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IN THE COURT OF CONCERNED LEARNED AREA

MAGISTRATE, PS CHAKRALA, MIANWALI

PRIVATE COMPLAINT NO: ____________/2024


Asif Iqbal S/o Fazal Elahi R/O Village & P/O Dhurnaka,Tehsil and
District Mianwali

COMPLAINAINT

VERSUS

i. Muhammad Irfan S/O Taj Muhammad


ii. Ahmad Khan S/o Mehr Khan

BOTH ARE RESIDENTS OF BAN HAFIZ DHOKE MUSDAL, TEHSIL &


DISTRICT MIANWALI.

RESPONDENTS

COMPLAINT UNDER SECTION 200 CRPC


RESPECTFULLY SHEWETH: -

1. That the addresses of the parties of the purpose of issuance of


summons/warrants issued by this Honorable court have correctly been given
above.

2. That through the instant complaint, the complainant humbly seeks indulgence
of this learned court for summoning and conviction of the respondents/ accused
persons for committing heinous crimes and taking law in their hands.

3. That succinctly stated facts giving rise to the filing of complaint in hand are
that the complainant is owner of the horse(mare) Desi Breed colored black
aged about 6years.
4. That the complainant has a relationship of trust & friendship with the
Respondent/accused No-1, on dated 14-04-2023 the respondent No-1
came to the Complainant house situated at dhurnaka at 2pm and said that
he needed the above mentioned mare (female horse) for riding for two
days and after two he will return it to the complainant.

5. That the complainant handed over the above mentioned mare (female
Horse) to the Respondent/accused No-1 because of his assurance and
trust relationship in the presence of Witnesses: 1. Kashif Iqbal son of
Fazl Elahi 2. Fazl Elahi father Noor Elahi at the above said date and time
and place and the Respondent/accused No-1 took the above mentioned
mare (female horse) at his home situated at Ban Hafiz G dhoke musdal
tehsil and district Mianwali.

6. That after two days later on 16-04-2023 at 4pm , when the


Complainant along with above mentioned witnesses went to the
house of the Respondent No-1 situated at Ban Hafiz G Dhoke Musdal
to take back the above mentioned mare, the respondent 1 to 2 came
and confined the complainant in their drawing room (bethak)
extended the life threats and told the complainant to forget the mare,
you are not going to get it back anymore and pushed the complainant
by using criminal force out of the house and furthermore said that we
have a very good relationship with the SHO Chakrala police station, if
you try to go to the police station, they will register a fake FIR against
you.

7. That the complainant went to police station which they refused to take
action against the respondents and even they not bother to record his
version.
8. The illegal and unlawful acts of the respondents’ amount to heinous offences and
crimes, therefore, they are liable to be prosecuted inter-alia under following
sections:
1. 506 PPC
2. 406 PPC
3. 357 PPC
4. 386 PPC

PRAYER

In aforementioned circumstance, it is humbly prayed the respondents may be summoned


and punished in accordance with the law.
COMPLAINAINT

Through: -

MALIK ATIF IQBAL AWAN ADVOCATE


LLM (New Delhi), India.

CERTIFICATE:

It is certified that upon instructions of our client, it is the first private complaint filed
before this Learned Court.

ADVOCATE

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