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IN THE COURT OF IIND ADDL: SESSIONS JUDGE SUKKUR

Cr.Misc: Appln: No. of 2008


IN
Sessions Case No.75 of 2007

S T A T E

V/S

Hidayatulla and others

Offence U/S 324,148, 114,


149,PPC.
Cr.No.49/2007 P.S Abad.

APPLICATION UNDER SECTION 193 CR.P.C

It is prayed on behalf of the complainant


that this Honourable Court may be pleased to join
the accused of column NO.2 namely 1) Inaytullah
2). Allah Dino both sons of Hussain Bux, by caste
Kharos, R/O their own houses near Saeed Abad
Sukkur in the case, on consideration of following
facts and grounds:-
F A C T S

The brief facts of the prosecution case are


that complainant namely Dilmurad, S/O Haji Ali
Murtaza, by caste Jatoi, R/O Village Bachal Shah
Miani Sukkur lodged this FIR with P.S Abad Sukkur
on 20.03.2007 at 1630 hours stating there in that
complainant along with his brother Shahzado after
sopping from Sukkur city were coming back to there
house it was 01.00 pm when complainant party
reached behind the Madrasa of Sain Abdullah Shah
Village Bachal Shah Miani Sukkur where complainant
party saw that accused each namely 1. Hidayatullah
armed with cartridge Pistol 2. Inayatullah armed
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with Gun 3. Allah Dino armed with Pistol all sons


of Hussain Bux, by caste Kharos R/O their own
houses near Saeed Abad and two un-identified
persons armed with Pistol if again seeing will be
identified, out of them Hidayatullah Kharos while
making Hakals to complainant party said them that
why they have taking the hand to accused party and
threatened them and he instigated all the accused
for murder of complainant party , thereafter
accused Hidayatullah made straight with his
cartridge Pistol upon complainant party which hit
the brother of complainant Shahzado, who after
crying fell down, complainant saved his life by
way of falling him on earth, on the sound of fires
complainant’s maternal uncle Haji Murdan S/O
Kareem Bux Jatoi and his cousin Mubarak Ali S/O
Bashir Ahmed Jatoi rushed there, accused party
after seeing them ran away towards their houses,
complainant saw his brother Shahzado that he
sustained fire-arm injury on the back of head and
it was bleeding then complainant with the help of
above name witnesses took his injured brother
Civil Hospital Sukkur for first-aid where
complainant left his brother Shahzado under the
treatment in the supervision of above name
witnesses and he came at P.S and lodged this FIR.

Hence this Application on consideration of


following grounds:-

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(Page No……….3)

G R O U N D S

1. That the I.O with malafide intention mixed with


the accused persons and let off the accused namely
Inyatullah and Allah Dino in column No.2 on the bases
of so called defence evidence managed by the I.O in
league with the accused persons.

2. That the accused persons committed heinous offence


and are connected with the commission of crime and they
all with planning participated in above crime with
intention to commit the murder of complainant party in
broad day light and they all liable be prosecuted under
the law.

3. That the complainant lodged FIR against the above


named accused persons with specific role assigned to
them and committed heinous offence in day light and PWs
also fully supported version of the complainant.

4. That the I.O in league with the accused persons


managed bogus defence evidence in the final report.

5. That there is sufficient evidence against the


accused persons who let off by the I.O.

6. That in the interest of justice join the above


named accused in the above case and proceed in
accordance with law.

6. That further grounds will be urged at the time of


arguments.

SUKKUR:
DATED : 05.2008 ADVOCATE FOR COMPLAINANT

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