IN THE COURT OF SESSIONS JUDGE, MULTAN.

Naveed Iqbal S/o Saghar Iqbal Siddiqui, caste Siddiqui, R/o 199,
Rehmat Colony, M.D.A. Road, Multan.
Petitioner/Accused
Versus
Union Bank Ltd., Abdali Road, Multan, Through Chief Manager.
Respondent/Complainant

Revision Petition U/s 439-A, read with

section 435 Cr.P.C. against the order passed
by the learned Magistrate Sec-30 Sadiq
Masood Sabir dated 15.10.2001 by which
the learned trial court dismissed the
application U/s 249-A Cr.P.C. of petitioner.

CLAIM IN REVISION: -
To accept the Revision Petition by setting
aside the impugned order and to accept the
application of the petitioner U/s 249-A
Cr.P.C.

Respectfully Sheweth: -
1. That the revision petitioner/alleged accused was an employee
of respondent as Assistant Vice President having its branch at
Abdali Road, Multan. The petitioner remain associated with
the said bank and after lapse of some period, the services of
revision petitioner were terminated by the management of the
respondent bank vide letter dated 1.9.97.
2. That feeling aggrieved by the termination, the petitioner filed
a civil suit on 18.3.98 for the recovery of damages caused by
that illegal and unlawful termination. During these
proceedings of civil suit the respondent/complainant, extended
 pressure on the petitioner and with ulterior motive and
malafide intention, as a counter blast filed a complaint against
the petitioner on 24.11.99 U/Ss467/468/471 and 474 P.P.C.
The copy of plaint and complaint are Annexes “A & B”.
3. That the respondent/complainant produced Rao Ikhlaq Ahmad
as P.W.1 and closed the evidence on same day without
tendering any documentary evidence or producing any oral
evidence for corroboration of their plea taken in the
complaint. The learned trial court on this in-sufficient oral
evidence of P.W.1, summoned the petitioner as an accused
without mentioning any offence vide order dated 10.12.99.
The copy of evidence of P.W.1 and order dated 10.12.99 are
Annexes “C & D”.
4. That the petitioner appeared before the trial court as required
under the law and subsequently filed an application U/s 249-A
Cr.P.C. The learned trial court dismissed the application vide
order dated 15.10.2001. The copy of the application and order
are Annexes “E & F”.
5. That the orders dated 10.12.99 and 15.10.2001 are impugned
inter alia on the following: -
GROUNDS
a) That both the orders are illegal, unlawful and passed
without application of judicial mind.
b) That both the orders are against the justice, natural
justice and law of equity.
c) That both the orders are passed by the learned trial
court against the facts of the case.
d) That both the orders are passed in violation of essence
of criminal law and procedure.
e) That all the offences mentioned in the complaint are
related with the preparation and use of forged
documents but no document was produced during the
preliminary evidence.
f) That the complainant bank has no forged document in
its possession, because during the process of recording
 evidence in civil suit as D.W.2 (Ikhlaq
Ahmad/complainant) admitted this fact. The said D.W.2
produced the photo-copies of all the documents in
documentary evidence in the civil suit. In this situation,
when there are no original documents in the possession
of the complainant, no preparation of forged document
can be proved, resultantly no question of using the said
forged document shall arise. Copy of evidence is Annex
“G”.
g) That keeping in view the preliminary evidence of
P.W.1, the requirements of section 249-A Cr.P.C. are
fully satisfied.
h) That in the light of evidence produced by the
complainant no charge can be framed and if framed
cannot be proved, so there is no possibility of any
conviction of petitioner.
i) That both the impugned orders have caused a great mis-
carriage of justice.
Keeping in view the above-mentioned
circumstances, it is most respectfully submitted
that this revision petition may pleased be
accepted, both the impugned orders may please
be set aside and the complaint may please be
dismissed U/s 203 Cr.P.C./the revision petitioner
may please be acquitted U/s 249-A Cr.P.C.
During the pendency of this revision petition the
proceedings in the trial court may also be
suspended/stayed.
Humble Petitioner,
Dated: ________

Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176