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Petitioner
versus
1.
2.
3.
4.
5.
Respondents
WRIT
PETITION
UNDER
ARTICLE
199
OF
CONSTITUTION
OF
THE
ISLAMIC
REPUBLIC
OF
PAKISTAN,
1973
Respectfully
Sheweth:
1.
2.
BACKGROUND
AND
FACTS
That
the
Petitioner
is
a
citizen
of
the
Islamic
Republic
of
Pakistan
and
holder
of
Computerized
National
Identity
Card
No.
37405-7270354-1.
He
is
a
resident
of
Gulshan
Dadan
Khan,
a
neighborhood
in
Rawalpindi
established
by
the
Petitioners
grandfather.
He
hails
from
one
of
the
most
respectable
families
in
the
region.
He
earns
his
living
through
various
businesses
including
CNG
supply
and
has
lived
more
than
five
decades
of
his
life
as
law-
abiding
citizen.
The
Petitioner
has
3
children,
among
whom
is
the
26-year-old
son,
Hammad
Dadan,
Advocate.
Advocate
Hammad
Dadan
(hereinafter
referred
as
detenu)
was
born
and
raised
in
the
Islamabad-Rawalpindi
region.
He
did
his
O
Levels
from
Beaconhouse
School
System,
Margalla
Campus
and
his
A
Levels
from
3.
4.
5.
6.
ix. That
there
is
no
other
alternate
and
efficacious
remedy
available
to
the
Petitioner
but
to
invoke
the
constitutional
jurisdiction
of
this
Honourable
Court.
PRAYER
In
view
of
the
foregoing
facts
and
circumstances
it
is
most
respectfully
prayed
that
this
Honourable
Court
may
be
pleased
to:
a) issue
a
writ
in
the
nature
of
habeas
corpus
to
the
Respondents
directing
them
to
immediately
produce
the
detenus
before
this
Honorable
Court;
b) provide
redress
for
the
criminal
offences
committed
by
the
Respondents
against
the
detenus
by
directing
the
relevant
authorities
that
criminal
charges,
under
the
relevant
laws
of
the
Islamic
Republic
of
Pakistan
be
registered
against
those
responsible
for
the
abduction
and
subsequent
detention
of
the
detenus;
c) Any
other
relief
that
this
Honourable
Court
deems
fit
may
also
kindly
be
granted.
Petitioner
through
ZAHOOR
ELLAHI
MIRZA
SHAHZAD
AKBAR
Advocate
High
Court
Barrister-at-Law
Advocate
High
Court
UMER
GILANI
Advocate
High
Court
Certificate:
Certified
that
the
subject
matter
has
never
been
directly
or
substantially
adjudicated
upon
by
any
court
of
Law;
and
this
is
the
first
Writ
Petition
filed
on
the
aforementioned
subject.
Counsel
BEFORE
THE
HONOURABLE
ISLAMABAD
HIGH
COURT,
ISLAMABAD
Writ
Petition
No:
_____/2015
Mumtaz
Anwar
Abbasi
versus
SHO,
P.S.
I-9
and
others
WRIT
PETITION
UNDER
ARTICLE
199
OF
CONSTITUTION
OF
THE
ISLAMIC
REPUBLIC
OF
PAKISTAN,
1973.
AFFIDAVIT
I,
Mumtaz
Anwar
Abbasi
S/O
M.
Anwar
Abbasi,
do
hereby
solemnly
swear
and
affirm
that
the
contents
of
my
accompanying
Writ
Petition
are
all
true
and
correct
according
to
the
best
of
my
knowledge
and
belief
and
nothing
has
been
concealed
from
this
Honourable
Court.
Deponent
Verified
on
oath
at
Islamabad
on
this
________
day
of
June,
2015
that
the
contents
of
my
above
affidavit
are
all
true
and
correct
according
to
the
best
of
my
knowledge
and
belief
and
that
nothing
has
been
concealed
from
the
Court.
Deponent