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APPLICATION UNDER SECTION 265-K

OF CR.P.C
Posted by Mumtaz Yousaf
Date: November 21, 2016
in: Legal Drafts
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IN THE COURT OF MR.________, LEARNED SPECIAL JUDGE


CENTRAL, ISLAMABAD.
Mr. Sohail Arshad S/o Guldastan, R/o D-14, Islamabad.

PETITIONER

VERSUS

The State

..RESPONDENT

IN A CASE VIDE FIR NO. ____, DATED 02-11-2016, UNDER


SECTION 420, 468, 471, 419, 409, 109 PPC R/W 5(II) 47 PCA,
FEDERAL INVESTIGATION AGENCY ISLAMABAD CIRCLE.

APPLICATION UNDER SECTION 265-K OF CR.P.C FOR ACQUITTAL


OF ACCUSED IN ABOVE MENTIONED CASE.
RESPECTFULLY SHEWETH:-

1. That the petitioner is the accused in the above mentioned case which is pending for
adjudication before this Honorable Court and is fixed for today.

2. That the State through on the complaint of Mr. ______ S/o _____ R/o ________,
Islamabad, the Federal Investing Agency Islamabad Circle has registered the above
mentioned case against the petitioner.

3. That the allegation leveled against the petitioner in the FIR is that the petitioner affidavit
issued without verifying/adopting the procedure.

4. That the allegations leveled in the FIR are false, frivolous, baseless, flimsy and concocted
and the petitioner has no concerned whatsoever with the commission of the said offence.
5. That the petitioner has been falsely implicated in the case by the prosecution as well as
the complaint for the ulterior motives and to cause humiliation and harassment to the
petitioner.

6. That the parties have been entered into a compromise at bail stage and complainant
submitted an affidavit and his statement got recorded before this Honble Court and
Order was passed by this Honble Court.

7. That in light of the statement, affidavit of the complainant and order passed by this august
Court there is no chance of conviction it would be futile exercise if the trial is continued.

8. That the prosecution has badly failed to produce evidence before this Honourable Court,
because more than 05 opportunities have been given to the prosecution but failed to
produced even a single evidence/witness before this Honble Court.

9. That in view of the facts available on the prosecution record, there is no justification of
continuing the process of case. These are the valid and sufficient grounds of abusing
court process and wastage of precious time of the court.

10. That petitioner is facing the agony of trial and there is no chance of conviction of the
petitioners/accused.

11. That if this application is not accepted the petitioner will suffer an irreparable loss.

In the circumstances, it is therefore, most humbly prayed that the accused/Petitioner


may graciously be acquitted from the charge under section 265-K Cr.P.C, in the best interest of
justice.

PETITIONER

THROUGH

Advocate