬‬
‫‪37.‬‬ ‫پتہ فارم‬ ‫‪84‬‬
‫‪38.‬‬ ‫فہرست دستاویزات پیش کردہ‬ ‫‪85‬‬
‫‪39.‬‬ ‫فہرست دستاویزات پیش کردہ منحصرہ‬ ‫‪86‬‬
‫‪40.‬‬ ‫ڈائری فارم‬ ‫‪87‬‬
‫‪41.‬‬ ‫وکالت نامہ مختار نامہ‬ ‫‪88‬‬
‫‪42.‬‬ ‫نکاح نامہ‬ ‫‪89‬‬
‫‪43.‬‬ ‫سمن‬ ‫‪94‬‬
‫‪44.‬‬ ‫نوٹس‬ ‫‪95‬‬
‫‪45.‬‬ ‫اقرار نامہ ثالثی نامہ‬ ‫‪96‬‬
‫‪46.‬‬ ‫‪CDI form‬‬ ‫‪97‬‬
‫‪47.‬‬ ‫شیڈول گواہان‬ ‫‪98‬‬
‫‪48.‬‬ ‫‪FINAL INTERPRETATION‬‬ ‫‪99‬‬

‫‪13‬‬
 INTERNSHIP REPORT
(01-06-23 to 11-08-23)
As per my internship report, I may classify my internship diary into following components i.e., (1)
family cases
(2) habeas petitions
(3) criminal cases
(4) civil cases
(5) drafting of documents (miscellaneous applications, petitions, etc.)
DAILY INTERNSHIP DUTIES
1. I was assigned to read minimum of four case files to learn how files are maintained and how
the records are maintained.
2. I was assigned to observe the proceedings during the Examination-in-chief, Cross Examination
and Final Arguments.
3. Supporting the lawyers that come into the office and programs. Sitting in on meetings and
appointments and offering required assistance.
4. Office type organizational work – photocopying, organizing papers, keeping files in order,
organizing the desk.
5. Reading any suggested law related materials for my own benefit.
6. Helping clients if possible and if I am able to since I don’t know much about the field yet.
7. Interacting to various lawyers in our office.
8. Research on judgments that are related to facts of case.

14
15
MASHAL GULZAR VS FAHAD HUSSAIN
Mashal Gulzar and Ayeza Fahad ……….. Plaintiff
Fahad Hussain…………………………….Defendant
SUITE: MAINTENANCE, DOWER AND RESTITUTION OF CONJUGAL
RIGHTS
INSTITUTION OF SUITE: 27TH March, 2023
COURT: In the Court of Muhammad Rizwan, Senior Civil\Family Judge, Multan
DATE OF DECISION: 07-06-23

FACTS OF THE CASE:

The brief facts of the case are as under:
1. Plaintiff no.1 (Mashal) is the real mother of plaintiff no.02 (Ayeza)\minor. She has no
interest adverse to that of the minor. And she has filed this suite on her behalf.
2. Nikkah has been solemnized between plaintiff no,01 and defendant on 24-04-2019 in
accordance with the sharia and in lieu of dower of Rs.5000/-, 02-tola gold ornaments and
02-marla plot alongwith house. and Rukhsati took place on 03.05.2019; that it was settled
that defendant would pay the aforesaid dower at the time of Rukhsati but not pay the same;
that behavior the defendant with her remained good for two months and subsequently,
family members of defendant started to tease her; that since plaintiff No.1 belonged to
well-off family as her father was a driver in Dubai, therefore, defendant side used to
demand money from her, that once defendant demanded plaintiff No.1 to ask her father to
take him Dubai and on her refusal to do so, he started to torture her and expelled her
alongwith minor in three wearing apparels.
3. The plaintiff No.1 was given substantial dowry articles of Rs.1,651,200/- at the time of
Rukhsati by her parents, which were still in the possession of defendant; that defendant
was carrying on the business of sale & purchase of mobile accessories at Afzal Electronics,
as such earned rupee 80/90 thousands per month, therefore, he could easily pay
maintenance @ Rs 15,000/- per month to each plaintiff, that the defendant was asked time
and again to get her Abad and acceded to the claims of the plaintiffs, but he refused to do
so, therefore, instant suit was filed.
4. Defendant did not appear despite issuance of process through different means, therefore,
he was proceeded against ex-parte.
5. Thereafter, in her ex-parte evidence, the plaintiff No.1 has filed her affidavit in evidence as
Exh.P.1, while Shah Zaman appeared as PW-2 and filed his affidavit in evidence as Exh.P.2

16
 in support of version of the plaintiff. In documentary evidence, plaintiff No.l tendered copy
of her Nikahnama with defendant as Exh.P.3, original list of dowry articles as Exh.P.4 and
closed her evidence.

ORDER:
It is ordered that:
"The suit of the plaintiffs is hereby decreed in the following terms: -
i. Plaintiff No.1 is entitled to maintenance @ Rs. 10,000/- per month six months prior to
the institution of this suit to onward with 15% annual increase at basic till the expiry of
her Iddat period, while minor plaintiff No.2 is entitled to maintenance @ Rs.7000/- per
month six months prior to the institution of this suit to onward with 15% annual
increase at basic till her legal entitlement.
ii. Plaintiff No.1 is entitled to recover dower of dower of 02-tola gold ornaments and 02-
maria plot alongwith constructed house (as mentioned in the Nikahnama/Exh.P.3) and
Rs.5000/- from the defendant.
iii. Plaintiff No.1 is entitled to recover dowry articles excluding makeup items, 04-tola
gold ornaments and 20 fancy costumes, as mentioned in the list/Exh.P.4; or in alterative,
she is held entitled to 88% of Rs.771,200/-, the value of decreed articles from the
defendant.
iv. She is entitled for the restitution of conjugal rights.

GENERAL OBSERVATION IN ANY FAMILY CASE

In a family case\suit, suite is filed by writing a plaint that revolves around the facts in detail
which client has given us. The number of forms and sequence of forms are as under that are used
in almost every family suit;
1. Copy of CNIC of client\ colored picture of client
‫شناختی کارڈ کی کاپی‬
2. Copy of license of lawyer\pleader
‫وکیل کے الئسنس کی کاپی‬
3. ‫دائری فارم‬
4. Original plaint
5. ‫پتہ فارم‬
6. ‫شیڈول گواہان‬
7. ‫فہرست دستاویزات پیش کردہ‬
8. ‫وہ تمام ڈاکومنٹس جو ہم اپنی پلینٹ کے ساتھ جمع کروائیں گے وہ پیش کردہ کے بعد لگتے ہیں‬
‫جیسے کہ نکاح نامہ کوئی ڈلیوری چارجز کی سیٹ ہاسپٹل سے‬
9. ‫فہرست دستاویزات پیش کردہ منحصرہ‬

17
10. ‫مختار نامہ‬
11. ‫فرد طلبانہ‬
12. ‫تین عدد سمن تنقیح طلب بنام مدعا علیہ‬
13. ‫لفافہ رجسٹری و رسید‬
14. ‫عرضی دعوی کی کاپی‬/ ‫پلینٹ‬

When a family suit is submitted in the ‫ فیملی دائری برانچ‬for filing of suit. That branch sends
family suit in any one of the available family courts\civil courts with a specified date of
hearing. And forward that whole file to that respective court. That respective court declares a
name of specific newspaper in which the plaintiff has to put advertisement that this case has
been filed against defendant\s in that respective court. The plaintiff is bound to present that
specific newspaper by advertising the title of suit on the first date of hearing. The purpose of
this newspaper advertisement is to make defendant/s aware that some kind of suit is filed
against them, so they may appear on time.
First set of summons is send through court to the defendant\s. If defendant doesn’t appear
in the court of law, second time summon is send through the plaintiff herself through any of
the courier or post services and the receipt of such service is submitted in the respective court
on specific date of hearing. If the defendant\s appears and present his written statement and
POA of his lawyer, the court fix a date of hearing for conciliation between the parties. If the
conciliation works, the case is disposed of with or without any kind of ‫اقرار نامہ ثالثی نامہ‬. If the
conciliation is failed between the parties, the court further proceed the case and fix the suit for
evidence and further proceedings take place.
On the other hand, if the defendant\s failed to appear even after sending summon, the court
shall proceed towards the ex-parte evidence. And then if still defendant does not appear, the
court may pass ex-parte judgement against the defendant\s.

18
THE STATE VS MUHAMMAD ZEESHAN

19
CASE NO. 2\22
P.S. DELHI GATE, MULTAN
OFFENCE. 462J PPC
DATED: 05-01-22

ACCUSED : MUHAMAD ZEESHAN QURESHI, S/O, MUSHTAQ QURESHI

ALLEGATION : ACCUSED HAS REVERSED THE METER, AND INVOLVED IN

THE THEFT OF ELECTRICITY

‫مذکورہ شخص نے محکمے کے میٹر بجلی کو ریورس کیا ہوا تھا اور میٹر کو ریورس کر کے بجلی‬
‫چوری میں ملوث پایا گیا ہے‬
462 ‫بجلی چوری اور محکمے کو مالی نقصان پہنچانے پر الیکٹرک سٹی ایکٹ ترمیم آرڈیننس‬J 39-A
‫کے تحت ایف ائی ار درج کر کے گرفتاری عمل میں الئی جائے اور ایف ائی ار کی نقل محکمہ کو مہیا‬
‫کی جائے‬

NAME OF WITNESSES :
1. JAMSHAI IQBAL (MP, METER INSPECTOR)
2. TAJAMAL HUSSAIN (MR, METER READER)
3. M. ISHFAQ (LM, LINEMAN)
4. MUHAMMAD MASOOD KHAN (MXT REPRESENTATIVE)
5. UMAR FAROOQ 1562/HC
6. M. YOUSAF SDO
7. MUSHTAQ AHMED SI

PROPERTY OF CASE :
ELECTRICITY METRER THAT HAS BEEN REVERSED

20
PROCEEDINS OF THE CASE :
First of all, my senior has filed pre-arrest bail (dated: 08-05-23) of accused Muhammad Zeeshan
Qureshi, s/o, Mushtaq Qureshi on the following grounds;
1. That the petitioner is innocent and local police has involved the petitioner falsely.
2. That the story of FIR is highly doubtful.
3. That the local police have involved the petitioner with malafide and ulterior motives.
4. That there is no evidence on the record.
5. That the petitioner is not residing on that address.
6. That the petitioner belongs to noble family and previously does not hold any criminal
record.
7. That the allegation does not fall in prohibitory clause.
8. That the local police want to arrest the petitioner, which can damage the reputation of the
petitioner permanently.
9. That the petitioner is ready to submit the surety bonds for the satisfaction of the court.

Charge is framed on 15-12-2022.

05-01-23………….accused not plead guilty and called for trial. Court proceed towards
prosecution evidence.
CHIEF EXAMINATION BY PROSECUTION:
PW1 : JAMSHAID IQBAL MI
PW2 : M. ISHFAQ LM-1
PW3 : UMAR FAROOQ HC
PW4 : M. YOUSAF SDO
PW5 : MUSHTAQ AHMED SI

CHIEF EXAMINATION
PW1 and PW2 given following similar statements in their chief examination:
1. On 05-01-22 checking team consisting of PW1, PW2, Muhammad Masood Khan MXT
REPRESENTATIVE, Tajamal Hussain MR checked the meter reading (acc. No:
10.15733.0623702), that is registered in the name of Shabbir Ahmed and under the use of
accused\ Zeeshan Qureshi.
2. During checking, It is found that the accused has committed the theft of electricity by
“reversing of meter”.

21
 3. Team removed the meter no# 005178PEL.P1, through recovery memo Exh.PA which bears
my signature as Exh.PA/1.
4. The whole matter was reported to SDO.
5. SDO drafted complaint Exh.PB
6. Complaint was sent to police station for the registration of FIR.
7. IO recorded our statements u/s 161CRPC
8. Prepared rough site plan on our statements.

PW3 gave the following statements in his chief examination:

1. 05-01-22 moharir police station Delhi Gate
2. Received complaint Exh.PB sent by SDO, Pak Gate
3. In view of said complaint, FIR no. 2/22 is generated as Exh.PC
4. Exh.PC Bears my signature as Exh.PC/1
5. FIR was registered without any deletion or omission
PW4 gave the following statements in chief examination:
1. Checking team went to the checking meters on 05-01-22, comprising of following
members; SDO Masood Khan, MI Jamshaid Iqbal, LM Ishfaq, MR Tajamal Hussain.
2. Checked the meter (acc. No. 10.15733.0623702), that is registered in the name of Shabbir
Ahmed and under the use of accused\ Zeeshan Qureshi.
3. During checking, It is found that the accused has committed the theft of electricity by
“reversing of meter”.
4. Team removed the meter no# 005178PEL.P1, through recovery memo Exh.PA which bears
my signature as Exh.PA/1.
5. The whole matter was reported to me.
6. I drafted the complaint Exh.PB, which bears mhy signatures as Exh.PB/2.
7. Sent the complaint to P.S.
8. IO interrogated me, recorded my statement of witness u/s 161 CRPC
9. Prepared the site plan
PW5 had given the following statements in the chief examination;
1. On 05-01-22, after lodging of FIR, I was designated as IO
2. Proceeded towards the place of occurrence along with the WAPDA witnesses and
complainant
3. Recorded their statements u/s 161 CRPC
4. Prepared rough site plan as Exh.PD, which bears my signatures as Exh.PD/1
5. 24-01-22, accused joined the investigation, while he was on pre-arrest bail, an found him
guilty
6. 25-01-22, Learned ASJ Multan, confirmed pre-arrest bail of accused
7. Challan u/s 173 CRPC was also submitted under the same date

22
CROSS EXAMINATION
PW1, PW2, PW4, and PW5 were cross-examined as under:
PW1 is cross-examined as under:
1. SDO was not along with the checking team.
2. Connection of meter is in the name of Shabbir Ahmed.
3. Meter was removed and took to the office
4. We served the notice of removal of meter to the meter owner (notice is not the part of file)
5. Meter was not sent to M & T lab for inspection, because the representative of MXT was
with us.
6. It is incorrect to suggest that either accused is involved due to resistance by the accused in
checking and removal of meter.
7. It is incorrect to suggest that the accused has no concern with the occurrence.
PW2 is cross-examined as under:
1. PW2 is unaware of the FIR no., for which he has appeared as a witness.
2. The meter was installed near the wall of a house, from where it was removed.
3. SDO was not with us at the time of checking.
4. Meter was not sent to MXT lab, because their representative was with us.
5. We have no instrument with which, we can check whether the meter was reversed or not.
Because the representative of lab can tell us that whether the meter was reversed or not by
seeing its condition.
6. PW2 failed to tell the name of IO
7. The owner of the meter is Shabbir Ahmed
8. This is my first case, in which I am appearing as a witness.
9. I was on duty and I removed the meter under the order of SDO.
10. It is incorrect to suggest that the proceedings were done while sitting in Delhi Gate Police
Station.
11. It is incorrect to suggest that accused was involved in the case due to hi resistance at the
place of occurrence.
12. It is incorrect to suggest that being a subordinate of SD, I had deposed falsely.
PW4 is cross-examined as under:
1. I was not present at the place of occurrence.
2. I was in my office, where the team/ raiding party had given me the meter and informed me
about the whole occurrence.
3. Meter was not sent to MXT lab
4. IO came to my office and recorded my statements u/s 161 CRPC
5. 05-01-22 was the date of occurrence
6. Meter is in the name of Shabbir Ahmed and under the use of Zeeshan Qureshi

23
 7. I inquired the matter while sitting in my office, when only the inspection team was present
with me.
8. Notice of removal of meter was given to accused, (not a part of file)
9. It is incorrect to suggest that either I had given notice to the accused or not.
10. It is incorrect to suggest that the accused is involved in this case because of the resistance
he created at the place of occurrence.
PW5 is cross-examined as under:
1. I was on patrolling duty where constable Arshad came to me and gave complaint Exh.PD
and the police file.
2. I reached the place of occurrence at 02:00 PM and SDO, and all PWs were present at the
place of occurrence
3. Exh.PD bears my signature and designation in Urdu

FINAL ARGUMENTS AND CLOSING OF CASE BY DEFENSE COUNSEL

Defense Counsel closed the case as under:
1. The property of the case (meter) has not been sent to MXT lab for inspection.
2. The meter is not in the name of the accused.
3. The accused is falsely involved in the case due to the resistance caused at the place of
occurrence.

DECISION OF THE CASE

The case was decided in the favor of the accused on the following grounds:
1. The accused became the part of investigation while on pre-arrest bail.
2. The property of the case was not sent to the MXT lab for inspection.
3. The accused is not the owner of the meter concerned.
Therefore, it was ordered that:
“The accused is acquitted from this case with honor and respect, bail confirmed.
Case dismissed.”

24
DRAFTING OF DIFFERENT

25
I.

26
FAMILY SUITE FOR MAINTENACE
IN THE COURT OF CIVIL\FAMILY JUDGE, MULTAN

[PLACE LEFT FOR AFFIXING COURT FEE\TICKETS]

1. Mst. Amna Aftab , D/o. Muhammad Aftab, W/o. Qamar Afzal, caste butt, R/o. House No.
05 Block-5, Gulshan market, Multan.
2. NOOR, daughter of Qamar Afzal [through plaintiff no.01\real mother]
…………PLAINTIFFS
VERSUS
Qamar Afzal, Son of Afzal ,caste ….., R/o. Flat No. 6-A, Block-5, xxx, Multan
……………………………DEFENDANT

SUIT FOR MAINTENANCE

The Plaintiff, above named, submits as under:-
1) That the Plaintiff, above named, was married with the Defendant, above named, at Multan, on
08-10-2007, and nikah was solemnized verbally before family members and other witnesses, in
consideration of dower amount of Rs.25000/= which is still unpaid. Rukhsati took place at same
day, but this nikah was registered on 18-12-2011. Photocopy of Nikahnama is attached herewith
and marked annexure “A”.
2) That after rukhsati, relations between the spouses remained harmonious married life for few
years and then the Plaintiff’s husband started to inflict mental & physical torture and mal-treated
the Plaintiff No.1, and started to suspect her character on instigation of in-laws family members
and his friends.
3) That out of this wedlock one female issue namely Noor was born on 10.10.2011, but the
defendant disowned her daughter, above named, and the defendant turned out her with above said,

27
newly born baby from his house and said until it is proved that he is father of the newly born minor,
above named, he will not rejoin her and he will divorce her.
4) That the defendant did not maintained the plaintiff No.1 & 2 properly since 10.10.2011 to upto
now.
5) That due to circumstances mentioned above it is very difficult and beyond the plaintiff’s
control to save her harmonious matrimonial life and maintain herself alongwith the minor above
named.
6) That the Plaintiffs are residing within limits, which is within jurisdiction of this Hon’ble Court.
7) That the prescribed court fees stamps has affixed as the suit is valued in accordance with the
provision of Family Court Act.

PRAYER
Due to circumstances mentioned above, It is respectfully prayed that this Hon’ble Court may be
pleased to pass Judgment and Decree in favor of the Plaintiff against the Defendant claims: -
A) To direct the defendant to pay past maintenance to the plaintiff No.1 & 2 at the rate
of Rs.2,000/= per month from 10.10.2011 up till now and in future on increment of 10% p/a.
B) Costs of the suit.
C) Any other relief, which this Hon’ble Court deems fit and proper in the circumstances
of the case.
Dated:13/04/2012.
PLAINTIFF No.1
M ZUBAIR
Advocare for the Plaintiff.

VERIFICATION
I, Mst. AAMNA Aftab W/o. Qamar Afzal, Muslim, adult,
R/o. Karachi, do hereby verify and state on oath that whatever stated
above is true correct to the best my knowledge and belief.
Dated: 13/04/12.
Deponent/Plaintiff

28
FAMILY SUITE FOR DOWER AND DOWRY ARTICLES
IN THE COURT OF CIVIL\FAMILY JUDGE, MULTAN

Xxxx, D\O ……,W\O ……., caste….. , R\O …….., MULTAN

…………PLAINITFF
VERSUS
Yyyy, S\O………., caste……….., R\O,………………, MULTAN
,………..DEFENDANT

SUITE FOR RECOVERY OF DOWER AMOUNT RS.90,000/- AND DOWRY ARTICLES

The plaintiff above-named submit as under, through counsel;
1. That the plaintiff was married to the Defendant on 3rd August 2016 in consideration of a
prompt dower of Rs. 90,000/- according to the Muslim rites. A copy of Nikkah Nama is
attached to this suit.
2. That out of this wedlock, no child is born.
3. That after the marriage plaintiff and defendant lived, a happy life but thereafter the
defendant went cruel towards plaintiff and turned her out of doors. That since 07-03-20 the
plaintiff has – been making repeated demands for the payment of her prompt dower i.e. Rs.
90,000/- which was fixed, at the time of the marriage but the defendant has utterly denied
paying the money and demands. On 20-08-21, on the demand of the dower money by
plaintiff, the defendant has beaten her badly and divorced her thereby. Since then, plaintiff
is residing in her parent’s house. The plaintiff belongs to a well-off family and her parents
had given her dowry articles of total amount 30,00,000/-. The list of dowry articles with
respective amounts has been affixed with the plaint. The divorce deed is also attached with
the plaint. The plaintiff has no other remedy except this suit. Hence this suit is filed.
4. That the cause of action arose against the defendant initially on ________. When the
plaintiff was married to defendant and secondly when the defendant turned out the plaintiff
of doors and lastly and finally on 25th October 2021 when the defendant utterly denied
paying the dower money and giving dowry articles to the plaintiff.
5. That the marriage was completed at and both the plaintiff and defendant reside in, therefore,
the Civil Courts of __________ have the jurisdiction to decree this suit.

29
 6. That the valuation of the suit for the purposes of Court fee and jurisdiction are Rs. 90,000/-
. Therefore, Court fee tickets of Rs. 15/ – is attached on the plaint, which is recommended
Court fee to be affixed to this suit.

PRAYER
In view of the above it is prayed as under:
1. A decree for a sum of Rs. 90, 000/ – may kindly be passed in favor of the plaintiff and against
the defendant.
2. Costs of this suit may also be awarded to the plaintiff.
3. Any other relief considered possible by this Respected Court may also be granted.
PLAINTIFF
Through counsel

VERIFICATION
Verified on oath at Lahore on this 25th day of
October 2016 that the contents of the paragraphs 1 to 3 are
correct to the best of my knowledge whereas rest of
paragraphs No 4 to 6 are true to my information and faith.
Plaintiff

30
FAMILY SUITE FOR DISSOLUTION OF MARRIAGE
IN THE COURT OF SENIOR CIVIL/FAMILY JUDGE LAHORE.

Shabana Ajmal daughter of Muhammad Ajmal , Resident of 10 Lytton Road chitai Ahatta Lahore.
Plaintiff
Versus
Muhammad Mosin son of Shehbaz Hussain Resident of Street No , 75, Dhoobi Ghat Aurangzaib
Road Wahga Town Lahore.
Defendant

SUIT FOR DISSOLUTION OF MARRIAGE

Respectfully Sheweth : -
1. That the plaintiff was married with the defendant in accordance with Muslim rites on 10 june
2010 and a sum of rupees 50,000 /- as prompt dower which still has not been paid by the defendant
to the plaintiff, copy of nikah nama is enclosed.
2. That the relation between the spouses remained cordial only few days in the beginning of of
the marriage and after that defendant start beating the plaintiff on very common house hold matters.
3. That the attitude of the defendant and his family was very cruel and harsh arrogant and
unreasonable towards the plaintiff, he started making demands from the plaintiff to bring money
form her parents and on the refusal of the plaintiff he used to beat the plaintiff mercilessly.
4. That despite the physical and mental torture given to the plaintiff by the defendant, the plaintiff
tried her level best to reconcile the matter for the sake of her matrimonial life but the behavior of
the defendant became more harsh and cruel on 05-09-2014 the defendant deserted the plaintiff
from his house in wearing apparels only after giving severe beatings to the plaintiff and since then
the plaintiff is residing on the above mentioned address without being maintained by the defendant.
5. That the defendant habitually assaulted the plaintiff and made her life miserable by cruelty of
act and conduct as she was unable to fulfill the illegal and immoral demands of the defendant.
6. That the defendant is in the habit of intoxication and is also involved in criminal activities.

31
7. That the defendant has never maintained the plaintiff and they are making their both ends meet
by the help of parents of plaintiff.
8. That due to the attitude of the defendant the plaintiff has got fixed aversion in her mind against
the defendant and it is now impossible for the plaintiff to live with the defendant as his legally
wedded wife , as such the plaintiff seeks dissolution of her marriage on the ground of KHULLA
also .
9. That the cause of action has arisen in favor of the plaintiff and against the defendant firstly at
the time of solemnization of marriage between the plaintiff and the defendant, secondly in 05-09-
2014 when the plaintiff was ultimately deserted by the defendant from his house after giving severe
beatings to the plaintiff, hence the cause of action is still continuing to occure.
10. That the plaintiff is now residing at Lahore , so this honorable court has got the entire
jurisdiction to adjudicate upon the matter.
11. That the appropriate court fee has been affixed on the plaint for the satisfaction of the court.
PRAYER :
In view of the above mentioned facts and circumstances, it is most respectfully prayed that the
titled suit may very kindly be decreed in favor of the plaintiff and against the defendant on the
following terms : -
1. A decree for dissolution of marriage may kindly be passed in favor of the plaintiff and
against the defendant with costs.
2. Any other relief , which this honorable court deems fit and proper, in the circumstances of
the case, may also be awarded in favor of the plaintiffs.
Plaintiff
Through Counsel

Verification : -
Verified on oath today the 10th Day of February 2015 that the
Contents of the above paras are True and correct to the best of my
Knowledge and nothing has been Concealed.
Plaintiff

32
Format of Written Statement In Suit of Dissolution of Marriage on the Basis of Khula
IN THE COURT OF JUDGE FAMILY COURT, ……………city name

Wife ABCD Vs Husband GHI

Plaintiff vs defendant
SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULA
WRITTEN STATEMENT ON BEHALF OF DEFENDANT
Respectfully Sheweth,
1. Para No. 1 is admitted to the extent of date of marriage inter-se the parties and prompt
dower of Rs. 50,000/-. It is worth mentioning that apart from the payment of prompt dower
of Rs. 50,000/-, the defendant had gifted gold ornaments worth Rs. 60,000/- (according to
the contemporary market rates). The detail of gold ornaments has been mentioned in
annexure “A”, appended with the written statement. Moreover, at the time of Nikah, the
plaintiff was also given clothes, shoes and other bridal gifts, appended as annex “B”. Ever-
since the Nikah, the defendant and his family members have been giving gifts on certain
occasions as appended in annexure “C”. The articles and gifts as mentioned in annexure A,
B and C are still in the use and possession of the plaintiff. it is also worth mentioning here
that the father of the plaintiff had obtained a loan of Rs. 100,000/- Cash from the elder
brother of the defendant for Rukhsati, which amount is also outstanding.
2. Para No. 2 is not admitted as stated. The facts are that neither the defendant is previously
married nor he was cruel and harsh towards plaintiff. Rather he was kind and showed his
love to plaintiff, but she didn’t care about this sacred relationship.
3. Para No. 3 is vehemently denied. There has been good understanding between the plaintiff
and the defendant as both are closely related to each other. The defendant never victimized
plaintiff and he was very cooperative with paintiff.
4. Para No. 4 is denied which is totally incorrect. The defendant have a good business and
provided plaintiff with mouthful necessities of life. It is the intention of plaintiff to get rid
of defendant this is the reason plaintiff is making such a fabricated story.
5. Para No. 5 is not admitted as stated. The plaintiff is not working rather she lives with her
parent and their parent are compelling the plaintiff to get khula from defendant.
6. Para No. 6 is vehemently denied.

33
 7. Para No. 7 is also denied being incorrect. The defendant and his family members have been
giving gifts and money to the plaintiff on different occasions, as mentioned in reply to para
No. 1. So, there is no question of not providing maintenance.
8. Para No. 8 is not admitted. The plaintiff has got no justification asking for dissolution of
marriage. Plaintiff is being played in the hands of family member because the family
member of plaintiff does not like defendant.
9. Para No. 9 is not admitted as stated. All this story narrated by plaintiff is false and
concocted hence on the basis of these facts plaintiff cannot be granted with Khuls.
10. Para No. 10 is denied.
11. Para No. 11 is legal
12. Para No. 12 is legal, hence not controverted.

PRAYER
In the light of above, it is, therefore, respectfully prayed that the suit for dissolution of marriage
on the basis of khula may graciously be dismissed. And the decree of conjugal right in favor of
defendant may kindly be granted.
Defendant
Through Counsel

Verification
Verified on oath at Islamabad on ____ of December 2016
that the contents of this written reply from Para No. 1 to 10 are true
and correct to the best of my knowledge and belief, whereas rest of
the paras are believed to be correct.

Defendant

34
FAMILY SUITE FOR RESTITUTION OF CONJUGAL RIGHTS
IN THE COURT OF LEARNED SENIOR CIVIL JUDGE/ JUDGE FAMILY COURT,..

ABC (Husband) son of DEF resident of xxxx, Tehsil & District Pyyyyy, presently resident of Block
X, xyx.
…Plaintiff

Versus

GHI (Wife) daughter of JKL resident of Adhwal P.S YYY, Tehsil and District XXX.
…Defendant

SUIT FOR RESTITUTION OF CONJUGAL RIGHTS

Respectfully Sheweth,
1. That the plaintiff was married with the defendant on 27-10-2008 at XXX according to the
tenets of Islam and Muslim Family Law Ordinance 1961 in lieu of 5 Tolas of gold as dower
which was paid at the eve of Rukhsati.
2. That in fact the defendant got married with the plaintiff with her free will, consent and
without and duress as earlier defendant’s father got engaged the spouses but subsequently
betrayed from his accord and deliberately attempted to give defendant’s hand to an alien
and a man of old age. On that the defendant requested the plaintiff, therefore, the plaintiff
rescued her and got married.

35
3. That the defendant is a sui juris, adult and more than 19 years of age.
4. That thereafter the defendant’s father became furious and extended threats of dire
consequences and subsequently got registered a false, frivolous and fabricated FIR by
putting wider-net and involved the plaintiff, his real brother and friend’s family just to put
undue influence and pressure upon the plaintiff and his family in P.S. YYY bearing FIR
No. 000 dated 28-10-2008 …. PPC.
5. That it is important to mention here that the defendant has recorded her statement before
the competent authority / Magistrate XXX and then got recorded her statement u/s 164
Cr.P.C and thrashed out the root of the criminal case.
6. That thereafter the parents of the defendant agreed with the marriage of the spouses and
they offered the plaintiff and defendant to come their house just to meet the family members
of the defendant. Therefore, on this request of the defendant’s father, the spouses went to
the house of the defendant’s parents and they treated with the spouses happily and without
showing any ill-will or bad desires.
7. That the father of the defendant requested the plaintiff to allow the defendant to stay some
days in his house and after 3/4 days, he may take her back. On that plaintiff came back to
resume his daily life / work and after the lapse of few days, the plaintiff requested the
defendant’s father to allow her to go with the plaintiff but he not only refused to hear the
legitimate request of the plaintiff rather forcibly restrained the defendant without any legal
justification, hence this suit.
8. That the defendant is bound under legal, moral and social obligation to perform her
conjugal rights in accordance with the Sharia with the plaintiff and the plaintiff for the sake
and honor of her matrimonial life, bonafidely seeks to ABAD the defendant but the
defendant and her family particularly her father not willing for ABADI of the defendant
without any rhyme and reasons.
9. That the defendant is duty bound to live with the plaintiff during the subsistence of the
marriage and she cannot deny the rights of her husband.
10. That after this, the plaintiff made hectic efforts even through Jirgas to bring the defendant
in his house but all in vain due to the stubborn attitude of the defendant’s father.
11. That the plaintiff has love and affection with the defendant from core of his heart and is
willing to keep intact the matrimonial bond between the parties and seeks the defendant to
return back to his house.
12. That the cause of action firstly accrued when the father of the defendant forcibly restrained
the defendant to perform the marital obligations with the plaintiff at his house and finally
two days ago when the defendant on the behest of her father refused to perform the marital
obligations, which is still continuing.
13. That the parties are residents of Rawalpindi, so this learned Court has the Jurisdiction to
entertain this suit.
14. That the prescribed Court fee has been affixed with the plaint.

36
PRAYER
In view of above, it is humbly prayed that a decree for restitution of conjugal rights may kindly be
passed in favor of the plaintiff and defendant be, directed to join the plaintiff and perform her
matrimonial obligation as per law and injunctions of Islam.
Any other relief, which this Honorable Court may deem just and proper may also be awarded.
Plaintiff
Through Counsel

Verification
Verified on Oath at Rawalpindi on this Day
of June 2008, that the para No. 1 to 13 are true and
correct to the best of my knowledge and belief. and
nothing has been concealed.
Plaintiff

37
II. CRIMINAL

38
PRE-ARREST BAIL U/S 498 CRPC
IN THE LAHORE HIGH COURT LAHORE.

1. Mohammad Rasheed son of Mohammad Ramzan Caste Arain Resident of Fatah Wala Post
Office xxxxxxxxx Khas tehsil and district Q.
2. Ijaz Hussain Abdul Rehman Resident of Abubakar Town Post Office xxxxxxx Khas tehsil and
district Q.
(Petitioners)
Versus
The ………………………………….….………..State.
(Respondent)

FIR No P.S Offence

502 /09 xxxxxxxxxx 324/148/149 P.P.C

BAIL APPLICATION U / S 498 CR.P.C FOR THE GRANT OF PRE ARREST BAIL.
MAY IT PLEASE YOUR HONOUR:-
1. That the accused petitioners were involved in the above mention case due to the malafide
intention of the complainant as well as local police, otherwise the accused / petitioner is quite
innocent.
2. That the above-mentioned case has been got Register against the petitioner is false frivolous
baseless and concocted, with malafide intentions and ulterior motives of the complainant and
police.

39
3. That the allegations leveled against the petitioner are totally false and petitioner has no concern
with the commission of the alleged offence.
4. That the complainant under ulterior motive and with malafide intention to harass and black mail
the petitioner, has got registered the above noted false case, no such incident as alleged in the F I
R (copy of F.I.R Annex as A & better copy annex as A1) had ever took place. Moreover, pre arrest
bail of the petitioners were dismissed by learned Additional Session Jude vide order 27-08-09.
(Copy of order dt 27-08-09Annex as B)
5. That nothing incrimination and substantial material available on record, connecting the
petitioners with the commission of the alleged offence in this way the complainant of the case did
high handedness and tried to involve the petitioners in this false and frivolous case.
6. That the petitioners are respected law-abiding citizen. The local police are bent upon to arrest
the petitioners and they will suffer irreparable loss to his respect and family honor.
7. That there is no apprehension of abscondence of the petitioners or to temper with the
prosecution evidence.
8. That the petitioners are ready to submit bail bonds to the entire satisfaction of this honorable
court.

Prayer
It is therefore respectfully prayed that the petitioners may very kindly be granted ad – interim pre
arrest bail, till the final disposal of this petition and oblige.
Petitioners
Through Counsel

Verification: -
Verified on oath at Lahore on 09-10-09 that the contents of
the said petition are correct to the best of my knowledge and belief

40
Sample Affidavit

IN THE LAHORE HIGH COURT LAHORE.

1. Mohammad Rasheed, son of Mohammad Ramzan Caste Arain Resident of Fatah Wala Post
Office XXXXXX Khas tehsil and district Q.
2. Ijaz Hussain Abdul Rehman Resident of Abubakar Town Post Office xxxxxx Khas tehsil and
district Q.
(Petitioners)

Vresus

The …………………………………………….….………..State.
(Respondent)

FIR No P.S Offence

502 /09 Khuddian 324/148/149 P.P.C

BAIL APPLICATION U / S 498 CR.P.C FOR THE GRANT OF PRE ARREST BAIL.

Affidavite of Mohammad Rasheed son of Mohammad Ramzan Caste Arain Resident of Fatah
Wala Post Office Khuddian Khas tehsil and district Qasoor,do hereby solemnly declare and
affirm as under:-
MAY IT PLEASE YOUR HONOUR
1 That the accused petitioners were involved in the above mention case due to the malafide
intention of the complainant as well as local police, otherwise the accused / petitioner is quite
innocent.
2 That the above-mentioned case has been got Registered against the petitioners is false
frivolous baseless and concocted, with malafide intentions and ulterior motives of the complainant
and police.

41
3 That the allegations leveled against the petitioners are totally false and petitioner has no
concern with the commission of the alleged offence.
4 That the complainant under ulterior motive and with Malafide intention to harass and black
mail the Petitioners, has got registered the above noted false case, no such incident as alleged in
the F I R had ever took place.
5 That nothing incrimination and substantial material Available on record, connecting the
petitioner with the commission of the alleged offence.
6 That the petitioner is respected law-abiding citizen. The local police is bent upon to arrest
the petitioners and they will suffer irreparable loss to his respect and family honor.
7 That there is no apprehension of abscondence of the petitioners or to temper with the
prosecution evidence
8 That the petitioners are ready to submit bail bonds to the entire satisfaction of this
Honorable court.
Deponent

42
POST-ARREST BAIL U/S 497 CRPC
IN THE COURT OF DISTRICT & SESSIONS JUDGE, RAWALPINDI.

1. ABCD resident of CDEF Tehsil and District Rawalpindi.

2. AB son of CD resident of Village Taja Bhara, Tehsil FAteh Jang District Attock.
…. Petitioners
VERSUS
1. The State
2. GHI w/o JKL resident of Village Mujahat, P.S Chauntra, Tehsil and District Rawalpindi.
…Respondents

CASE FIR NO…. DATED 28-08-2008

UNDER SECTIONS 302/147/149 PPC P.S CHAUNTRA, TEHSIL & DISTRICT,….
PETITION UNDER SECTION 497 Cr.P.C FOR THE GRANT OF POST ARREST BAIL.

Respectfully Sheweth,
1. That brief story of the case is that Mst. Shamim Akhtar, complainant lodged the FIR with
an allegation in brief that on 28-08-2008 at about 30 am, she alongwith her husband
Tauqeer Ahmed (deceased), Raja Gulfaam Akhtar and Raja Imtiaz Qamar (PWs) boarded
a car and proceeded towards her house at Rawalpindi. Tauqeer Ahmed was driving the car.
The moment, the car reached within the area of village Mujahad, two vehicles boarded by
the petitioners here in and other four accused persons blocked the way, Tauqeer Ahmed
(deceased) stopped his car, upon which, the petitioners and other co-accused persons
alighted from their vehicles allegedly Tariq Mehmood accused raised LALKARA that
Tauqeer Ahmed should not let alive. The accused persons dragged out Tauqeer Ahmed and
PWs from the car Muhammad Safdar petitioner No. 2, gave churri blow to Tauqeer Ahmed

43
 hitting him on palm of right-hand, followed by another churri, blow by Mumtaz Khan (co-
accused) striking him in the chest/-. On receipt of above said two injuries Tauqeer Ahmed
fell down, when Mushtaq co-accused armed with Danda, Sadaqat, co-accused armed with
iron-rod, other three Qazi Tariq, Qazi Abdul Hamid and Qazi Akram (all co-accused) gave
him, Danda, blows, which landed upon different parts of his body. All the accused fled
away leaving as the story of the FIR goes Tauqeer Ahmed at the spot in an injured
condition, from where, he was removed to the hospital but he breathed his last on the way.
Motive for occurrence allegedly was an earlier altercation between two co-accused persons
and deceased.
2. That firstly the pre-arrest bail application was moved by petitioner No. 2 before this
Honorable Court which was entrusted to the Court of Mr. Ghulam Mehdi Khan, the
Learned ASJ, Rawalpindi, which was declined.
3. That petition for bail after arrest u/s 497 Cr.P.C of Sadaqat accused was accepted by the
Learned Judge Mustafa Tanvir Safwat, the Learned ASJ, Rawalpindi as being not resisted
by the complainant, while the petition to the extent of 3 others namely Tariq, Abdul
Hameed and Akram was declined on 13-1-2009.
4. That this is first bail application after arrest of both petitioners. Anyhow Qazi Tariq, Qazi
Abdul Hamid and Qazi Muhammad Akram moved their such bail petitions before the
Honorable High Court, which was accepted by his Lordship Mr. Justice Mr. Kazim Ali
Malik, Lahore High Court Rawalpindi Bench, Rawalpindi in Crl. Misc. No. 153-B of 2009
dated 25-02-2009.
5. That the grounds of post arrest bail by the petitioners are as under;
a. That the petitioner No. 1 is not nominated in the FIR and the name of the
petitioner No. 1 was later on added with malafides by the complainant party
through so-called supplementary statement. The real brother of the petitioner
No. 2, who happens to be the real uncle of the petitioner No. 1 died and on
the day of alleged occurrence Name-ze-Janaza was scheduled to be held at
11.00 am in his native village and the both the petitioners were busy in
obsequies of deceased namely Manzoor Hussain being closely related inter-
see and were not at the place of occurrence.
b. That the complainant with malafidies roped the whole family members by
extending their net maliciously. The alleged role was fake attributed to
petitioner No. 1 while role attributed to petitioner No. 2 that he inflicted injury
on non-vital part of the deceased, stately on right palm near the little finger,
which simple in nature and not fatal one.
c. That the complainant with malafidies roped the whole family members by
extending their net maliciously. The alleged role was fake attributed to
petitioner No. 1 while role attributed to petitioner No. 2 that he inflicted injury
on non-vital part of the deceased, stately on right palm near the little finger,
which simple in nature and not fatal one.
d. That the case against the both petitioners is that of further inquiry and comes
under the umbrella of section 497 (2) of Cr.P.C and the both the petitioners
deserve bail after arrest.

44
e. That the case against the both petitioners is that of further inquiry and comes
under the umbrella of section 497 (2) of Cr.P.C and the both the petitioners
deserve bail after arrest.
f. That the fate of trial is not-visible in the near future. Both the petitioners are
previously non-convict, having unblemished character.
g. That the fate of trial is not-visible in the near future. Both the petitioners are
previously non-convict, having unblemished character.

PRAYER
It is therefore, respectfully prayed that the instant petition may
magnanimously be accepted and post-arrest bail may graciously be granted
to the petitioner in the interest of Justice.
Petitioners
Through Counsel

CERTIFICATE.
Certified on the instruction received from the
petitioner this is a first bail petition ever moved
before this Honorable Court on the subject.
COUNSEL

45
PETITION U/S 497(5) Cr.P.C. FOR THE CANCELLATION OF BAIL
IN THE LAHORE HIGH COURT, LAHORE.

Crl. Misc.No.___________/CB/2014.
Muhammad Saeed S/O Muhammad Daud R/O Ayya-Pur, Tehsil Shariqpur, District
Sheikhupura.
.......Petitioner
VERSUS
1. The State.
2. Jamil Ahmad
3. Naveed Ahmad both sons of Muhammad Saeed R/o Ayya-Pur, Tehsil Shariqpur, Distric
Sheikhupura.
……Respondents
CASE FIR NO: 546/2014, Dated; 12.08.2014
OFFENCE U/S: 452/379,337/A1,337/F1,148/149,337A(ii), 337F(v) subsequently added
POLICE STATION: Shariqpur Sharif District Sheikhupura.
PETITION U/S 497(5) Cr.P.C. FOR THE CANCELLATION OF BAIL OF RESPONDENT
NO.2 & 3.
HUMBLY SHEWETH:
1. That on 11.08.2014 at 12:00 PM Respondent No.2&3 alongwith Atif, Ahsan Tafail and one
unknown person were stealing bricks before the gate of the petitioner on intervention Respondent
No.2 & 3 and other accused became annoyed and started beating to the petitioner meanwhile
Muneer Ahmed s/o Muhammad Sharif who is closed relative to the petitioner and Hussnain S/o
Muhammad Sharif reached there. The respondentNo.2/ accused Atif took the pistol out from his
folder. The petitioner, Muneer Ahmed and Hussnain entered into the house of the petitioner and
closed the gate all the accused jumped the walls and entered into the house of the petitioner,
accused Atif beated at the left ear of Muneer Ahmed with the pistol who severely injured, accuse

46
Jamil broke the little finger of left hand of the petitioner beating with brick, accuse of
Jamil/respondent No.2 secondly beat with brick at right cheek of the petitioner accused
Naveed/Respondent. No.3 beat with the iron rod at the right arm of the Muneer Ahmed while
accused Ehsan Tufail beat with brick at the right hand of the Muneer Ahmed for detail prosecution
story copy of FIR is attached as Annexure.......“A”.
2. That the injured persons were examined on the same day on 11.08.2014 at DHQ Hospital
Sheikhupura where the injury No. 1 of the injured Muneer Ahmed s/o Muneer Sharif and Injury
No.1&3 of Injured petitioner/Muhammad Saeed were kept under observation and referred to
Services Hospital Lahore, for X-ray where as per radiologist Report No.5795 and 5796 injury No.1
of the injured Muneer Ahmed was declared as “it falls under section 337/A2” and injury No.3 of
the inured Muhammad Saeed/petitioner was declared as “as per radiologist report 5792 and 5794
there is fracture shaught of 5th MC left hand therefore injury No.3 fall under section 337/F5”.
Therefore offences under section 337/A2&337/F5 were added subsequently. Later on the
Respondent No.2/Jamil Ahmad submitted an application during the pendency of bail petition
before learned ASJ Ferozwala, for addition of the offence 337/F5 which was subsequently added.
Copy of MLCs of injured Munir Ahmed and Jaml Din are attached as Annexure.......“B & B/1”
respectively.
3. That the respondent No.2&3 alongwith others filed their pre-arrest bail applications before the
learned Aqib Nazeer ASJ Ferozwala during the pendency of bail petition the Respondent
No.2/Jamil Ahmad filed an application before learned ASJ Ferozwala, for permission of addition
of offence under section 337/F5 in his bail petition while he concealed the fact of addition of
offence 337/A2 PPC there. Now it is crystal clear that the addition of offences 337/A2 & 337/F5
was in well knowledge of the respondents/accsed. The learned ASJ Ferozwala, Aqib Nazeer
dismiss the bail petition vide order dated 30.10.2014. Copy of bail application with order and
application for addition of offences 337/A2 & 337/F5 are attached as Annexure.......“C&C/1
respectively”.
4. That later on Respondents No.2&3 alongwith other co-accused filed the Crl.Misc.No.14991-
B/2014 before Honourable Lahore High Court Lahore with concealment of true facts excluding
the not bailable offences 337/A2&F5 PPC to achieve the undue favour of this Honourable Court
while during the pendency of pre-arrest bail application of respondent No.2&3 alongwith other
co-accused the respondent No.2/Jamil Ahmad submitted his own application before Learned ASJ
Ferozwala to him for addition of offences under section 337/F5 PPC which was added
subsequently while suppressing the offences under section 337/A2 which was also subsequently
added now it is crystal clear the addition of offences under section 337/A2&F5 PPC were in well
knowledge of the respondent No.2&3 who concealed the same while applying their pre-arrest bail
petition before this Hounourable Court. His Lordship Mr. Justice Altaf Ibrahim Qurashi
accepted the bail petition of Respondent No.2&3 (which was filed with concealment of facts) in
case FIR No. 546/2014 in offences under section 452,379,337/A1 337/F1 148/149 PPC vide order
dated 17.11.2014. Copy of order dated 17.11.2014 is attached as Annexure.......“D”.
5. That the impugned order Dated: 17.11.2014 is liable to be cancelled on the amongst others.

47
GROUNDS:
1. That the Crl.Misc.No.14991-B/2014 was filed before this Honourable Court concealing the
true and real facts of the above said case excluding the not bailable offences under section
337/A2&F5 PPC.
2. That it is crystal clear as discussed above addition of offences under section 337/F5&A2 PPC
was in well knowledge of Respondent No.2. The Respondent No.2 filed an application before
learned ASJ Ferozwala for addition of offences under section 337/F5 during the pendency of bail
petition before Learned ASJ Ferozwala, later on while applying for pre_arrest before this
Honourable Court, the Respondent No.2&3 concealed these not bailable offences deliberately to
achieve the undue favour of this Honourable Court.
3. That the Respondent No.2&3 committed lurking house tress pass and inflicted severe injuries
to the petitioner and other injured Muneer Ahmed which are attributed to the Respondent No.2&3.
4. That the Respondent No.2&3 were also declared guilty during the course of investigation.
5. That the respondent No.2&3 concealed the real and true facts deliberately therefore they are
not entitled for concession of extraordinary relief of pre-arrest bail hence the order dated
17.11.2014, is liable to be cancelled in supreme interest of justice.
6· That such like elements, who cheat with this Honourable Courts with concealment of true and
real facts be dealt with strict hands to secure the ends of Justice.
7· That since after the confirmation of pre-arrest bails, Respondent No.2&3 with the connivance
of 2 other accused persons started to threaten the petitioner about dire consequences and also
pressurised the petitioner to withdraw the case.
It is, therefore, respectfully prayed that this petition may kindly be accepted and the order dated
17.11.2014 may kindly be recalled and bail already granted to the Respondents No. 2 and 3 may
kindly be cancelled in supreme interest of justice and fare play.
PETITIONER
Through Counsel
NOTE:
As per instructions, this is first petition on the subject matter and Crl.Misc.No.14491-B/2014
may kindly be put up with this petition

48
SAMPLE AFFIDAVIT
IN THE LAHORE HIGH COURT, LAHORE.

CRL. MISC.NO.___________/CB/2014.

Muhammad Saeed VERSUS The State etc.

PETITION U/S 497(5) Cr.P.C. FOR THE CANCELLATION OF BAIL OF RESPONDENT NO.2
& 3.
AFFIDAVIT.
Of Muhammad Saeed S/O Muhammad Daud R/O Ayya-Pur, Tehsil Shariqpur, District
Sheikhupura.
1. That on 11.08.2014 at 12:00 PM Respondent No.2&3 alongwith Atif, Ahsan Tafail and one
unknown person were stealing bricks before the gate of the petitioner on intervention Respondent
No.2 & 3 and other accused became annoyed and started beating to the petitioner meanwhile
Muneer Ahmed s/o Muhammad Sharif who is closed relative to the petitioner and Hussnain S/o
Muhammad Sharif reached there. The respondentNo.2/ accused Atif took the pistol out from his
folder. The petitioner, Muneer Ahmed and Hussnain entered into the house of the petitioner and
closed the gate all the accused jumped the walls and entered into the house of the petitioner,
accused Atif beated at the left ear of Muneer Ahmed with the pistol who severely injured, accuse
Jamil broke the little finger of left hand of the petitioner beating with brick, accuse of
Jamil/respondent No.2 secondly beat with brick at right cheek of the petitioner accused
Naveed/Respondent. No.3 beat with the iron rod at the right arm of the Muneer Ahmed while
accused Ehsan Tufail beat with brick at the right hand of the Muneer Ahmed for detail prosecution
story copy of FIR is attached as Annexure.......“A”.
2. That the injured persons were examined on the same day on 11.08.2014 at DHQ Hospital
Sheikhupura where the injury No. 1 of the injured Muneer Ahmed s/o Muneer Sharif and Injury
No.1&3 of Injured petitioner/Muhammad Saeed were kept under observation and referred to
Services Hospital Lahore, for X-ray where as per radiologist Report No.5795 and 5796 injury No.1
of the injured Muneer Ahmed was declared as “it falls under section 337/A2” and injury No.3 of
the inured Muhammad Saeed/petitioner was declared as “as per radiologist report 5792 and 5794

49
there is fracture shaught of 5th MC left hand therefore injury No.3 fall under section 337/F5”.
Therefore offences under section 337/A2&337/F5 were added subsequently. Later on the
Respondent No.2/Jamil Ahmad submitted an application during the pendency of bail petition
before learned ASJ Ferozwala, for addition of the offence 337/F5 which was subsequently added.
Copy of MLCs of injured Munir Ahmed and Jaml Din are attached as Annexure.......“B & B/1”
respectively.
3· That the respondent No.2&3 alongwith others filed their pre-arrest bail applications before
the learned Aqib Nazeer ASJ Ferozwala during the pendency of bail petition the Respondent
No.2/Jamil Ahmad filed an application before learned ASJ Ferozwala, for permission of addition
of offence under section 337/F5 in his bail petition while he concealed the fact of addition of
offence 337/A2 PPC there. Now it is crystal clear that the addition of offences 337/A2 & 337/F5
was in well knowledge of the respondents/accsed. The learned ASJ Ferozwala, Aqib Nazeer
dismiss the bail petition vide order dated 30.10.2014. Copy of bail application with order and
application for addition of offences 337/A2 & 337/F5 are attached as Annexure.......“C&C/1
respectively”.
4· That later on Respondents No.2&3 alongwith other co-accused filed the Crl.Misc.No.14991-
B/2014 before Honourable Lahore high Court Lahore with concealment of true facts excluding the
not bailable offences 337/A2&F5 PPC to achieve the undue favour of this Honourable Court while
during the pendency of pre-arrest bail application of respondent No.2&3 alongwith other co-
accused the respondent No.2/Jamil Ahmad submitted his own application before Learned ASJ
Ferozwala to him for addition of offences under section 337/F5 PPC which was added
subsequently while suppressing the offences under section 337/A2 which was also subsequently
added now it is crystal clear the addition of offences under section 337/A2&F5 PPC were in well
knowledge of the respondent No.2&3 who concealed the same while applying their pre-arrest bail
petition before this Hounourable Court. His Lordship Mr. Justice Altaf Ibrahim Qurashi accepted
the bail petition of Respondent No.2&3 (which was filed with concealment of facts) in case
FIR No. 546/2014 in offences under section 452,379,337/A1 337/F1 148/149 PPC vide order dated
17.11.2014. Copy of order dated 17.11.2014 is attached as Annexure.......“D”.
5· That the impugned order Dated: 17.11.2014 is liable to be cancelled on the amongst others.
GROUNDS:
1· That the Crl.Misc.No.14991-B/2014 was filed before this Honourable Court concealing the
true and real facts of the above said case excluding the not bailable offences under section
337/A2&F5 PPC.
2· That it is crystal clear as discussed above addition of offences under section 337/F5&A2 PPC
was in well knowledge of Respondent No.2. The Respondent No.2 filed an application before
learned ASJ Ferozwala for addition of offences under section 337/F5 during the pendency of bail
petition before Learned ASJ Ferozwala, later on while applying for pre_arrest before this
Honourable Court, the Respondent No.2&3 concealed these not bailable offences deliberately to
achieve the undue favour of this Honourable Court.

50
3· That the Respondent No.2&3 committed lurking house tress pass and inflicted severe injuries
to the petitioner and other injured Muneer Ahmed which are attributed to the Respondent No.2&3.
4· That the Respondent No.2&3 were also declared guilty during the course of investigation.
5· That the respondent No.2&3 concealed the real and true facts deliberately therefore they are
not entitled for concession of extraordinary relief of pre-arrest bail hence the order dated
17.11.2014, is liable to be cancelled in supreme interest of justice.
6· That such like elements, who cheat with this Honourable Courts with concealment of true and
real facts be dealt with strict hands to secure the ends of Justice.
7· That since after the confirmation of pre-arrest bails, Respondent No.2&3 with the connivance
of 2 other accused persons started to threaten the petitioner about dire consequences and also
pressurized the petitioner to withdraw the case.
VERIFICATION: -
Verified upon oath at Lahore at this 16th day of
December 2014, that the contents of affidavit are true and correct to
the best of my knowledge and belief and nothing has been concealed
therefrom.
DEPONENT

51
HABES PETITON U\S 491 CRPC
IN THE COURT OF SESSION JUDGE LAHORE.

Muhammad Saeed son of Mukhtar Ahmed Caste Qazi Resident of Begum Kot Shama Colony
Sharaq Pur Road lahore.
(petitioner)
Versus
1. SHO police Station Shahdara lahore.
2. Incharge chowki Muhammad Shafique sub inspector police Station Shahdara lahore, and 6/7
other police officials.
3. Sheikh Sardar son of not known Resident of Nashtar colony Street No 1 lahore.
4. The State .
(Respondents)
APPLICATION U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA
AGED ABOUT 2 YEARS OLD FROM THE ILLEGAL AND IMPROPER CUSTODY OF
THE RESPONDENT NO 3.
MAY IT PLEASE YOUR HONOUR,
1. That the abrigdely contents of this application are that the petitioner is a law abiding
citizen of Pakistan and has very good antecedent in his credit , and very popular in his community.
2. That the petitioner was married with the daughter of the respondent No 3 according
to Muslim rites and in the presence of the witnesses in the year of 2007 and due to this wedlock
one female baby detneu was born .
3. That it is pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was
abnormal and the patient of Epilepti form by birth and the respondent No 3 with malafide intention
and ulterior motive married her with the petitioner.
4. That on the first day of the marriage the petitioner came to know regarding the illness
of the Mst Nargis bibi , but due to the fear of Allah the petitioner accept her with all her illness ,
and began to her treatment .

52
5. That the mental and physical health conditions of the wife of the petitioner became
down day by day and at least the respondent No 3 took back her daughter from the house of the
petitioner for further treatment about one month ago , while the minor Mst Zahra remained in the
house of the petitioner, while the petitioner and his sisters were looking after the minor .
6. That on 15-05-11 at about 4/5 pm when the petitioner was present at his home at once
respondents No 2 with the active convenience of the respondent No3 forcibly entered in the house
of the petitioner and forcibly snatched the minor Mst Zahra from the legal custody of the petitioner
and handed over to the respondent No 3 and fled away from the spot.
7. That being aggrieved the petitioner at once approached the respondent No 1 and told
him the whole story about the kidnap of the daughter of the petitioner, but the respondent No 1 did
not pay any attention to this fact and kicked out the petitioner from the police stations.
8. That petitioner has no other speedy and educate remedy except to invoke the jurisdiction
of this honourable court for the recovery of her minor daughter from the illegal and improper
custody of the respondent No 3, hence this petition.
Prayer
It is therefore respectfully prayed that the petition of
the petitioner may kindly be accepted and request for
depute a bailiff of this honourable court for the
recovery of minor daughter of the petitioner from the
illegal and improper custody of the respondent No 3
and oblige.
Petitioner.
Through Counsel
16-05-11

53
Sample Affidavit
IN THE COURT OF SESSION JUDGE LAHORE.

Muhammad Saeed son of Mukhtar Ahmed Caste Qazi Resident of Begum Kot Shama Colony
Sharaq Pur Road Lahore
(petitioner)
Versus
1. SHO police Station Shahdara lahore.
2. Incharge chowki Muhammad Shafique sub inspector police Station Shahdara lahore, and 6/7
other police officials.
3. Sheikh Sardar son of not known Resident of Nashtar colony Street No 1 lahore.
4. The State .
(Respondents)
APPLICATION U / S 491 CR.P.C FOR THE RECOVERY OF DETNEU MST ZAHRA AGED
ABOUT 2 YEARS OLD FROM THE ILLEGAL AND IMPROPER CUSTODY OF THE
RESPONDENT NO 3.
AFFIDAVIT
of Muhammad Saeed son of Mukhtar Ahmed, Caste Qazi Resident of Begum Kot Shama Colony
Sharaq Pur Road lahore do hereby solemnly affirm as under,
MAY IT PLEASE YOUR HONOUR,
1. That the abrigdely contents of this application are that the petitioner is a law abiding
citizen of Pakistan and has very good antecedent in his credit , and very popular in his community.
2. That the petitioner was married with the daughter of the respondent No 3 according to
Muslim rites and in the presence of the witnesses in the year of 2007 and due to this wedlock one
female baby detneu was born .
3. That it is pertinent to mention here that the wife of the petitioner Mst Nargis Bibi was
abnormal and the patient of Epilepti form by birth and the respondent No 3 with malafide intention
and ulterior motive married her with the petitioner.

54
4. That on the first day of the marriage the petitioner came to know regarding the illness of
the Mst Nargis bibi , but due to the fear of Allah the petitioner accept her with all her illness , and
began to her treatment .
5. That the mental and physical health conditions of the wife of the petitioner became down
day by day and at least the respondent No 3 took back her daughter from the house of the petitioner
for further treatment about one month ago , while the minor Mst Zahra remained in the house of
the petitioner, while the petitioner and his sisters were looking after the minor .
6. That on 15-05-11 at about 4/5 pm when the petitioner was present at his home at once
respondents No 2 with the active convenience of the respondent No3 forcibly entered in the house
of the petitioner and forcibly snatched the minor Mst Zahra from the legal custody of the petitioner
and handed over to the respondent No 3 and fled away from the spot.
7. That being aggrieved the petitioner at once approached the respondent No 1 and told him
the whole story about the kidnap of the daughter of the petitioner, but the respondent No 1 did not
pay any attention to this fact and kicked out the petitioner from the police stations.
8. That petitioner has no other speedy and educate remedy except to invoke the jurisdiction
of this honourable court for the recovery of her minor daughter from the illegal and improper
custody of the respondent No 3, hence this petition.

Verification : -
Verified on oath at Lahore On 16-05-
11 that the contents of the said
petition are correct to the best of my
knowledge and belief.
Deponent

55
PETITION U/S 22A 22B CRPC FOR THE REGISTRATION OF A
CRIMINAL CASE
IN THE COURT OF SESSION JUDGE LAHORE.

Muhammad Aslam son of Sardar Muhammad Resident of Huse No 21/ A Street NO 8 Data Street
Alhamd Colony lahore.
Petitioner
Versus
1. S.H.O Police Station Lahore.
2. Bin Yameen Khan son of
Respondents
Writ petition Under Section 22 /A 22 / B cr.p.c for the registeration of a criminal case against
the respondent No 2 under the relevant provision of law.
MAY IT PLEASE YOUR HONOUR:-
1. That abridgely the facts giving rise in the instant petition are that the petitioner is a
law abiding citizen of Pakistan and has a very good antecedents at his credit, and never involved
in any criminal case .
2. That the respondent No 2 who is friend of the petitioner , took Rs-19,00,000/-
(ninteen lac), as loan , and as a rebutal he also issued a cheque regarding the above said amount.
3. That on the fixed date the petitioner deposited the above said cheque in the relevent
bank, but the cheque was dishonoured due to insufficient funds.
4. That the petiitoner had very good relations with the respondent No. 2 so he tried his
level best to solve this matter ammicable but the respondent No.2 did not pay any attention towards
the petitoner’s demand and he always remained non serious for the above said payment, it is
pertinent to mention here that the defendant even did not bother to return the above said money to
the petitioner.

56
5. That the petitioner being aggrieved moved an application to the respondent No 1,
but no proper action has been taken by the respondent no . 1. hence this petition. Application as
annex –A

PRAYER
1. Keeping in view of the facts , and circumstance Mention
above the respondent no.1, may also be directed to protect the life
property , and libety of the petitioner along with his family members
from the brutal clutches of the respondent no 2 , and also request for a
registeration of a criminal case against the respondent No 2 under the
relevant provision of law.
2. Any other relief deemed fit may also be awarded .
Petitioner
Through Counsel

57
APPLICATION FOR STAY OF SUIT U\S 10 CPC
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN

Suit No………….
EF ………………. Plaintiff
Versus
PQ ………………. Defendant
Fixed for………………. Date
Application for Stay of Suit under Section 10 C.P.C.
Respectful Sir,
Respectfully it is stated:
1. That the plaintiff has instituted a suit against the defendant in this hon’ble Court on
…………(date).
2. That the defendant has also instituted a suit impleading the plaintiff as a defendant in this Court
on ………….(date). The certified copy of the plaint filed by the defendant against the plaintiff is
being enclosed along with this application.
3. That in the suit instituted by the defendant (referred in paragraph 2 above), involves the matter
in issue which is directly and substantially is the same in the previously instituted suit by the
plaintiff (referred to in paragraph 1 above) and the parties in both the suits are the same, who are
litigating under the same title.
4. That the suit previously instituted by the plaintiff is still pending in this Court.
5. That this Court has jurisdiction to grant the relief claim in both the suits.
It is therefore prayed that the trial of the suit instituted by the defendant, referred to is paragraph
No. 2 above may be stayed till the suit referred to in Para 1 above instituted by the plaintiff, be
heard and decided so as to avoid further litigation in the matter.
Dated…………… Applicant

58
APPLICCATION U\S 12(2) READ WITH SECTION 151 CPC

IN THE COURT OF III rd. CIVIL JUDGE AT KARACHI (WEST)

Civil Suit 1174/10.
Execution No. 02/11.

Abdul AZiZ Khan, son of Abdul Rashid, R/o. House No. C-161, Hasrat Mohani Colony, Manghpir road,
S.I.T.E. Town, Krachi. …………………… APPLICANT
VERSUS
Muhammad Wakeel Khan,son of Fareed Ahmed, R/o. House No. A-470, Hasrat Mohani Colony, Manghpir
road, S.I.T.E. Town, Karachi. ……………… RESPONDENT
APPLICATION U/S. 12 (2) CPC
READ WITH SECTION 151 CPC
For the facts and reasons disclosed in the accompanying affidavit, it is most respectfully prayed on behalf
of the applicant, above named, that this Hon’ble Court may be pleased to set-aside the Judgment and Decree
dated 29-08-2011 and 29-08-2011 respectively passed by this Hon’ble Court as the same is obtained by the
Plaintiff by way of fraud, misrepresentation, fabrication, concoction and matter is requires want of
jurisdiction.
Prayed according in the interest of justice.
Karachi.
Dated: - 31/03/2012.

59
APPLICATION UNDER SECTION 12(2) CPC FOR SETTING ASIDE
JUDGMENT AND DECREE PASSED BY THIS LEARNED COURT AND
OBTAINED BY THE RESPONDENT THROUGH FRAUD AND
MISSREPRESENTATION.
IN THE COURT OF _________, LEARNED CIVIL JUDGE, LAHORE.
.
.
.
.
____________ VERSUS _________
[SUIT FOR RECOVERY]
_____________, SON OF ________, RESIDENT OF _________, LAHORE.
……..Petitioner/Defendant
VERSUS
_____________, SON OF ________, RESIDENT OF _________, LAHORE.
……..Respondent/Plaintiff
P E T I T I O N UNDER SECTION 12(2) CPC FOR SETTING ASIDE JUDGMENT AND
DECREE DATED 06.06.2014 PASSED BY THIS LEARNED COURT AND OBTAINED BY
THE RESPONDENT THROUGH FRAUD AND MISSREPRESENTATION.
RESPECTFULLY SHEWETH:
1. That through the instant application, the petitioner/defendant humbly seeks indulgence of this
Learned Court, for setting aside judgment & decree dated 06.06.2014, whereby this Learned Court
was pleased to decree the suit filed by the respondent/plaintiff for recovery of an amount of
Rs.20000000/- (2crores). Copy of judgment & decree dated 06.06.2014 passed by this Learned
Court is appended herewith as Annex-A for kind perusal of this Learned Court.
2. That succinctly stated facts giving rise to the filing of petition in hand are that
Respondent/plaintiff filed a suit for recovery of an amount of Rs. Rs.20000000/-. It was alleged in
the plaint that the defendant/petitioner borrowed an amount of Rs.20000000/- from the
plaintiff/respondent on 03.02.2013 for the purpose of investment in the business of import of motor
vehicles. Moreover, an agreement was also executed between the parties whereby it was promised
by the defendant that he would return the amount on or before 12.12.2013. It was also alleged by
the plaintiff that he had contacted the defendant after expiry of stipulated time but the defendant
refused flatly. Copy of plaint filed by the plaintiff/respondent is appended herewith as Annex-B.

60
3. That the suit was filed by the plaintiff on 06.02.2014 and this Learned Court was pleased to
initiate ex-parte proceedings against the defendant/petitioner on 11.04.2014. Thereafter, this
Learned Court recorded ex-parte evidence of the plaintiff/respondent and the suit was decree vide
judgment & decree dated 06.06.2014. Copies of complete order sheet and evidence are Annex-C
& D.
4. That judgment & decreed dated 06.06.2014 is not sustainable in the eyes of law as same has
been obtained by the respondent/plaintiff through fraud and misrepresentation; hence same is liable
to be dismissed inter-alia on the following:
GROUNDS
i. That the judgment and decree dated 17.03.2014 was obtained by concealing material facts from
this Learned Court; Respondent defrauded this Learned Court by withholding truth, therefore,
judgment and decree dated 06.06.2014 is not sustainable in the eyes of law and liable to be set
aside.
ii. That the plaintiff/respondent intentionally mentioned wrong address of the defendant
intentionally so as to avoid service of summons and notices upon the defendant. The Plaintiff has
mentioned address of the defendant as “________________”, whereas, correct address of the
defendant/petitioner is “_____________”. The petitioner has no nexus whatsoever with the
location which has been mentioned by the plaintiff as residence of the petitioner in the titled of
abovementioned suit. Copies of CNIC of the petitioner and sale deed are appended herewith as
Annex-E & E/1 so as to ascertain correct address of the petitioner.
iii. That neither the petitioner borrowed any amount from the respondent nor did he execute any
agreement with the plaintiff. The alleged agreement which was produced by the respondent in his
evidence as Ex.P1 is an outcome of fraud and forgery. The agreement bears false and fabricated
signatures and thumb impressions of the petitioner/defendant.
iv. That the petitioner has also filed a separate suit for declaration for declaring aforementioned
agreement as null and void and ineffective qua rights of the petitioner. Copy of plaint in suit for
declaration is appended herewith as Annex-F.
v. That the petitioner has also submitted an application to the SHO of the concerned police station
so as to register an FIR against the respondent/plaintiff for preparing a forged and fabricated
document and using the same against the petitioner in an illegal and unlawful manner.
vi. That a bare perusal of the signatures of the petitioner at his CNIC and sale deed and then
comparing the same with the forged signatures at alleged agreement would reveal that the
respondent/plaintiff has defrauded this Learned Court and judgment & decree dated 06.06.2014
was obtained by him through fraud and misrepresentation.
vii. That the petitioner/defendant obtained knowledge regarding judgment & decree dated
06.06.2014 two days ago when notice was received by the petitioner/defendant after filing of
execution petitioner. It is pertinent to mention here that the respondent/plaintiff has mentioned
correct address of the petitioner/defendant in execution petition.

61
viii. That the applicant humbly seeks permission of this Learned Court for raising additional
grounds at the stage of arguments.
PRAYE R
In aforementioned circumstances, it is humbly
prayed that the petition in hand may kindly be
accepted and judgment and decree dated 06.06.2014
may be set aside, as it is in the interest of justice and
fair play.
PETITIONER/DEFENDANT
Through Counsel

62
63
FIR UNDER SECTION 154 CRPC

64
First Information Report (FIR) is a written document prepared by the police under section 154 of
Criminal Procedure Code, 1898. When they receive information about the commission of a
cognizable offence. It is a report of information that reaches the police first in point of time and
that is why it is called the First Information Report.
The above given picture is the format of FIR used in Pakistan for the registration of FIR. FIR
consists of 6 columns. Column 01 shows when the crime is reported to police. Column no 02
shows the name of complainant on behalf of whom FIR is registered. Column no 03 shows the
offence charged. Column no 04 show the distance between/direction from the place of occurrence
and respective police station in which FIR has ben registered. Column no 05 shows the reasonable
cause if FIR is registered after reasonable time. Column no 06 shows the date and time when police
has departed towards the place of occurrence.
At the top third line of the FIR, one can find the FIR NO. (609/17 as in above FIR). Also at the
top, one can find the name of respective police station and the respective district.
Below these 06 columns, the whole occurrence has been described very briefly.
Although the word “FIR” is not defined in the CRPC, it refers to oral information on the conduct
of a cognizable offence that is provided to the police at the earliest possible moment. An FIR is
not intended to be fully detailed; rather, it is intended to initiate the criminal justice system. The
information provided to the police officer in order to register a case may be true and accurate.
An FIR is an essential document for both parties (prosecution and defense). It serves as the case’s
initial foundation. The prosecution case will collapse if the foundation is weak.
The FIR is crucial in every criminal case since it is the opening stage of any criminal prosecution.
FIR is evidence that causes the start of criminal procedures, which leads to a criminal’s conviction.
A first information report, as its name implies, is the action taken in the event of an offence ,
followed by an investigation, a court case, and the punishment of the guilty. It serves as a record
of the details of the victim’s account. The FIR serves as the foundation for all subsequent actions
taken by the police. As a result, it is the earliest and first information of a cognizable offence that
a police station officer has ever documented. The FIR turns out to be the key piece of evidence
upon which the prosecution’s case is based. The state’s responsibility is to take cognizance, which
gives the victim a remedy and upholds justice in society.

65
CHALLAN FORM UNDER SECTION 173 CRPC

66
‫کسی بھی فوجداری مقدمے میں پولیس جب ملزم یا ملزمان کی تفتیش کرتی ہے تو اس تفتیش‬
‫سے اخذ کیے گئے نتائج کو متعلقہ ٹرائل کورٹ میں پیش کرنے کے لیے سیکشن ‪ 173‬کے‬
‫تحت ایک رپورٹ مرتب کرتی ہے جسے ہم عام عدالتی زبان میں چاالن کہتے ہیں۔ یاد رہے‬
‫کہ چاالن کا لفظ سی ار پی سی میں کہیں بھی استعمال نہیں ہوا ہے بلکہ یہ عام عدالتی زبان‬
‫سے وجود میں آیا چاالن میں مندرجہ ذیل سات کالم ہوتے ہیں‬
‫‪Column no1: Name of the informant‬‬

‫چاالن کے کالم نمبر ایک میں مدعی یا اطالع دہندہ کا نام ہوتا ہے‬
‫‪Column no 02: Name of persons who have not to be challan or his name includes as an absconder.‬‬
‫‪all innocent persons who are under section 496, 469 investigation incharge of Police station take‬‬
‫‪Michalka (bail) also keep in column #2‬‬

‫چاالن کے کالم نمبر دو میں ان ملزمان کا نام ہوتا ہے جن کو پولیس نے بے گناہ کیا ہو یا پھر‬
‫ان کا نام ہوتا ہے جن کو پولیس نے اشتہاری قرار دیا ہو ۔‬
‫‪Column no 03: All accused who have been challaned by investigation officer keep in column #3.‬‬
‫‪and investigation officer declares them guilty.‬‬

‫چاالن کے کالم نمبر تین میں ان ملزمان کا نام ہوتا ہے جن کو پولیس نے گنہگار کر کے‬
‫چاالن کیا ہو‬
‫‪Column no 04: The persons who are guilty and challaned but are on bail.‬‬

‫چاالن کے کالم نمبر چار میں ان ملزمان کا نام ہوتا ہے جن کو چاالن کیا گیا ہو مگر وہ‬
‫ضمانت پر ہوں‬
‫‪Column no 05: property of the case‬‬

‫کالم نمبر پانچ میں مال مقدمہ کا ذکر ہوتا ہے جو کہ پولیس کو جائے وقوعہ یا ملزمان سے‬
‫مال ہو‬
‫‪Column no 06: Prosecution witness‬‬

‫کالم نمبر چھ میں استغاثہ کے گواہان کی فہرست ہوتی ہے اس کو ٹرائل کی اصطالح میں‬
‫کیلنڈر اف وٹنس بھی کہتے ہیں‬
‫‪Column no 07: Facts of the case and opinion of investigation officer‬‬

‫کالم نمبر سات میں مقدمے کے حاالت و واقعات کا ذکر ہوتا ہے اور تفتیشی افیسر کی رائے‬
‫تحریر ہوتی ہے‬

‫‪67‬‬
‫روبکار‬

‫‪68‬‬
‫‪What is Robkar :-‬‬
‫‪Robkar is the Urdu word which means order of court.‬‬
‫‪Whenever, court issues non bailable warrant(NBW) to arrest a person either as an accused or as‬‬
‫‪witness, the same need to b cancelled with undertaking given to appear on the scheduled date and‬‬
‫‪time. So, while allowing the application for cancellation of NBW, court issues a letter/certificate‬‬
‫‪directing cancellation of warrant. This order is called Robkar.‬‬
‫‪Similarly, whenever a person is released on bail, court gives a letter or certificate to this effect that‬‬
‫‪the person concerned may b released on bail. This order of the court is called Robkar.‬‬

‫روبکار کیا ہوتا ہے ؟؟؟؟‬

‫روبکار کا مقصد ہوتا ہے کہ کسی ملزم کو مخصوص تاریخ میں پولیس گرفتار نہیں کر سکتی‬
‫یعنی کہ عدالت کی طرف سے جہاں پر ملزم نے اپنی بیل دائر کی ہوتی ہے اس عدالت کی‬
‫طرف سے ایک حکم نامہ ہوتا ہے کہ فالں ملزم کو پولیس فالں تاریخ تک حراست میں نہیں‬
‫لے سکتی اور نہ ہی گرفتار کر سکتی ہے اور ملزم کو یہ ہدایت دی جاتی ہے کہ وہ شامل‬
‫تفتیش رہے۔‬
‫اوپر دی گئی تصویر میں ایک روبکار ہے جو کہ ایک ملزم کی ہے جس کا نام ہے اظہر‬
‫عباس‪ ،‬اظہر عباس نے اپنی ضمانت قبل از گرفتاری دائر کی تھی جس میں عدالت نے اسے‬
‫جون ‪ 2023‬تک بیل‪ /‬انٹیرم بیل دے دی ہے اور اس روبکار میں یہ حکم دیا ہے کہ پولیس ‪26‬‬
‫اظہر عباس کو ‪ 26‬جون تک گرفتار نہیں کرے گی اور ملزم اظہر عباس شامل تفتیش رہے‬
‫گا۔‬
‫اسی طرح اگر ضمانت بعد از گرفتاری دائر کی ہو کسی ملزم نے تو اس کی روبکار میں یہ‬
‫لکھا جاتا ہے کہ اس ملزم کو رہا کر دیا جائے اور یہ ملزم شامل تفتیش رہے گا اور اس ملزم‬
‫کو فالں تاریخ تک گرفتار نہ کیا جائے‬
‫‪ order of the court‬روبکار کو انگریزی میں آرڈر اف کورٹ کہتے ہیں۔‬
‫روب کار کو عام طور پر بیل میں استعمال کیا جاتا ہے لیکن روبکار ایک عدالتی حکم نامہ‬
‫ہوتا ہے جس میں کسی قسم کا بھی حکم دیا گیا ہو گا جیسے کہ اوپر بتایا گیا ہے کہ زمانت‬
‫قبل از گرفتاری میں عدالت نے کیا حکم نامہ دیا ہے یا وہ کیا حکم نامہ دے سکتی ہے اسی‬
‫طرح ضمانت بعد گرفتاری میں عدالت یہ حکم نامہ دے سکتی ہے کہ فالں ملزم جس کی‬
‫گرفتاری کا ارڈر دیا گیا تھا یا جس کے خالف نان بیلیبل وارنٹ جاری کیے گئے تھے ان‬
‫بنوائی جا سکتی ہیں ‪ROBKAR‬کے لیے مزید ‪ cancellation‬کی کینسلیشن‬

‫‪69‬‬
‫وکالت نامہ فوجداری‬

‫‪70‬‬
"Vakalatnama" is a legal document that authorizes a lawyer to represent a client in a court of law.
The term "Vakalatnama" is derived from the Persian language, where "vakil" means "lawyer" and
"nama" means "document" or "paper."
Vakalatnama is a written document that is given by a client to an advocate to appear and or plead
before any court of law on behalf of him.
In English, we refer to term “power of attorney” for the urdu word “vakaltnama”. The term power
of attorney (POA) refers to a legal authorization that gives a designated person the power to act
for someone else. As such, a POA gives the agent or attorney-in-fact the authority to act on behalf
of the principal.

‫اوپر موجود وکالت نامہ فوجداری کا فارم عام طور پر عدالتی کاموں میں استعمال کیا جاتا‬
‫ہے جس پہ دو روپے کی ٹکٹ چسپاں کی جاتی ہے۔ وکیل کسی ملزم کے کیس میں بطور‬
‫وکیل پیش ہونے کے لیے عدالت میں یہ وکالت نامہ جمع کرواتا ہے۔ فارم کو بھرنے کا طریقہ‬
‫یہ ہے۔ سب سے پہلے اس عدالت کا نام اتا ہے جس عدالت میں وہ کیس موجود ہوتا ہے۔ پھر‬
‫مقدمہ نمبر تاریخ جرم اور تھانے کا نام لکھا جاتا ہے۔ پھر کیس کا ٹائٹل لکھا جاتا ہے۔جیسا‬
‫کہ اوپر لکھا گیا ہے شاہد صدیق بنام سرکار۔ اس کے بعد لکھا جاتا ہے کہ آیا یہ کس لیے‬
‫وکالت نامہ دیا جا رہا ہے۔ جیسا کہ اوپر واال وکالت نامہ درخواست قبل از گرفتاری کے لیے‬
‫دیا گیا ہے اور آخر میں العبد کے نیچے مستغیث کا نام آ جاتا ہے‬

71
CHARGE SHEET

72
Charge is an accusation; a charge to a jury is the address of the presiding judge with regard to the
duties of the jury. The court shall frame the charge in form whether he committed such offence as
alleged in the F.I.R. On framing the charge, if accused denies, the court records his denial in writing
and proceeds for trial.
Relevant Provisions : Section 221, 222, 223, 227, 228, 229, 230, 237, 238 of Criminal
Procedure Code.
Particulars / Contents / Essentials of a Charge
A charge must contain the following particulars
i. Offence to be stated: Sec 221(1)
In a charge sheet the offence must be stated, so that the accused may defend him.
ii. Description of Offence by Name: Sec 222 (2)
The Charge should give a description of offence by name which is given by that the creates
an offence.
iii. Definition of offence: Sec 222 (3)
Where the criminal law does not give any specific name to offence than a definition of the
offence must be stated.
iv. Law or Section of Law
A charge must be containing the law or the section of the law against which the offence is
alleged to have been committed.
v. Compliance with substantive Requirements of offence
The charge must fulfill the requirements of offence i.e, that it must not come within the
exceptions, or if it comes, then it must be mention in it.
vi. Language of the Charge
The charge shall be framed in English or in the Court’s language or in the language
understandable by an accused.
vii. Previous conviction of the accused
Where the accused is liable to enhanced punishment on account of his previous conviction
and such previous conviction has to be proved, such charge shall state the fact, date and place of
the previous conviction.
viii. Particulars as to time Place and Person
In is necessary that charge should contain Time of offence, Place of offence, Person against
whom offence was committed and Thing against whom offence was committed.

73
ix. Particulars of the Manner of the alleged offence
Where the particulars above are not sufficient to give notice of the offence with which the
accused is charged, the charge shall also contain the particulars of the manner in which the alleged
offence was committed.
x. Thing is Respect of which offence was committed
A charge should state the property in respect of which not is said to have been taken place,
e.g., where an offence is committed under Arms Ordinance, details of the arms recovered from the
house of the accused must be stated in the charge.
Purpose of Framing of Charge
Followings points are important for explanation of purpose of Framing of charge
i. Precise and Concise Statement about offence
Object of charge is to give accused precise and concise statement about the offence which
is charged against him.
ii. Proof against Accused
Charge is to convey to accuse with possible and sufficient clearness and certainty what
prosecution is to prove against him.
iii. Prosecution of case
Purpose of charge is to inform accused about the case, which he is going to be prosecuted.
iv. Defense against case
Charge is to enable accused to concentrate on his defense against that case, which is bring
tried against him in court.
v. No Prejudice against Accused
Object of charge is that there should be no prejudice against accused during trial before
court.
vi. Certain and Accurate Information
Charge is to deliver accused certain and accurate information about that offence against
which accused is being tried.
vii. Knowledge about Substantive Charge
Purpose of charge is to make accused known to substantive charge and is to make him
prepared for such charge before production of evidence.

viii. Knowledge about case

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 Charge is to give knowledge to accused about that case, which is being brought against
him and which is being tried in court.
When can Charge be changed & altered / Amendment?
At any time before pronouncement of judgment, charge can be altered or added. However, it is
essential that charge can only be altered on justification on basis of material on record, and that
every such alteration or addition should be read and explained to accused.
To conclude, it can be stated that court can convict accused for that offence with which he
is not charged, but he should have committed such offence. However, if charged is framed is such
a vague manner that essentials of offence with which accused is convicted is not brought out in
charge, charge is then considered defective.

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DEATH REGISTRATION CERTIFICATE

76
FRC (FAMILY REGISTRATION CERTIFICATE)

77
 Family Registration Certificate (FRC) is a mean of being identified with your NADRA’s
record. This provides the family composition. Please note that the Family Registration Certificate
(FRC) helps in Embassy use mostly but cannot be used for any Legal requirement.
One apply for FRC in the following three categories:
• By Birth – The produced certificate will list your family including the details of your
parents and siblings.
• By Marriage – The produced certificate will list your family including the details of your
spouse and children.
• By Adoption – The produced certificate will list your family including the details of your
guardian.

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‫ عبوری ضمانت فارم‬INTERIM BAIL FORM

79
 When an accused applies for a pre-arrest bail, the court grants him an interim bail till the
final decision of the pre-arrest bail. This is why if interim bail is not granted, the accused will get
arrested, the n what will be the benefit for applying for pre-arrest bail.
The concept of the accused being innocent until proven guilty is highlighted through bail,
which plays a significant part in the any legal system. One of the most essential fundamental rights
that each individual has is the right to liberty and dignity. These rights also apply to those who are
charged. These rights may not be denied to anyone. Thus, the granting of bail preserves the
accused’s fundamental rights. The idea of interim bail is crucial because an accused person may
be in danger of being detained even before the outcome of the hearing on his bail is known. Interim
bail is therefore granted when the court is certain that doing so will prevent the accused from being
unjustly imprisoned or detained. In general, the magistrate or court should use the ability to grant
interim bail whenever it is practical. Such an exercise of authority will successfully dissuade abuse
of the criminal justice system for purposes unrelated to its purpose.

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‫‪ /BAIL BONDS‬مچلکہ و ضمانت نامہ واسطے حاضری عدالت‬

‫‪81‬‬
‫وارنٹ گرفتاری‬ ARREST WARRANT

82
‫فرد طلبانہ‬

‫طلبانہ فارم وہ فارم ہے جس میں کسی چیز‬

‫کے طلب کروانے کسی شخص کو یا کسی دستاویزات کو طلب کروانے کے لیے کورٹ میں داخل کیا جاتا ہے‬

‫‪83‬‬
‫درخواست اجرا ڈگری‬

‫‪84‬‬
‫پتہ فارم‬

‫‪85‬‬
‫فہرست دستاویزات پیش کردہ‬

‫‪86‬‬
‫فہرست دستاویزات پیش کردہ منحصرہ‬

‫‪87‬‬
‫ڈائری فارم‬

‫‪88‬‬
‫وکالت نامہ ‪/‬مختار نامہ‬

‫‪89‬‬
‫نکاح نامہ‬

‫‪90‬‬
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Meaning and Importance of the Different Clauses of the Nikah Nama in Pakistan
Nikah Nama, is an Islamic Marriage Contract, which is signed by both partners at the time
of their marriage. This document is fundamental in officiating the marriage in Islam and helps in
determining the rights and duties of both partners in a marriage (Husband and Wife). In Pakistan,
the Nikah Nama for Muslim couple is designed under the 1961 Muslim Family Ordinance, which
determines different particularities of a marriage. The Nikah Nama can be later registered with the
National Database and Registration Authority (NADRA), after which the status of the bride and
the groom can be updated on their Computerized National Identity Card (CNIC).
Clause by Clause Breakdown of the Nikah Nama
The clause-by-clause breakdown of Nikah Nama is as below:
Clause 1 to 6 – Basic Information of the Bride and Groom
Clause 1-6 of the Nikah Nama include basic information. Like the address of the place
where the marriage ceremony is taking place, name of the bride and groom, name of their fathers
and their addresses including their age.
Note: Clause no. 3 and clause no. 6 are very important because the age of the groom and the bride
are stated in these clauses respectively. This clause is important to identify child marriages, which
are illegal in Pakistan. However, in most parts of the country the minimum age of the bride is 16
and the age of the groom is 18, with the exception of the Sindh province, where the minimum legal
age of marriage for both the bride and the groom is 18 years. Apart from the Sindh province, the
Child Marriage Restraint Act 1929 is currently applicable across Pakistan, which states:
"child" means a person who, if a male, is under eighteen years of age, and if a female, is
under sixteen years of age.
Clause 7 to 11 – Information of Attorneys and Witnesses
These clauses include the information of the attorneys and witnesses that are assigned by the bride
and the groom.
Clause 12 – Date of the Marriage
Clause 12 is about the date of the marriage
Clause 13 to 17 – Particularities related to Haq Mehr
Section 13 to 17 are very important part of the Nikah Nama for bride as the amount of her Haq
Mehr is stated in this section. Haq Mehr (the terminologies used for Haq Mehr in English version
of the Nikah Nama are ‘Dowery and ‘Guarantee for marriage’) is not only a gift that a woman gets
at the time of the wedding, but it also guarantees her financial protection in case of a divorce. It is
legally binding on the groom to pay the woman her Haq Mehr. It can be waived off by the will of
the bride.

92
Haq Mehr can be in any form like cash, property, or jewelry (that is valuable).
• Muajjal, (‫ )معجل‬the kind of Haq Mehr that is paid upfront at the time of the marriage.
• Muwajjal, (‫ )موجل‬the kind of which is deferred and can be paid later depending on the
timeframe decided in the agreement or whenever the wife demands.
Clause 15 of the Nikah Nama states whether a part of the Haq Mehr is being paid up front and if
it is what is the amount.
Clause 16 discusses whether the bride has been given any property as dowry. If so, the value of
the property and the specification that both parties have mutually agreed on.
Clause 17 talks about any special conditions tied to Haq Mehr.
Clause 18 and 19 – The Right to Divorce
This is one of the most important clauses in the Nikkah Nama, which guarantees the bride a right
to divorce. Unfortunately, in many cases in Pakistan these sections are cut off at the time of the
Nikkah without consultation from the bride.
Clause 18 asks whether the husband has granted his wife the right to divorce and if so, what are
the terms decided for it? While clause 19 asks if the husband’s right to divorce has been curtailed
in any way.
Note: If the wife is granted the right to divorce, she can divorce her husband and keep her Haq
Mehr. If the right to divorce is not granted, the wife must file for Khula from court. Khula is
conditional, it is granted by the court and the wife must forego her Haq Mehr in Khula cases
Clause 20 – Guarantees and Allowances
Clause 20 asks the parties if there is any agreement among them related to the monthly allowance
and guarantees while they are together as a married couple. If they do, they can state the
particularities of it.
Though it is generally interpreted to be about the wife’s monthly allowance from her husband, but
experts say that this section can include the division of responsibilities and chores among the
couple, guarantee the wife the right to pursue her professional career or education. This section is
important in sense that it can help set tone for the marriage and can be helpful in avoiding any
conflict that arises later in context of roles and responsibilities of the husband and wife.
Clause 21 and 22 – Marital Status of the Groom
This is another important section of the Nikah Nama. It asks whether the groom is already married
or has another wife. If so, has he taken the permission of his first wife to enter another marriage
and submitted the proofs of permission for second marriage.

Clause 23 to 25 – Information of the Nikkah Khawan, Date and Fee of Registration

93
This part includes the information of the Nikkah Khawan, the person who performed or solemnized
the Nikkah, the date the Nikkah was registered and the fee that was paid for registration.
Signatures:
Underneath clause 25, there is a section that include the signatures of the bride, groom, their
witnesses, Nikkah Khawan and the Nikkah-registrar.
Note: Under the Muslim Family Law Ordinance 1961 it is obligatory to register your Nikah Nama
with your union council and obtain a Marriage Registration Certificate (MRC).
You can also obtain a Family Registration Certificate (FRC) from NADRA which will grant you
access to different public services as family as well as visa processes for any intended travel.

94
‫سمن‬

‫‪95‬‬
‫نوٹس‬

‫‪96‬‬
‫اقرار نامہ ‪ /‬ثالثی نامہ‬

‫‪97‬‬
C.D.I. FORM

98
‫شیڈول گواہان‬

‫‪99‬‬
FINAL INTERPRETATION
I Thank you to Mr. Masood Arif Butt at the Arif Law Associates of Multan for having me
as an intern over the course of the Summer. My introductory experience of working in the legal
field could not have been better suited with anyone else. Overall, I have consequently found myself
more motivated than ever to excel in my studies, so that I may pursue a career as an attorney. The
knowledge and skills that I garnered as an intern span from personal injury law to manifesting self-
discipline to honing one's skillset to perform at the apex of your abilities. The considerable range
of knowledge that encapsulates just one subset of the law was an initial challenge that I faced in
my position. I had to develop a true thirst for learning which is something I will take with me in
perpetuity. An important lesson that I gleaned from my experience is the undeniable importance
of interpersonal relationship management. In short, you must be able to effectively communicate
with others. It could be argued that it is a skill that is just as important as the knowledge needed to
perform the basic operations of a job. This is not something you get to work on too often in a
standard classroom setting, and my internship was an exceptional platform to develop past my
modicum level of experience. It was thoroughly enjoyable to be able to personally help expand the
reach of the law firm by creating a new website to represent the firm. Overall, I am extremely
thankful for the opportunity presented to me by the Gillani Law College and Arif Law Associates.
I know that I owe it to them and myself to carry on with my progression in the legal field with the
utmost diligence and hard work.

100