Sample Transfer Application Qadir

IN THE COURT OF DISTRICT & SESSIONS JUDGE, CENTRAL, AT KARACHI

Criminal Transfer Application No.______ of 2023

[APPLICANT/ACCUSED NAME]

S/o [FATHER NAME]

& [CO-ACCUSED NAME] S/o [CO-ACCUSED FATHER NAME] …………… Applicant/Accused

(Both are presently confined in central jail)

Versus

[RESPONDENT NAME] S/o

[RESPONDENT FATHER NAME]

R/o Flat no. L-386 sector II

[AREA REDACTED] Karachi …………………….. Respondent

FIR NO: 22/2023

U/S: 302/397/392/34

P.S: LIAQUATABAD

APPLICATION UNDER SECTION 528 OF THE CODE OF CRIMINAL PROCEDURE, 1898

It is most respectfully submitted on behalf of the Applicant, named above that this Hon’ble Court may be pleased to transfer the above mentioned FIR No. : 22/2023 P.S: LIAQUATABAD U/S: 302/397/392/34 PPC, 1860 pending before the Court of Learned Court of VIITH Additional District & Sessions Judge Central at Karachi to another Learned Additional District & Sessions Judge having jurisdiction upon consideration of the following facts and grounds amongst others: -

F A C T S

Brief facts of the case as narrated in the FIR are that complainant stated that the complainant is an ambulance driver in edhi service. That my mother in law had been residing alone from 12 years to 13 years in the house no. 174 qasimabad, [AREA REDACTED] Karachi. That she also kept a maid at her house two days ago. That on dated 13/01/2023 my wife went to meet with her mother at her house in the evening and knocked on the main gate to which her mother did not open the door and my wife kept knocking. Then, my wife asked a boy from locality to climb the wall of the house of my mother in law and to open the main gate. As soon as my wife entered the house of her mother she saw that her mother is lying on the bed faced down while blood was streaming down from her neck in a lifeless condition. My wife hurriedly called me and upon my arrival to the house of my mother in law. We discovered that the amount of committee, two android cellphones and one keypad cellphone owned by my mother in law were missing from the Almirah. That I, immediately called on 15 and upon the arrival of police the dead body of my mother in law was sent to hospital for post mortem. Th