491 Petition Crpc Draft

IN THE COURT OF DISTRICT AND SESSIONS JUDGE AT KARACHI

CENTRAL

Cr. M.A. No. ____________/2024

……………..

W/o Mirza Zahid Baig

Muslim, Adult R/o Flat no………..,

Liaquatabad, Karachi …………………………… Petitioner

V/s

The Station House Officer (S.H.O)

P.S. Liaquatabad.

Karachi.

The SSP Central

Karachi

………… (Founder .......... Trust)

Muslim, Adult, R/o

Karachi.

Aagosh Trust

(Through the owner)

Located at Khayaban-e-Bahria,

DHA Phase 5, Defence Housing Authority

Karachi.………………………………………….. Respondent(s)

……………. D/o

Muhammad Ishaq……………………………….. Detenue

PETITION UNDER SECTION 491 OF THE

CRIMINAL PROCEDURE CODE, 1898

That the Petitioner named above respectfully submits as follows:-

That the petitioner is a law abiding citizen of the Islamic republic of Pakistan and the petitioner is a poor old lady residing at the above mentioned address along with her family.

That the Petitioner namely Sugheera majida talat is the real maternal grandmother of the detenue while Respondent no.3 Mrs. ……….. is the founder/ owner and runs a trust namely Aagosh Trust located at Khayaban-e-Bahria, DHA Phase 5, Defence Housing Authority Karachi i.e. Respondent no.4, who is illegally and unauthorizedly retaining the custody of a minor girl namely Quratulain D/o Muhammad Ishaq i.e. detenue.

That the detenue had been living peacefully with the petitioner since young age as the father of the detenue passed away due to terminal illness as well as the mother of the detenue is mentally disable as well and is currently admitted in edhi.

That in the month of August 2024 the maternal aunt(s) of the detenue took the detenue along with them assuring the petitioner that for the purpose of continuing higher studies they are taking detenue to a hostel for her further studies.

That the maternal aunt(s) of the detenue instead of enrolling the detenue to the hostel took her along with them to an old age home namely Aagosh Trust located at Khayaban-e-Bahria, DHA Phase 5, Defence Housing Authority, Karachi which is run by respondent no.3.

That the maternal aunt(s) of the detenue assured the petitioner that the detenue is continuing her further studies at the hostel peacefully witho