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IN THE COURT OF SESSION COURT, LAHORE

Habeas Petition No.____________/2010

Mst. Shahida Sardar daughter Muhammad Sardar, wife of

Naseer-ul-Hassan, Resident of House No.09 Street No.170,
Chaman Parak, Near Govt. Shalimar College, Baghban Pura,
Lahore.

……
PETITIONER

VERSUS

1. Naseer-ul –Hassan son of Nazeer Ahmed, resident of

House No.8-A, Street No.22 Near Aik Minar Wali
Masjid, Muslim Abad, Lakho Dayr Road, Lahore.
2. S.H.O Police Station BaghbanPura, Lahore

…….RESPO
NDENTS
___________

PETITION under section 491 Cr.P.C for

recovery/ production and release of
minors/detenue Zara Naseer Aged 5
years, Suleman aged about 8 years
presently confined in the illegal,
unlawful and improper custody of
respondent No.1
___________

RESPECTFULLY SHEWETH:

That the addresses of the parties are sufficient to

serve them summon/ notices are true and correct.

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2. That on 23.09.2000 marriage was solemnized

with the respondent No.1 at Lahore according to Muslim rites

against the sum of Rs.30,000/- and 3 Tolla of Gold Ornaments as

dower amount.

3. That only few days of happiness were taken by the

respondent to the petitioner as far as matrimonial life but after

that life of the petitioner was made as miserable by the

respondent No.1

4. That on 28.05.2010 respondent No.1 after severe

beating to the petitioner and expel her from his house and snatch

both minors namely Zara and Suleman from the petitioner.

5. That the minors/ detenue are in unlawful, unfair and

improper custody of the respondent No.1.

6. That the as the minors/ detenue are of tender age and

petitioner can do to be take care of the minors/detenue as a real

mother.
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PRAYER:

It is, therefore, very humbly prayed that the

minors/detenue be ordered to recovered from the illegal, unlawful

and improper custody of the respondent No.1 be produced before

this Honourable Court and be set at liberty as per free will and

desire of the minors/detenue.

It is further prayed that legal action be taken against

the respondent No.1 and other who are responsible for detention

of the minors/detenue and keeping them in their illegal and

unlawful confinement and detention.

It is further prayed that the respondent No.2 may

also be directed to recover the minors/detenue from the

respondent No.1 and be produced before this Honourable Court

for the liberty of the person and for the fair decision of the present

petition.

PETITIONER
Through

(RANA MAJEEB-UR-REHMAN)
Advocate
Lawyer Chambers, Cantt Courts, Lahore

Dated: 03.06.2010
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IN THE COURT OF SESSION JUDGE, LAHORE

Habeas Petition No._______________/2010

In re:

Muzammal Jamil…………. Vs ………. Station House Officer

I N D E X

S. No Documents Date Pages

1. Petition 31.05.2010 1 to 3

2. Affidavit to above 31.05.2010 4

3. Annex.”A” Nikah Nama 31.04.2010 5 to 6

4 Power of Attorney 31.05.2010 7

_______________________________________________

PETITIONER
Through

(GHULAM MUSTAFA CHAUDHRY)

Advocate High Court,
003-Lawyers Chambers, District Courts, Lahore

Dated: 13.05.2010
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IN THE COURT OF SESSION JUDGE, LAHORE

Habeas Petition No._______________/2010

In re:

Mst. Shahida Sardar …………. Verus ………. Naseer-ul-Hassan.

(Petition Under Section 491 of Cr.P.C)
__________

AFFIDAVIT of Mst. Shahida Sardar daughter

Muhammad Sardar, wife of Naseer-
ul-Hassan, Resident of House No.09
Street No.170, Chaman Parak, Near
Govt. Shalimar College, Baghban
Pura, Lahore.
___________

I, the above named deponent do hereby solemnly affirm

and declare as under:-

That contents of the accompanying petition

for the recover of minors are true and correct
to the best of my knowledge and belief and
nothing material has been suppressed from
this Honourable Court.

DEPONENT

VERIFICAITON
Verified on oath at Lahore, this the 3rd day of June,
2010 that contents of the above affidavit are true and
correct to the best of my knowledge and belief.

DEPONENT