BEFORE THE SESSIONS JUDGE,

LAHORE.

Name , S/o, D/o Father Name , resident of

_____________________.

….Petitioner

VERSUS

1. Learned Judicial Magistrate P.S. Green Town, Model Town

Courts, Lahore.
2. Name , S/o, D/o Father Name , resident of
_____________________.

….Respondents

FIR No. : 357/18 Dated 25.04.2018

Offence : U/s 406/506 PPC
Police Station : Township, Lahore.

REVISION UNDER SECTION 435 Cr.P.C. AGAINST THE ORDER DATED

26.09.2018 PASSED BY JUDICIAL MAGISTRATE, MODEL TOWN
COURTS LAHORE.

Respectfully Sheweth:-

1. That the brief facts leading to file the present

revision petition are that the petitioner lodged the

above said FIR No.357/18 dated 25.04.2018 offence

 u/s 406/506 PPC at police station Green Town Lahore,

against the respondent for not paying the due

payment to the petitioner. Copy of FIR is attached

herewith.

2. That the local police arrested the accused /

respondent No. 2 on 25.09.2018 and presented him

before the Judicial Magistrate P.S. Green Town

Lahore on 26.09.2016 for seeking remand but the

learned Judicial Magistrate on the same day instead

of giving remand, replace the offence u/s 406 PPC

with 403 PPC which is bailable, however, offence u/s

506 PPC is also bailable and on the same day the

Judicial Magistrate released the respondent No. 2 on

bail subject to furnishing the surety bonds to the

tune of Rs.50,000/-. Copy of impugned order dated

26.09.2018 is annexed herewith for kind perusal of

this Honourable Court.

3. That the impugned order dated 26.09.2018 is illegal,

unlawful and is liable to be set aside inter alia on the

following:

GROUNDS
(a) That order of the learned Judicial Magistrate is

against law and facts of the case.

(b) That the learned Judicial Magistrate ignored the

facts of the case that the case is regarding

money matter and the local police mentioned in

their application that the amount has to be

recovered and requested to gave remand of 10

days of respondent but the learned respondent

No. 1 turn down the request of local police and

by replacing the offence 406 with 403 bailed out

the respondent No. 2 on the same day.

(c) That the impugned order is illegal and not

sustainable.

(d) That the impugned order is result of mis-reading

of record.

(e) That the impugned order is against the law and

facts of the case and is liable to be set aside,

otherwise the petitioner shall suffer an

irreparable loss and injury.

It is, therefore, most respectfully prayed

that this revision may kindly be accepted and

the order dated 26.09.2018 passed by the

learned Judicial Magistrate, Model Town Courts

 Lahore / respondent No. 1 may kindly be set

aside.

Any other relief which this Honourable

Court deems fit may also be awarded.

Petitioner

through

Dated:

Advocate
 BEFORE THE SESSIONS JUDGE,
LAHORE.

In re:
VS Muhammad Hussain

(Private Complaint under Section 406/506 PPC Police Station Bata Pur
Lahore filed by respondent)

REVISION UNDER SECTION 435 Cr.P.C. AGAINST THE ORDER DATED

06.05.2016 PASSED BY MS. TABINDA BATOOL, JUDICIAL
MAGISTRATE, FIRST CLASS, LAHORE CANTT.

AFFIDAVIT OF

I, the above named deponent do hereby solemnly affirm and

declare as under:
That the contents of accompanying revision petition are true
and correct to the best of my knowledge and belief and
nothing has been concealed therein.

Deponent
VERIFICATION
Verified on oath at Lahore this ___ day of _______
2016, that the contents of above affidavit are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

Deponent
 BEFORE THE SESSIONS JUDGE,
LAHORE.

In re:
VS Muhammad Hussain

(REVISION UNDER SECTION 435 Cr.P.C. AGAINST THE ORDER DATED 06.05.2016 PASSED BY MS.
TABINDA BATOOL, JUDICIAL MAGISTRATE, FIRST CLASS, LAHORE CANTT.)

PETITION UNDER SECTION 561-A Cr.P.C. FOR STAY OF

PROCEEDINGS PENDING BEFORE THE LEARNED TRIAL COURT.

Respectfully Sheweth:

1. That the petitioner has filed the above titled criminal revision

petition in this honourable court in which no date of hearing

has yet been fixed.

2. That the contents of the revision petition may kindly be read as

an integral part of this petition.

3. That petitioner has made out a good prima facie arguable case

in his favour and the same is likely to succeed.

4. That the balance of convenience lies in favour of the petitioner

and against the respondent.

5. That if the proceedings pending before the learned Judicial

Magistrate First Class Lahore Cantt, are not stayed, the

petitioner shall suffer irreparable loss and injury.

PRAYER:
 Under the above circumstances it is, therefore, most

respectfully prayed that during the pendency of the

criminal revision petition the proceedings pending

before the learned Judicial Magistrate First Class

Lahore Cantt may please be stayed in the larger

interest of justice and equity.

Petitioner

through

Advocate
Dated:
 BEFORE THE SESSIONS JUDGE,
LAHORE.

In re:
VS Muhammad Hussain

(REVISION UNDER SECTION 435 Cr.P.C. AGAINST THE ORDER DATED 06.05.2016 PASSED BY MS.
TABINDA BATOOL, JUDICIAL MAGISTRATE, FIRST CLASS, LAHORE CANTT.)

PETITION UNDER SECTION 561-A Cr.P.C. FOR STAY OF

PROCEEDINGS PENDING BEFORE THE LEARNED TRIAL COURT.

AFFIDAVIT OF

I the above named deponent do hereby solemnly affirm and

declare as under:
That the contents of accompanying petition are true and
correct to the best of my knowledge and belief and nothing
has been concealed therein.

Deponent
VERIFICATION

Verified on oath at Lahore this ___ day of ______

2016, that the contents of above affidavit are true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent