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IN THE COURT OF DISTRICT & SESSION JUDGE (CENTRAL) AT KARACHI
Cr. M. A. No. [REDACTED]/2024
Mst. [REDACTED] D/o [REDACTED]
Muslim, Adult, R/o House No [REDACTED],
Ishaqabad [REDACTED]
FB Area [REDACTED],
Karachi ………………………………………….… Petitioner
VERSUS
The S.H.O
P. S, Sharifabad [REDACTED]
Karachi.
S.S.P
District Central
Karachi
Additional I.G Sindh
Karachi
I.G Sindh
Karachi …………………………………………. Respondent(s)
[REDACTED]
(I.O Ps Sharifabad [REDACTED]
[REDACTED]
(SIO Ps Sharifabad [REDACTED]
[REDACTED]
(DSP) Central .................……………….Proposed Accused(s)
APPLICATION U/S 22-A and 22-B OF THE CODE OF CRIMINAL PROCEDURE 1898
It is respectfully submitted by the above named Petitioner/Complainant that this Hon'ble Court may be pleased to direct the Respondent above named to register an First Information Report against the following accused persons on the consideration of the facts and grounds, amongst others, viz:-
That the petitioner is a bonafide and law abiding citizen of Pakistan and at presently enrolled as a practicing advocate in Sindh Bar Council [REDACTED] holding Ledger No. [REDACTED] as well as member of Karachi Bar Association [REDACTED] holding Ledger No. [REDACTED].
That on dated [DATE REDACTED] the petitioner lodged an FIR against the accused who was hired on the same day as a driver via social media by the petitioner who stole the said vehicle bearing Reg No. [REDACTED], MAKER [VEHICLE REDACTED], [COLOR REDACTED] belonging to the petitioner. Thereafter, petitioner went to the concerned PS, Sharifabad [REDACTED], 408ppc, PS Sharifabad [REDACTED]
(Photocopy of the FIR No. [REDACTED]/2024 is marked herewith as an annexure )
That the investigation of the said FIR was handed over to the proposed accused no.1 namely [REDACTED] (I.O Sharifabad [REDACTED], both the proposed accused(s) had been extremely negligent towards the investigation of the said matter as well as there are sufficient evidences against the proposed accused no.1 and no.2 of being involved with the accused nominated in the Fir. 174/2024 by the petitioner.
(Photocopy of the application for the action against the misconduct of both the proposed accused n
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