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IN THE COURT OF DISTRICT & SESSION JUDGE AT KARACHI SOUTH.
Cr. Misc. Application No. of 2024
[PETITIONER NAME]
S/O [FATHER NAME]
MUSLIM, ADULT, R/O
REHMAN COLONY GHAZALI ROAD
MAHMOODABAD FLAT NO. B-66
KARACHI………………………………………………….. PETITIONER
VERSUS
STATION HOUSE OFFICER
P.S [POLICE STATION REDACTED]
S.S.P COMPLAINT CELL
[DISTRICT REDACTED]
KARACHI ……………………………………………. RESPONDENT(S)
___________S/O __________…………… PROPOSED ACCUSED
APPLICATION UNDER SECTIONS 22-B OF THE
CODE OF CRIMINAL PROCEDURE, 1898.
It is most respectfully submitted on behalf of the above-named Applicant/Petitioner as follows:
That the petitioner is a respectful and law abiding citizen of the Islamic republic of Pakistan and the petitioner is a poor person residing at the above mentioned titled address along with his family.
That the petitioner runs a family business of garments/ clothes and is the owner of a garment shop situated at [BUSINESS LOCATION REDACTED].
That from past couple of months the proposed accused namely ________ is threatening and blackmailing the applicant for an amount of extortion i.e. ______________ and in case of failure to do so the said proposed accused has extended the threats of grave consequences.
That it is pertinent to mention here that the applicant has no direct connection or relation with the said proposed accused.
That it is pertinent to mention here that the applicant is the sole bread winner of his family and that the applicant with honesty and devotion is running the said shop to afford and earn the livelihood for his family. However, such illegal and criminal acts as well as threats extended by the said proposed accused to the applicant is causing serious threat to the right to liberty, right to life and right to do business as per the fundamental rights laid down in the constitution of 1973.
That there is an apprehension to the Applicant’s life and liberty at the hands of the said proposed accused. It is submitted that the Applicant requires protection under the law and that of his family from the said proposed accused.
That the applicant having no option except to approach this Hon’ble Court to save the A
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