How to challenge the order of a justice of peace through a writ petition? What is a remedy against the dismissal of a petition U/S 22-A/B Cr.P-C for registration of a criminal case? The sample/ format/draft is given here, kindly make necessary changes as per the facts of the case.

Writ Petition against the dismissal of a petition U/S 22-A/B Cr.P-C

Purpose: to impugn the order of a justice of peace, whereby he dismissed the petition U/S 22-A/B Cr.P.C.

Forum: High Court

Parties /title: Implead all the parties of a petition under section 22 A/B including Justice of Peace and State.

PETITION U-A- 199 OF THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF PAKISTAN

Respectfully Sheweth,

The brief facts leading to the instant petition are that the petitioner moved an application before respondent No.2 vide No. PPKR-5/5/2022-544 dated 0305.2021 for registration of a criminal case which was entrusted to respondent No. 3 for necessary legal action, after receiving the said application, respondent No. 3 marked the same to respondent No. 4 for verifying the facts of the case. After verifying the facts and figures of the case, respondent No. 4 did not register a criminal case against the culprits and started lingering on the matter without any reason or justification, and subsequently, the application of the petitioner was converted into the preventive proceeding U/S 107 & 151 PPC which is totally illegal, unlawful and against the norms of the criminal justice system because the spirit of section 154 Cr.P.C is categorically clear that if the cognizable offense is made out, then the concerned police is duty bound to register a criminal case.

That being aggrieved of the said act of respondent No. 4, the petitioner, filed petition U/S 22-A Cr. P.C before the learned Ex-Officio Justice of Peace Rawalpindi, upon which the comments of police were summoned, and after hearing both the parties, the learned court dismissed the petition U/S 22-A Cr. P.C vide order dated 03.06.2021 with the observation that the criminal case U/S 365-B PPC has already been got registered against the petitioner and it seems that the petitioner has filed this petition as a counterblast to the said criminal case against respondent No. 5, hence this writ petition on following:-

G R O U N D S

That while deciding the petition, the learned court observed that the petitioner wants to drag her real brother in a criminal case just to counterblast the criminal case which is got registered against her.

That the said observation is totally against the record and facts of the case because the said criminal registered by respondent No. 5 against one of Raja Azam Mehmood nominated accused in the said crime report, in which the petitioner is an abductee who put her appearance before the learned Area Magistrate and made a statement that she was not abducted by anyone and on the said statement of the petitioner, the said criminal case was canceled by the local police but unfortunately, the learned Justice of Peace while dictating the impugned order could not go through the fact of the case and passed the impugned order in a routine manner. 

That despite all efforts, the respondents are refusing to lodge an FIR, under the relevant provision of the law.

That the impugned order is amount to infringing the fundamental rights of the petitioner.

That no other efficacious and speedy remedy is available to the petitioner except to invoke the jurisdiction of this Hon’ble Court, hence this petition.

Prayer

In view of the above, it is most respectfully prayed that an instant writ petition may kindly be issued and the order dated 03.06.2021 passed by the learned Additional Session Judge/Justice of Peace may kindly be set aside and directions may kindly be issued to the respondent No. 4 to register an FIR on the application of the petitioner against the said culprits, in the interest of justice.

Petitioner              through                 Counsel

Certificate:-

As per instruction received from the petitioner, this is the first writ petition ever moved on the subject.

                                                                                                Counsel

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