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| APPLICATION FOR MEDICAL EXAMINATION |
Purpose: to avail the medical facility by the accused who is confined in jail premises.
IN THE
COURT OF LEARNED SESSIONS JUDGE, RAWALPINDI
In the
matter of:
(Full name, parentage, and address of
the petitioner). Presently confined in Central Jail Rawalpindi
…Petitioner
Versus
The State
…Respondent
(CASE FIR NO. 168 DATED 28-02-2018 U/S 392 PPC P.S. NEW TOWN, RAWALPINDI)
APPLICATION FOR MEDICAL EXAMINATION AND
MEDICAL TREATMENT
Respectfully Sheweth,
1. That
the petitioner has falsely been involved in the above-mentioned case by the
complainant making collusion with the police while the petitioner has got
nothing to do with the alleged offenses and he is innocent totally.
2. That
the petitioner was arrested on 05-04-2018 but he was not mentioned in the
record and he was severely beaten by the police. Due to the torture and cruelty
of the police officials, the petitioner was seriously injured and he sustained
28 stitches on the Bailly and the police falsely and by fabricating the false
story registered another FIR of suicide attempt just to save their skins.
3.
That
the petitioner is in the custody of the police for the last 12 days and he is
on remand for the last 09 days but the police have not got the petitioner
medically examined. The petitioner requires exhaustive internal examination as
it is strongly apprehended that during the brutal physical torture on the part
of the police the petitioner suffered certain critical internal injuries which
could only be diagnosed by a complete exhaustive internal check-up of the
petitioner. In case the petitioner is not properly examined by the concerned it
is apprehended that his life would be in great jeopardy and there would be
every likelihood that this man is going to die. The seriousness of the
situation could also be realized by considering the plea of the police which
they have taken that this man has attempted suicide whereas no such attempt was
ever made by the petitioner. This shows that this petitioner is having internal
injuries.
4.
That
no treatment of the above said injury is given to the petitioner for the last
09 days. The injury of the petitioner / accused is deteriorating day by day. If
the petitioner is not medically examined and treated his life would be at
stake. It is worth mentioning here that the jail hospital is not having the required
operations for an exhaustive internal check-up of the petitioner so it would be
appropriate to send the petitioner to some other outside hospital having all
the required equipment.
5.
That
the petitioner immediately needs medical treatment and if he is not medically
examined and also if he is not properly medically treated the life of the
petitioner would be in danger.
6.
That
in the interest of justice and for the life of the applicant it is necessary
that the petitioner is medically examined and treated accordingly.
In view of the above, it is most humbly
prayed that direction may kindly be issued to the Superintendent Jail to
produce the accused in the Learned Court and he may kindly be sent immediately
to the concerned hospital for medical examination and treatment so that the
ends of justice could be fulfilled.
Applicant
Through
(Counsel)
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