Application Under Section 169 Draft

To,

The SSP Investigation (South),

Karachi.

Sub: APPLICATION FOR DISHCARGE OF APPLICANT WITH REFRENCE TO THE FIR NO. 33/ 2025 UNDER SECTION 169 OF CRPC 1898.

Respected Sir,

It is respectfully submitted that I, Umair khan S/o Abdul Sattar R/o Karachi working as an Assistant Protocol Officer in the Government of Sindh has been falsely implicated in the Fir no. …./ 2025 by the complainant namely ……. (P.A) OF GHULAM NABI (land Grabbers and Water Tanker Mafia) as the complainant and his group are habitual offender(s) of law and are also known as famous land grabbers and water tanker mafia in the city.

That the complainant has narrated a false and fabricated story in the FIR, whereas the actual incident occurred to me on dated: On dated: 18-01-2025 around 1940 hours at main preedy street near Islamia Girls College. I was on my way to my duty station along with one of my friend namely ........ S/o ……… who has also been nominated in the FIR by the ulterior motives of the complainant, while a motorcyclist namely Fahad began to follow my car as well as began to film/ record a video without any apparent reason. Furthermore, he attempted to intimidate me with threats during the filming/ recording of the said incident on his cellphone. In response, I tried to stop him on the road and asked him to delete the video which he had recorded upon which he began to extend me further threats of dire consequences. Despite this, he continued his attempts to record and kept issuing the threats.

Further that I made a telephonic call to the SHO brigade upon which he asked me to submit an application to the concerned p.s. (call log marked as annexure A). Hence, I moved a written application in the concerned p.s on dated: 19-01-2025 marked herewith as an (annexure B). I also produce the official letter dated; 23RD January 2025 from the department of the Protocol Cell Government of Sindh being on official duty on the date of said incident marked as (annexure C)

It is further submitted that the same complainant filed a civil suit no.1294/2024 against me which is pending before the Honourable court of ….. senior civil judge at Karachi, east in which the Honourable court has granted