IN THE COURT OF LEARNED JUDICIAL MAGISTRATE, PS

RAMNA, ISLAMABAD.

THE STATE VS ABDUL HAMEED

IN CASE FIR NO.398/13, Dated 04-10-2013, OFFENCE U/S

420/468/471 PPC, P.S RAMNA, ISLAMABAD.

APPLICATION U/S 249-A Cr.P.C

Respectfully Sheweth: -
NOTE: (That this fresh application u/s 249 -A Cr.P.C on fresh
ground. Earlier Petitioner’s first application u/s 249-A was
dismissed by this honorable court vide order dated _________ )

1. That the above captioned case is pending adjudication in this

Honorable Court and fixed for today i.e. 26.06.2019

2. That the applicant was implicated in this case falsely and wrongly,
even the record of the case itself indicates the vexatciousness of the
case. The case clearly constitutes malicious prosecution.

3. That since the above said FIR is lodged the complainant never came
to attend the proceedings of this instant case nor he is pursuing it.
From the perusal of record, it reveals that complainant sworn in an
affidavit, wherein he has stated above compromise affected between
the parties and he has also stated that he has no objection if accused
in enlarged on bail or acquitted from charge.

4. That the prosecution produce a single witness despite availing of

ample opportunity, in such a situation it would be unjust to bind the
applicant in a false case and there is no likelihood of conviction
of the applicant.

5. That Petitioner stood surety before the court in bail Petition bearing No.
Cr.Misc. 528B of 2013 titled Mir Meran Khan vs the State etc., for the
accused. It is pertinent to mention here that the said accused Mir Meran
was acquitted from the competent court of jurisdiction, therefore
responsibility of present Petitioner also absolved.

6. That to continue with the trail would be a futile exercise and abuse of
Court proceedings in the malicious prosecution, and this Honorable
Court is empowered under section 249-A of Cr.P.C to acquit the
innocent citizen from a false and malicious case.

Prayer:

In view of above mentioned circumstances, it is humbly

prayed that this case kindly be quashed U/s. 249-A Cr.P.C.-A
and the applicant may graciously be acquitted in above
mentioned criminal case

Applicant

Through

WASEEM AHMED ABBASI

Advocate High Court
Islamabad.
 THE COURT OF LEARNED JUDICIAL MAGISTRATE, PS
RAMNA, ISLAMABAD.

THE STATE VS ABDUL HAMEED

IN CASE FIR NO.398/13, Dated 04-10-2013, OFFENCE U/S 420/468/471 PPC, P.S
RAMNA, ISLAMABAD.

APPLICATION U/S 249-A Cr.P.C

AFFIDAVIT

I Abdul Hameed Abbasi Son of Muhammad Arzan Khan R/o Dr

Qadeer Road House No.194, Gali No.9, Peer Jamshed Colony,
Rawalpindi, do hereby solemnly affirm and declare as under: -
1. That the Applicant has filed today the above titled Petition
before this Honorable Court.

2. That the contents of this Petition are true and correct to the best
of my knowledge and belief and nothing has been concealed or
withheld.

DEPONENT

VERIFICATION
It is verified in oath on this 14 th day of May 2019, that the
contents of above affidavit are true and correct to the best of my
knowledge and belief and nothing has been concealed therefrom.

DEPONENT