IN THE HONOURABLE LAHORE HIGH COURT, LAHORE Writ Petition No. 12023 ‘Imran Ahmad Khan Niazi v. Federation of Pakistan etc’. INDEX Sr.No. Description of Documents Annexure | Page No. | 1._| Writ Petition with Affidavit 1-1/6 Copy of FIR No. 691 / 2022 dated 07.11.2022. —a_ |_| Copy of Dawn Newspaper clipping dated 03.03.2014 Bo 8-0) 4. _ | Copy of FIR No. 463 / 22 dated 21.10.2022 c 20 5. _| Copy of Application submitted before learned pene Additional Sessions Judge expressing Security i DA Concerns. 6. Letter of Chairman PTI to CJP dated 05.03.2023 7, | Letter of Shah Mehmood Qureshi & Asad Umar to CJP dated 05.03.2023. 8. _| Copy of FIR No. 153/23 & 154/23 dated 28.02.2323 9.__| CM for Exemption from Certified Copies along with Affidavit. 70. | Power of Attorney Petitioner, Through Barrigter Salman Safdar Advckate Supreme Court LL.B, (LSE, UK); Bar-at-Law (Lincoln's. Inn) Ground Floor, Alvi Manail, 9 Fane Road Lahore,q IN THE HONOURABLE LAHORE HIGH COURT, LAHORE Writ Petition No. 12023 “Imran Ahmad Khan Niazi v. Federation of Pakistan etc’. Imran Ahmad Khan Niazi S/o Ikram Ullah Niazi Resident of Zaman Park, Street 1, Lahore, Pakistan Petitioner Versus 1. Federation of Pakistan through Secretary Pakistan, Secretariat Constitution Avenue G-5/2 Islamabad. 2, Federal Secretary Law & Justice Division, Pakistan Secretariat, Constitution Avenue G-5/2 Islamabad. 3, Additional Chief Secretary Home Department Punjab Secretariat, Lower Mall, Lahore. 4, Inspector General of Police (1G), Punjab, CPO Building near Anarkali Lahore Police. 5, Inspector General of Police (1G), Islamabad Mauve Area G/ 11-1, Islamabad. 6. Inspector General of Motorway (IG), Punjab Motorway Police Headquarter Islamabad. 7. Commissioner Lahore Division, Lahore, Shadman 1, Jail Road, Lahore, 8, Deputy Commissioner Islamabad, DC Office Islamabad, 9. Secretary Defence, Government of Pakistan, Islamabad. 10. Province of Sindh through Secretary Home Department, Karachi. 11. Province of KPK through Secretary Home Department, Peshawar. 12, Province of Balochistan through Secretary Home Department, Quetta. 13. Capital City Police Officer (CCPO), Queens Road, Lahore 14. Superintendent of Police, (SP) Civil Lines, Lahore.15. DIG Operations DIG Office Lahore 16. Station House Officer (SHO), P.S Garhi Shahu, Lahore. 17. The State, «Respondents WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF PAKISTAN, 1973. Respectfully Sheweth, 1, That the Petitioner through the instant Petition wishes to invoke the Constitutional Jurisdiction of this Honourable Court for the enforcement for his basic Fundamental Rights which are guaranteed under the Constitution of Islamic Repul of Pakistan 1973. 2. That the Petitioner is one of the few honest and dignified statesmen of Pakistan having a well-established national and international stature. The Petitioner has made significant contributions to the socio-economic forefront of the country through his humanitarian and philanthropic services, only one of which is Shaukat Khanum Cancer Hospital(s) that has over the years emerged as the most credible specialized cancer hospitals of Pakistan. Recognition of the Petitioner as fa statesman began from a tiresome journey to challenge the years long, unfettered, corrupt political landscape of the Country. To accomplish this goal, the Petitioner began in the year 1996 and successfully formed his own party, now most famously known and chanted as Pakistan Tehreek-e-Insaaf (hereinafter referred to as PTI’), 3. That the Petitioner's mandate and growing popularity it got from the masses became a threat to the already well-established political forces, In the year, 2013, the Petitioner's political party namely, PTI, against all odds defeated the long: stonding ruling party of the Province of Khyber Pakhtunkhwa (‘KPK') and successfully formed its governm + During the Petitioner's tenure in KPK, the© Petitioner amongst other changes, managed to reform the K'K police by creating check and balance: to ensure fairness for every citizen and curtailed terrorism. After Five (5) more years of the Petitioner's struggle, on the 18 of August 2018, with a massive margin, his party PTI won the 2018 General Elections, and he became the 22" Prime Minister of Pakistan. That even after assuming the charge as the 22 Prime Minister of Pakistan, the Petitioner struggled with the balance of payments crisis which required him to seck foreign aid and in a timely manner made a deal with the International Monetary Fund. The Petitioner also carried out negotiations between the United States of America and the Afghan Taliban, paving way for the successful withdrawal of the US coalition forces from Afghanistan. During the COVID-19 crisis, the Petitioner effectively managed the country’s healthcare sector which was lauded and acknowledged at the International level by various States and Organizations. For the first time in Pakistan’s history, the Petitioner was seen adamant and confident to table many social and economic reforms by way of enacting various legislations revolving around women empowerment and shielding victims of harassment as well as domestic violence. Unfortunately, the Petitioner was ousted from the government through a well-orchestrated scheme in the April 2022 and the ensuing arbitrary actions and highhandedness of the political opponents who took over the Federal as well as Provincial government and thereafter indulged in political victimization against the Petitioner and his party (PTI). ‘That in order to meet the unlawful desires ‘Political Rivals’ decided to lodge series of bogus cases against Petitioner and ‘Senior Leadership’ of PTL. They were also subjected to torture on the basis of serious charges like ‘Sedition’ and ‘Mutiny’. State machinery was misused with the sole object of ‘Political Vi ization’ and ‘Score Settling’. Being aggrieved with malicious campaign launched against PTI Chaiman and Senior members by registering base! frivolous, groundless and false cases across Pakistan, Pal tan Tehireek-E> Insaaf decided to protest agains! incumbent government along. with “Pal Democratic Movement’ (P 2 = response that the Azadi March received was extra ordinary and at the same time,@ disturbing and a cause of concern for the political rivals. In consequence thereto fon 03.11.2022 a Pre-Planned murderous assassination attempt was made, specifically targeting the Petitioner which left him critically wounded. As a result of murderous assault and reckless firing One (1) died at the spot whereas Thirteen (13) persons sustained serious firearm juries, ‘That it may not be out of place to mention that the assassination attempt was properly planned and executed at the behest of the political adversaries of the Petitioner who were getting increasingly insecure with the immense popularity Petitioner and his party were gaining at National and International level. Petitioner had prior intimation from reliable and credible sources that he would be targeted at a specific place during the Azadi March. Despite serious apprehension Respondent No. 1 and Respondent No. 4 pro} led insufficient and wholly inadequate security to ensure the well-being of Petitioner and those present in the Hageeqi Azadi March. Quite miraculously, Petitioner having 2 narrow escape survived from the assassination plot which was designed to eliminate him from the political scene. ‘That soon after the occurrence Petitioner was shifted to the Shaukat Khanam Memorial Hospital, Lahore for life saving treatment. Petitioner remained ‘admitted for Seven (7) days in the Intensive Care Unit (ICU) and remained under periodical checkups and treatments of a panel of doctors, who monitored and super vide his recovery for nearly Three and a half months (314). Quite shockingly, an FIR was refused and by shrewdly interpreting the landmark and authoritative case of ‘Sughra Bibi v. The State’ reported in PLD 2018 SC 595 where an application from an eye witness aggrieved was discarded and Police Station City Wazirabad assuming the role of Complainant lodged an FIR No. 691 1 22. dated 07.11.2022 Containing inaccurate details and incomplete details of the occurrence, State functionaries and the custodians of Fundamental Rights of the citizens of Pakistan were visibly abusing power and authority along with provisions of S. 154 Cr-P.C, 1898 by misconstruing the dictum laid down in 'Sughra Bibi Case’.© ‘don the 8, That it is imperative to mention that the Petitioner has always emphasi supremacy of the constitution and rule of law. Petitioner has always demonstrated utmost respect to the Honourable Courts and despite registration of innumerable false and frivolous cases choose to not only join the inquiry and investigation but also regularly appeared before the Honourable Courts whereas his physical presence was necessary. Petitioner was witnessed appearing, before the Anti-Terrorism Court, Banking Courts, Judicial Complex, F-8 Kachehri as well as the Honourable High Courts of Pakistan. Prior to the assassination attempt on his life Petitioner never hesitated from performing his legal obligations. That such was the venom of the political opponents against whom several criminal cases of Financial Corruption (Nab and Money Laundering) were initiated during Petitioner's Government. That after removing Petitioner from power corridors they exhausted the whole range of Penal Offences in a fishing expedition to somehow frame him in a series of cases to discredit him politically as well as for their own personal score settling. Toshsa Khana case, Shahbaz Gill case, Prohibited funding case, Terrorism case for Learned Judge Zeba, ‘Sedition’ cases were registered on the instructions of Interior Ministry. All these cases met their logical fate as being baseless and false in nature, of which none has substance and only caused inconvenience to the Petitioner. 10. That the Petitioner remained immobile and almost bedridden for few months. The Election Commission of Pakistan was visibly seen playing as a tool in the hands of present Government and des the collapse of economy and devaluation of Pakistani Rupee refused to announce Elections to elect a democratic Government as per the wishes of the people of Pakistan, 11. That upon his recovery quite recently Petitioner has yet again resumed with his political activities. The Petitioner quite recently appeared in Honourable Lahore High Court Lahore (Divisional Bench) and again appeared in Judicial Comples Islamabad as well as directly approached the Honourable Islamabacl High Court for the grant of bail in several politically motivated cases that were registered against the Petitioner.12. That Petitioner wishes to fight with ‘Politically Motivated’ cases but due to inadequate and improper arrangements Petitioner remained unable to attend some hearings physically. Now the Petitioner knocks the doors of this Honourable Court for upholding of his ‘Fundamental’ and ‘Inalienable’ right enunciated under Article 9 and 35 of the Constitution of Islamic Republic of Pakistan, 1973 mainly on the following grounds; GROUNDS A. That the Petitioner has served the country in a variety of ways and has the honor to serve Pakistan as the 22” Prime Mii er of Islamic Republic of Pakistan and Chairman of the most popular and largest Political Party (PTI). IT is important to mention that his popularity in the political arena has become a cause of concern for his political adversaries who after failure of several criminal cases have now resorted to the option of eliminating him altogether for the political scene as ‘Final Disposal’. This apprehension is based on reliable, credible and authentic sources who have informed the Petitioner that he would yet again be targeted during his exposure in Court hearings and appearances B. That the Petitioner being the Former ‘Prime Minister’ of Pakistan and being a ‘Citizen’ of Pakistan is entitled to protection as provided under law. Right to Life and Liberty are his basic Fundamental Rights guaranteed under the Constitution of Islamic Republic of Pakistan, 1973. Despite a failed assassination attempt that let him critically wounded and despite several demands to provide proper and inadequate security the Respondents deliberately are exposing the Petitioner so that he may fall a prey to any attack that may be launched or directed towards him. “That after his illegal and unlawful ouster from the power corridors, a conspiracy is being hatched which has widely been reported in print and electronic media at both national and International level that there exist clear and present danger to the life of Petitioner as her an internal and foreign conspiracy to eliminate bi( @ ¢ That the concerns and apprehension of the Petitioner is based upon authentic and reliable sources. The Wazirabad incident in which One (1) died and Thirteen (13) were critically wounded along with the Petitioner provides overwhelming support to the serious apprehension of the Petitioner. The State machinery and Respondents failed to protect the Petitioner in broad daylight. Petitioner was targeted and left shown several times. Series of new false cases are being registered compelling Petitioner to give Court appearance by exposing himself before the Courts. It is vital to mention that so far altogether Seventy Six (76) Criminal Cases have been registered against Petitioner and his Party (PTI) in various cities of Pakistan. All 76 cases are Politically Motivated and contain baseless accusations. The horrific incident of Wazirabad has proved the grievance of the Petitioner beyond any shadow of doubt. That plot to Kill is real and not a ‘Figment of Imagination’. The Respondents are duty bound to protect the Petitioner however, quite unfortunately, they are shying away from performing their professional and legal duties for which they have taken Oath 'D. That the reckless registration of graft cases and repeated abuse of criminal machinery and Section 154 Cr.P.C, 1898 clearly establishes the mal-intent and shows that by design the largest political party of the Country is being denied it’s right to participate in the democratic process and hence, the right of choice of the people of Pakistan is being curtailed. Being aggrieved and frustrated with the sheer volume of registration of false criminal cases. Petitioner in the capacity of Chairman PTI through letter dated 05.03.2023 had already expressed geave concerns regarding ‘Safety and Security’ to the Honourable Chief Justice of Pakistan for his kind notice. Separately, Senior PTI party officials namely Mr Shah Mahmood Qureshi and Mr. Asad Umar had also expressed similar concerns drawing the gracious attention of the Honourable Chief Justice of Pakistan vide Letter dated 05.03.2023, E, That avoiding unnecessary exposure, Petitioner has even attempted giving appearance in the Court with the use of ‘Modem and Scientific devices’. Th ind Scientific devices’. The Petitioner relying on the authoritative judgment of Honourable Supreme Courtreported in PLD 2021 SC 362 titled as ‘Ali Haider v. Jameel Hussain’ has prayed from the Honourable Courts to adopt a realistic and liberal approach by embracing modern technology by exempting the Petitioner from personal appearance is Courts. Moreover, as it has been witnessed in the hearings that had taken place ‘in the Lahore High Court, Lahore, Islamabad High Court and Judicial Complex, Islamabad that police erably failed to maintain law and order situation. Overcrowding for which Petitioner is in no manner responsible was witnessed making it an absolutely chaotic situation where security breach is highly likely and absolutely unavoidable F, That it is alarming and unfortunate at the same time the law enforcement agencies have previously failed to protect the one who had voiced concems about his safety and well-being. Despite all alarming indications the Law enforcement agencies forming a league simply failed to provide adequate security arrangements to the Former ‘Prime Minister’ of Pakistan G. That Petitioner has yet again received information from credible, reliable and trustworthy sources that he is extremely ‘Vulnerable and Susceptible’ to fresh attack if he does not exercise extreme care and caution. His exposure and appearance in public is being mastered by his enemies. This state of affairs is extremely alarming not only for the Petitioner but also for Pakistan as a nation which has an unfortunate history where prominent political leaders such as Liagat Ali Khan, and Mohtarma Benazir Bhutto were killed as a result of conspiracy theories, These unfortunate events played havoc with the image, repute and economy of the Country and these unfortunate killings are clearly a stigma on the performance of guardians and custodians of ‘Citizens” of Pakistan, The country is already struggling with the ongoing Constitutional crisis due to nonholding of general election and sinking economy. 1 is undeniably the duty of the Respondents to ensure safety and well-being of citizen of Pakistan, a duty wich lately has been lett unperformed by thers. The Wazitabad Incident and the security breach spenks volumes about the mal-intent of Respondents / Police Oficial who are simply not performing their legal duties® H. That the campaign to falsely register bogus cases is not ending. Each passing day is witnessing an increase in the number of criminal cases which have been fered against the Petitioner without any rhyme, reason or justification. Sheer abuse of power and authority is being exercised by registering cases for absolutely no wrong doing of the Petitioner. The agenda of the opponents is secking public exposure for a fresh attempt on his life. Through the instant Petition the Petitioner after exhausting all remedies is left with no other option but to knock on the doors of the ‘Constitutional Court’ to ensure strict implementation of Petitioner's basic Fundamental Right in letter and spirit. That a fresh wave of terrorism has also hit the country, numerous acts of terrorism including the recent attack on police Head Quarters in Karachi and Peshawar are proper indicators that law and order situation is already out of the Country. This sudden spell of terrorism maybe just an offshoot behind the nefarious designs of the enemies of the Petitioner. The sharp increase in terrorism across Pakistan is also something which could be linked with the concerns of the Petitioner as raised in the above paragraphs. The Petitioner prior to the Wazirabad incident was residing at Bani Gala, Islamabad. Due to poor security arrangements, the Petitioner has not been able to leave his residence in Lahore. His personal staff is ill equipped and not trained at all to counter any untoward incident that may result from any breach of security. Petitioner in order to attend the Court hearings left by road taking the motorway (M-2) in order to reach Courts in Islamabad. Throughout the stretch of motorway absolutely, no security arrangements were provided by Punjab Police, Islamabad Police as well as Motorway Police ie Respondent No. 4, 5 and 6. This has exposed Petitioner to serious threats! which can easily be repeated in case Respondent No. 4, 5, and 6 yet again failed in performing their duties. J. That the Petitioner has recently been summoned before the Lahore High Court.) Lahore, Anti-Terrorism Court, Islamabad, Honourable Islamabad ftigh Court 0 and The Special Judge Banking Court in Islamabad. Despite repeated resssurances of security errangerents the Petitioner was dismayed to find that no security measures were ken upon his arrival tthe Court premises. The lack of police deployment speaks f the fire of law enforcement agencies andexposes the Petitioner to grave threats. The Petitioner is not only the ‘ex-Prime Minister’ of Pakistan but is also under serious threat to life. The absence of adequate security arrangements caused turmoil within the court premises, leaving the Petitioner exposed to thousands of people whose intentions remained unknown. Such failures are highly questionable, especially when a person with serious threats to their life is forced to attend court proceedings. It is respectfully prayed before the Honourable Court to mandate security arrangements for the Petitioner, as failure to do despite the recent murderous plot hatched will be in abrogation of his Constitutional ‘Right to Life’. K, That the Petitioner is now being demanded to be present in the Court where his Bail Petition is to be heard. However, the Kachehri located in F-8 Islamabad is a Judicial Complex that lacks adequate security measures. It is an open place with congested lanes, which makes it difficult to provide proper security. The architectural design of the Complex is compact with limited and concealed exists, which can create a security risk for the Petitioner. The repeated threats he receives concerning his life create an alarming concern for the protection of not only the Petitioner but also the judiciary and lawyers who are present in Court premises. In the event that a nefarious plot was to be executed against the Petitioner during his exposure to the public, it could result in a blatant damage beyond the Petitioner's life, Therefore, it is crucial that adequate security measures be commanded to secure the legal fraternity of the country. These measures should not only be in accordance with the Petitioner's Constitutionally guaranteed Right but also aimed at preventing any further loss of lives. L. That the recent court appearances of the Petitioner fully exposed the security plan of police in Lahore, Motorway (Punjab) and Islamabad. These court hearings have witnessed that the security plan was totally missing / absent. It was seen on the social media that police failed to effectively control and secure court premises during bail proceedings at Lahore High Court, Lahore, Banking Court Judicial Complex and lastly in Islamabad High Court. In the background of Wazirabad incident followed by absence of security altogether at Court appearances it is evident that Petitioner is deliberately being exposed making him highly vulnerable for an attack,) M. That even otherwise Petitioner is at the advanced age of 71 Years, not yet fully recovered from the physical trauma, his lis are weak, he is unable to walk without support and he is practically immobile without assistance. All these make him an easy target in chaotic and crowded venues of Court premises. His physical circumstances along with vulnerability seck humanitarian grounds that the Petitioner be kindly be allowed to participate in Court proceedings through madern ‘Scientific Devices’. N. That according to Article 9 of the Constitution of Pakistan 1973, right to life and security is a fundamental right of every citizen. The word life in Article 9 is not limited to mere breathing but demands much more from State which includes actions by the State to remove all threats likely to abridges such guarantees. In the case titled ‘Sh. Ahsan-ud-din, Advocate and two others Versus Federation of Pakistan and others’, reported as 2014 CLC 451, it was elaborated by the Court that Right to life shall be construed broadly and the constitutional guarantee was not limited to life itself but encompasses the duty of the State to ensure the security of a person and to protect them. It was directed that the state should aid in the ‘enforcement and protection’ of the right guaranteed under Art. 9 in a manner that no person or institution should be given the authority to jeopar © a life or expose a person to danger. Therefore, the duty is not restricted to preventing violation of the right to life but to take effective measures to deter any threat to right of life, Exercising diligence is a duty and it ought to be demonstrably reflected through the actions and conducts of the public functionaries. In the presence of immense threats and past assa: ation attempt, it will made Petitioner vulnerable, if proper security measures are not provided ‘The relevant portion of the above cited Judgment by the Islamabad Ligh Coutt is reproduced below for the kind convenience of the Court: in light of the prevatem lov and arder siuation in the country and the sheer umber of assassinations of prominent national p somalities, it isthe obligation and primary duly of the Government to provide adequate security protection as well as tae all feasible steps 1 ensure the provection of us eltizens especially State personalities facing foreseeable, existent and actual threats to their lives Farmer Chef Justice of Pakistan, Ar. Justice (R) Mikhor Muhammad Chaudhry. The word ‘fet such as the Hon'b in the Constitution is very significant as it@® covery all facts of human existence and Includes provistans of guarding, and protecting the same, The State should therefore actin ald af enforcement and protection of the fundamental right to te yuaranteed under Article Y of the Constitution of Islamic Republic of Pakistan and puble functionaries lhe Police, Ministry of Interior and Cabinet Division must aet In suppart af the same and faciliate, sustain and minister the enforcement of the sald Constitutional provision rather than to violate, neglect, overlook and disregard the sume, The ‘right to life’ has 10 be safeguarded and upheld and mo person or institution can he given the right 10 feopardize a life and expose a persan to danger elther due to mala fide intent or heedless uttitudes like tn the present case." ©. That in this same Judgment, reported as 2014 CLC 451, it was noted that a Former Chief Justice of Pakistan, Mr. Justice ® Iftikhar Muhammad Chaudhry was identified as a top target of terrorist activity. Hence, in order to give effect to Article 9 the Court not only interpreted the provision but also condemned the neglect of the state machinery in this regard. In doing so, the Court mandated the provision of ‘fool proof security to the Former Chief Justice. The relevant partition of the same judgement is reproduced below: “10. From the plain reading of the above it is clear that the Former Hon'ble chief Justice Supreme Court, Mr. Justice (R) Ifikhar Muhammad Chaudhry, is the top target for a terrorist activity. His name has been listed even above important and crucial State functionaries like the Prime Minister and President, This fact has also been conceded by the respondents in Court also. However, despite such clear, evident and manifest information the respondents have not only disregarded, neglected but also adopted a heedless altitude towards the life security of the Former Chief Justice and his family. The respondents have exhibited a typical bureaucratic approach by complicating the simple issue of ensuring full proof security to the Former Chief Justice of Pakistan which clearly feads to a conclusion that an intentional and deliberate attempt has been made to disgrace the Former Chief Justice which in turn is a disrespectful approach towards the institution of judiciary which i further made evident from the provision of a decrepit, ramshackle and dilapidated vehicle which apparently does not even mect the baste requiremems af not only infringed but also disreyarde rights of protection of the Ife of his Lordship and have demeaned his stature and efforts for the Country, . travelling, Hence, respondents have , derided and abridged the fundamental( 11. Therefore, itis hereby ordered that the Former Chief Justice shall be provided foolproof security along with possesston af the aforementioned bulletproof car for his and his family's use without putting embarye af any time specification, Ax per the maimenanee and expenses of the bullet proof car is concerned, the same shall as per section 24(2)(a) of the Rules for the Use of Staff Cars, 1980 be borne by the Ministry of Law as being ‘the respective Ministry/ Div ision/ Department concerned’. Moreover, as far as the directions to the 1-G of Police (ICT), are concerned, order dated 9-1-2014 (reproduced in para 5 ( V) herein above) suffices.”) PRAYER: ‘That in light of aforementioned facts and circumstances of the case, i ‘most respectfully prayed that; . ML. Vv. vi. The Petitioner being ‘Citizen’ & Former ‘Prime Minister’ of Pakistan be Provided ‘Fool Proof’ security arrangement & his safety and well-being be assured as guaranteed under the Constitution of Pakistan 1973. In the Interest of Justice & for upholding the fundamental rights Petitioner be saved from orchestrated ‘Politically Motivated’ False Cases that are being registered against him with the sole agenda to Expose him so that he may be ‘Targeted’ yet again after his survival from the last Assassination Attempt at Wazirabad. Taking into account serious Threat & risk involved to all those present in Court Premises permission may kindly be granted to mark attendance / attend proceedings through Video / Skype Link (Modern & Scientific Devices). Strict action be taken against Respondents for failing to maintain Law & Order in Court premises & during court hearings in cases involving. Petitioner in Lahore High Court, Lahore. No ‘Adverse Action’ (Including Arrest) be taken against the Petitioner til he is properly facilitated & provided proper security arrangement for court attendance and appearances, Any other relief that this Honourable Court deems fit and appropriate may also be extended to the PetitionerPetitioner, ‘Through Barrister Salinjn Safdar Advocate Supreme Court LLB (LS.E), Bar at Law (1incoln's tin) Ground Floor, Alvi Manzil, 9 Fane Road Lahore. Intazar Hussain Panjhuta Advocate High Court ocate High Court Rights’ of the Petitioner. of the client that this is Honourable Court on the subject matter for the ‘Enforcement of cof © Ishting Ahmad Khan Advocate Supreme Court Mazhar Ali Haider Advocate High Court ad Bin Mohsin Muhammad Abdullah Barrister Abdullah Khan Advocate High Court Advocate High Court i}qoal | Writ Petition ) ‘ ry d\nRA LAHORE HIGH COURT, LA Writ Petition No. 12023 ‘Imran Alinad Khan Niazi v. Federation of Pakistan etc’. ATE! IDAVIT OF: Imran Ahmad Khan Niazi S/o Ikram Ullah Niazi R/o Zaman Park, Strect 1, Lahore, Pakistan WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF THE MIC REPUBLIC OF PAKISTAN, 1973. contents of the accompanying Writ Petition are true and correct to the best of my knowledge and belief and that nothing has been concealed therefrom. ct Ques . fhm Pius ponent — f= VY Verification: Verified on oath at Lahore on the Th above affid 23 that the vontents ot the il are true to the best of my knowledt incl by has been cor J there from, 4 Deponent =(1)s-244 ebu4y rg Moar dab cnberit Visor bop ZeP eps wile ln i cwZ-002964- ‘0000-00-00 00:00:00 cwzn-11/7/2022-3103 Man Aigind! pg JAQ3) eponbe | 07-11-2022 11:10PM SibrWnesd 6 snbwi tit 2 03338457574: y35202-2359837-3:7 NE oe eae vei au eer) sy> THE ANTI-TERRORISM ACT, 1997 BNRALI Sep Lup iaFe kona mest binshiLy 4 SI oben TI LEE Se nwri 8 03338457574 ruil Sl uae OLB ok wee (heugetonben A yerin Lar classe? 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I ey eke OPM arheitnl? gt iySift C190 sutA 07-11-202211 people, in rr luding addi ¢_killed_and_29 others wou bomb attack ina court in th eported] lon Bt gun ‘city’s F-8 area, DawnNew: capital 'Asad Mansoor, a spokesperson for the Abrarul Hind splinter group of the Tehteek-i Dawn.com claimed that hi -known: iliban Pakistan (ITP), while talking, to roup was responsible for today’s court attack. ‘The group had ly parted ways with the TTP over holding of talks ‘with the government. He claimed that the court was targeted as the prevailing system in the country was un-Islamic which included the courts and its administration. He added that their struggle would continue till Sharia law was implemented in Pakistan, According to police, two blasts took place inside the court's premises, one near {the lawyers’ chambers and the other outside another office. “Moreover, lawyers fled from their chambers seeking shelter from bullets as {ear and panic gripped the premises. lorneers at the scene told AFP the incident began when a defendant was ‘brought before the court and his associates tried to break him free. another senior-ranking police official said the incident could be a terror a \but nothing could be said with certainty as yet. |According to police authorities, militants entered the chambers of judge Rafaqat Awan and opened fire on him. Initial medical reports said that the judge was hit by three bullets. | brhe hearings of cases scheduled for the day were postponed. |subsequently, police and special forces were deployed in the court and emergency was declared in hospitals. ‘the capital city is currently under high alert and the Red Zone was also s ‘ne head and feet of the alleged suicide attacker were found. CHB, Go in-depth: ITP « efieg | [Dan eETP's tunes [ Falk, fight, repe: (Chief Justice Tassadug Hu: in Jilani took notice of the incident and summoned interior retary, inspector ral (1G) and commis: would not discoura ss and also called for those behind the att arate ot ack to be brought © penne ter eee ereereieey Meanwhile in Lahore, lawyers of the Pakistan Bar Council announced a [boycott of court proceedings. Tehreek-i-Taliban Pakistan (TTP) spokesman Shahidullah Shahid denied the joutlawed group's involvement in the attack. Shahidullah Shahid said TIP condemned the attack on the court in Islamabad, adding that recent terror attacks should not be linked with the org; further said the outlawed organisation would not violate th 1ad announced on Saturday, ion, (The spoke Interior minister Nisar Ali Khan had responded to the Taliban announcement ‘saying that {the government had decided to h: ‘Taliban militants, |An FIR of the attack was lodged against unknown persons at the Maragalla ipolice station. Pakistan has been in the grip of a bloody homegrown Taliban insurgency since | 2007 but attacks within the capital have been very rare in recent years. | Zahir Shah Sherazi contributed to the reporting ofthisstory] —__ |¥ e4 as-24 A pty 14037512 be Gita) Ae af 1S outer wsien Bt prer ef SoS seet-10/21/2022-3497: 7 B gi Tew Dep 220 geshra id _ 21=10-2022 02:45 PM beds Su but viet] Sabs IS 20] 6 spall pez 2! 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LBA ee bolt wy) te | i eet } { eit 20236 J2B wisn i2T ar KL 1 bedi p7eU o-r ~ey 02350 )28 yr Str re AOILELY YSPakistan Tehreek-e-Insaf Central Secretariat Honourable Chie! Justice Supreme Court of Pakistan S March 2023 Honourable Chief Justice wish to draw your attention to a very critical issue. Ever since the removal of my government through a regime ‘change operation, [have been confronted with questionable FIRs, threats and finally an assassination attemet. Despite being 3 former PM of Pakistan | have not been pravided with proper security and my FIR on my assassination attempt was not allowed to be registered by me. have and continue to maintain that the present PM, Interior Minister and a senior intellizence agency officer were involved in the failed assassination plot. Subsequent actions Including attempts to destroy the JIT report on my assassination lend further credence to my view as to my assassination plotters. ‘There are also clear Indications of another assassination attempt being plotted on my life. ‘To date there are 74 cases against me and Lam being made to appear in court for hearings time and often. 1am chairman of the largest political party In the country and wherever I go massive crowds naturally follow. This further aggravates the prevailing security threat. Right to life [s fundamental right under the Constitution and there Is a grave threat to my life. Inmy lost appearance before the LHC there was a total failure of oiial security and the same happened in Ilamabsd when | had to appear before diferent courts. Its now abundantly clear that neither the State nor the govt has any Intention of providing me adequate foolproof security for my court appearances tam requesting your Honourable self to take action on this threat belg (3¢ed by me from those in power. One of my avzascing, Hoveed, has been allowed video ink facies for is court appearances while myself, the target of the assassination, am being denied the same. Under the prevaling threats and possible assassination plots would request your Honourable se totakevotce dad enture thet adequate Security arrangements be made I'my appearance is necessary. There are precedents Mrot incase of security threats video lnk faclty for appearance Is provided, In view of severe threats to my i I mnay be provided video link felity for court appearances. This would. ala prevent the massive crows coming cot spontaneous to show :uppart whenever Ihave to make a court appearance. Slncerety, Prot A, Street # 32, See “Tet: +92 1 261008 wG-A/A, Wlamabad, Panlata 492 51 26102047, Webslte: wwwinsat ph‘ @ ™ Mareh, 2023 Honourable Chief Justice of P Supreme Court of Pakistan, Constitution Avenue, slim kistan, : , bad Honourable Sir, 1. That Me, Imran Ahmed Khan has served as the mation as 22" Prime Minister and is the head of the PTI, the largest political party, which was ousted from power as a result of criminal conspiracy. Subsequent to his ouster, numerous bogus and ill- founded cases were registered against the undersigned and Senior members of the PTI to settle political scores. In the wake of failure to effectively prosecute Mr. Imran Ahmed Khan, an assassination attempt on his life was made at Wazirabad in which one died at the spot and thirteen were critically wounded. Mr. Imran Ahmed Khan sustained multiple firearm injuries on both legs and was immobile for almost three months and remained under treatment by a panel of doctors / experts at Shaukat Khanum Hospital 2, That through reliable and credible sources, it has come to the notice of Mr. Imran Ahmed Khan that during his exposure andappearance in court proceedings he would yet a in be targeted so that he ma yy be eliminated from the political scene. 3. That Pakistan has witnessed political targeting and elimination of notable politicians through the course of history, beginning from the assassination of late Liaquat Ali Khan, Mir Murtaza Bhutto & Benazir Bhutto. There is every apprehension that a similar attack as had taken place in Wazirabad will be repeated if adequate security arrangements ensuring the wellbeing and safety of Mr. Imran Ahmed Khan are not ensured. A criminal case FIR No. 691 / 2022 was registered under S. 302, 324 along with 5.6 / 7 of the Anti Terrorism Act 1997 at PS Wazirabad. 4, That it may not be out of place to highlight that in the recent past, District Courts located in F/8 Islamabad came under a terrorist attack in which one Honourable Judge was killed along with scores of innocent litigants and Court staff who were critically wounded during the episode. This is clearly indicative of the fact threat the court premises are neither safe nor secure for Court appearance of Mr. imran Ahmed Khan who is already vulnerable and for whom there exists clear and present danger,© 5. That it is imperative to draw the gracious attention of the Court that chances should be eliminated and safety and wellbeing of not only Mr. Imran Ahmed Khan but also of those who are physically present during court proceedings, including the Court staff, the Honourable Judges, lawyers & ordinary litigants. Adopting modern technology is resorting to safer course in the prevailing deteriorating law and order situation where the country has also witnessed a fresh wave of terrorist attacks across Pakistan. 6. That it has been widely reported in electronic and print media and also acknowledged by the incumbent Government that there is huge risk to the life of Mr. Imran Ahmed Khan. Despite this, absolutely insufficient, inadequate security arrangements are in place to ensure that no untoward incident takes place, creating a law and order situation. 7, That during the recent court appearances at Islamabad Judicial Complex and the Honourable Islamabad High Court, it was observed that absolutely insufficient security arrangements by the Police despite advance notice were in place, which resulted in an absolutely chaotic situation making security breach unavoidable. “The undersigned are convinced that the threat to the life of former@ Prime Minister, Mr. Imran Ahmed Khan, is well founded as it has previously too, materialized in the form of the Wazirabad incident, in which Mr, Imran Ahmed Khan miraculously survived 8. That a series of politically motivated cases are being registered containing, bogus allegations and frivolous charges. The agenda behind registration ofthe said cases is to compel Mr. Imran Ahmed Khan to give appearance, rendering him vulnerable and exposed £0 an attack, 9. That the Honourable Supreme Court of Pakistan in judgment titled ag Ali Haider v. Jameel Hussain (PLD 2021 SC 362) emphasized that the Courts with a liberal mind shall adopt modern and scientific methods in the Criminal Justice system. PRAYER: Keeping in view the aforesaid facts and circumstances & purely in the national interest, it i8 requested that Mr. Imran ‘Ahmed Khan be allowed to use the available modern technology and appear through Video Link before the various Courts to join the proceedings. bo Xd Mp RGure Y ASAD UMAR SHAH MAHMoob QuresHt Sceretary General, PTL View Chairman, PTIs-24dpate onde Slap boar Shh arenfne Sian seprerenqSwiies nan-2/28/2023-681 BUI AT eb 120 sala id Go Payor a-or-aensosaan SibaSSivect] 6 epenbrl s Ale tatrsoes By, Rasheed Abmed Si ee ee twrshral 2 VEL beth 3 20 ep eM eI L001 Pa doe ered LarsTity| 4 snPivnedseipste?| cinbebeenisintn sibel Foss iIE aon § suonsiazies = ded slot as ick Gulkhen i> (feng tors Gf etradbenrs 20s sr 10-4300 2 Sigh Le shecsabret rx SUSUOS ¥ATATAs06t/427/389/ 186/148 49/440.) 23804 SIAN IL Lf SP BLD tA PLA SULLA Crete AAT 1A OA nS ors Se LAL rt TP ae BLL IIRL Od LIP PMA eM AL Gp Eide PV RGL CLL Lael hn FEWABN poe ASA EASES APU LIL PRE EAL Sony BN NAL SALE Stn SNP EN MEALIS AILSA AM MEMES ASS CO Later LBP GP gil Eile eM Shekhar Qt ISI AMES AEH IPE IPA SPO Erase nL II Lies LSS goa ain SENIIWSA/ a eee Aer AL I te hel ACV A Lhasa neh vee wens aia SNe SP AMIDE I DIED AIRLINES SAFE ALE SILI Daan ArebeSf CSO COIS EY AG WIT MSE ISIPE AYLIV AID Abe lDEAEt AY MEAL Fhe ee U). 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DCL AOD pb s2DSHI SOA ELOSID ETC HO-LN/ yA Medrnumerdratty CC ebbind/ we PENA reac” PA Ade bothers AP see Seaver Ney rine Mia 2S 1001 Kan 28-02-2029@) sreceate one78—: Aube Seb seat sebemboy ty susnerds rere Swe) BS NT 2, Sibiu 6 eee RMN-2/28/2023-684 ¢ ee uitoitys 2 ELS MM rete 3 DIOP RAPS ne} Lael FeAl (Gok | eet birsdiiy 4 _{—_____ —— | Fat? cbt nn IEEE Soot oP aerbun 5 65-1 Gul Khao, (Aengtovibizn egos er Los chinasze clrarscazela94e Fay C1012 Fh ASIP LSI (TATA cy S06! 186/383/148/149.55 356 PU BLL SSM SVLF LALO HSB 8 AAS AES EM IG 10) ASAT HSA RLF tH Mp bene hee LINZ Ae shtu Le Lip hLigguthn ILI” RW bad vote nl Soap Sie Lei biaresh tebe LOL Lingo t nk innit des DP WSinPubod Alpert rt nd fonpe LA ENNELY AL Aids Agha 0a VE ALI Ls LIP L ASAT AIL WE Pobipee EUS eNOS hete StS t MLAB IAA ALL AAI ENS Sign BEA NSA: MMVII S AKL A SRAM INF ERLE M ALI ESS Rohe MA ASO SS Loe Suan ol Cre ASHE apd DiS pb Dee E ME fia Oe A AAs Ss TSR M65 SU" Bt anh ae Pp Lew Z tHE veri e100) soph aenph ALIAS AOI / A997 (BASU AI CSOF Und Seth 16—HrT PLAT Prt SLIMY IL ORE MASAMI IA RASS fecha ndige Sabin S PSL Wot SeoLierter mrorcirnt biarhinve che tttetoa sty prey Ait Besa eohse? RACES eto MI AES MH EL LL ANE NM MAA ar hE S aun. Lihean eae eed Rel mine Wse” eal Sop SH AHCABL RE LONT AS. S06i/6/283/uslishztacnre. (raul tater pefoeos SAT ioral aS Al pbabr snamitr Br BEAU Er aul Sorell Aft bed e Soa heen ARP ot PS IANS IE A ccd Pin sAN ad rnoa tat PA SLI 7 sue Le rei rE s1Guthan 26-02-2023IN THE HONOURABLE LAI ORE HIGH COURT, sanom CM No. 12023 IN Writ Petition No. 12023 ‘Imran Ahmad Khan Niazi v. Federation of Pakistan etc’. Imran Ahmad Khan Niazi S/o Ikram Ullah Niazi Resident of Zaman Park, Street 1, Lahore, Pakistan Petitioner Versus 18. Federation of Pakistan through Secretary Pakistan, Secretariat Constitution Avenue G-5/2 Islamabad. 19, Federal Secretary Law & Justice Division, Pakistan Secretariat, Constitution Avenue G-5/2 Islamabad. 20, Additional Chief Secretary Home Department Punjab Secretariat, Lower Mall, Lahore. 21. Inspector General of Police (IG), Punjab, CPO Building near Anarkali Lahore Police. 22, Inspector General of Police (1G), Islamabad Mauve Area G/11-1, Islamabad. 23, Inspector General of Motorway (IG), Punjab Motorway Police Headquarter Islamabad. 24, Commissioner Lahore Dit ion, Lahore, Shadman 1, Jail Road, Lahore. 25, Deputy Commissioner Islamabad, DC Office Islamabad. 26, Secretary Defence, Governin tof Pakistan, Islamabad,ze 27, Province of Sindh through Secretary Home Department, Karachi. © 28. Province of KPK through Secretary Home Department, Peshawar. 29, Province of Balochistan through Secretary Home Department, Quetta 30. Capital City Police Officer (CCPO), Queens Road, Lahore. 31. Superintendent of Police, (SP) Civil Lines, Lahore, 32, DIG Operations DIG Office Lahore 33. Station House Officer (SHO), P.S Garhi Shahu, Lahore. 34. The State, ..-Respondents PETITION UNDER SECTION _561-A OF CR.P.C_1898 FOR EXEMPTION OF PRODUCTION OF CERTIFIED COPIES OF THE ANNEXURES, It is Respectfully Submitted; 1. That the Petitioner has filed the accompanying CM Application and Writ Petition beforethis Honorable Court. 2. That the Petitioner is making vigorous and strenuous efforts to secure the certified copies of the Annexures attached and that the same will be placed on the record as and when made available, Uncertified copies thereof, duly checked and signed by thecounsel, are being placed on the record, 3, That it is therefore respectfully prayed that production of the certified copies of the Annexures may kindly be dispensed with and the instant Writ Petition be entertained as itis.al Petitioner, Through \ Barrister Sdiman Satta Ishtiag Ahmad Khan Advocate Skpreme Court Advocate Supreme Court LLB (LS.E), Bar at Law (Lincoln's Inn) Ground Floor, Alvi Manzil, 9 Fane Road Lahore, Intazar Hussain Panjhuta Mazhar Ali ed Advocate High Court Advocate High Court Muhammad Bin Mohsin Muhammad Abdullah Barrister Abdella oa Advocate High Court Advocate High Court Advocate High CourtIN THE HONOURABLE LAHORE HIGH COURT, LAHORE CM No. 12023 IN Writ Petition No. 12023 “Imran Ahmad Khan Niazi v. Federation of Pakistan etc’. EFIDAVIT OF; Imran Ahmad Khan Niazi S/o Ikram Ullah Niazi Ryo Zaman Park, Street 1, Laizore, Pakistan PETITION UNDER PRODUCTIO ION 561-A OF CR.P.C 1898 FOR EXEMPTION OF OF CERTIFIED COPIES OF THE ANNEXURES. ,/the above-named deponent hereby solemnly affirm and declare that the ontents of the accompanying CM Application are tri and correct to the best of my knowledge and belief and that nothing has been concealed th refyom. leponent — Verified on oath at Lahore on the Z#A_ of Maiel'2023 that the contents of the above affidavit are true to the best of my knowledge and belja thing has been concealed there from, Deponent ~: POWER OF ATTORNEY, in tHE LAHaCE LAbeKE Wy CASE NO. / 0x3: For. PLAINTIFF. PETITIONER (pe Jeb a | San VERSUS RESPONDENT | DEFENDANT. ACCUSED. KNOW ALL to whom these presents shall come that I/We, the undersigned appoint BARRISTER SALMAN SAFDAR Advocate Supreme Court of Pakistan To be counsel in the above matter for me/us and on my/our behalf as agreed to-appear, plead, act and answer in the above court or any appellate Court or any Court to which the business is transferred in the above matter as and is agreed to sign end file petitions, appeals, statements, accounts, exhibits, compromises or other documen™ <= > connection with the said matter or any matter arising therefrom and also to apply for - "VE RUPEES ments or copies of documents, depositions etc., And to ‘poena and to apply for and get issued any arrest, =‘ conduct and proceeding that may arise thereout: — 3; or submit the above matter to arbitration, and to ueise the power end authorities hereby conferred ‘employ and other legal ¢ onthe Advocate wheneve ‘AND t0 do snage and conduct the said case in all respect whether herein specified: tient. "AND IME aillawful acts done on my/our behalt: under or by virtue of thest hsuch matter. PROVIDED...» ‘at time of calling of the case by the court Vimy authorised agent shat isin ‘ake appear in court, if the case may be dismissed in Tar ee eget aroaded expu SCOUR 6! shall not be held responsible for the same. All costs awarded in favour shall Be th@ tay» wn. -OUNSE! OF his nominee, and if awarded against shall bo Payable by me/us. IN WITNESS WHEREOF I/We | have hereunto set my hand to these presents the contents of wi Been explained to and understood by me this the ‘ay of hich have Accepted, —————— 202 BARRISTER SAL. Advocate St Ce ‘Pakist , & * / sonra WY A/G 9. Fane Road Likore oa Mob: 0300-4234414 GC. No._18582 0300 92.3446, 3922-91 62S