Application for Exemption from personal appearance by Accused format

 

Exemption from personal Appearance of Accused 

In the name of ALLAH, the most beneficent, the most merciful

 

IN THE COURT OF MR. SALEEM UN SABIR, ASSISTANT DISTRICT AND SESSIONS JUDGE SECTION 30 RAHIM YAR KHAN

 

The State     Versus     Naeem Ahmed Malik Gujar

 

FIR NO. 55001/18 DATED 02-06-2018, OFFENCES UNDER SECTION 353,500,186,506 PPC, 25-D, TELEGRAPHIC ACT, POLICE STATION CITY-A DIVISION, RAHEEM YAR KHAN

 

 

APPLICATION FOR EXEMPTION FROM PERSONAL APPEARANCE OF APPLICANT/ ACCUSED

Respectfully Sheweth:-

1.               That the applicant is accused in the above said false, frivolous, baseless and vexatious FIR, the trial of which is pending before this Honourable Court and is fixed for 16-12-2021.

 

2.               That the applicant is resident of far flung area i.e Karachi and he has been facing the trial for long time and that too without committing the offence leveled in the FIR. On the other hand, the complainant of FIR (the then the then Deputy Director Anti Corruption, District Raheem Yar Khan) using his influence got lodged the said false FIR after lodging of FIR kept himself silent and never bother to appear before this Honourable Court as well as other Police Officers / Inquiry Officers, so in these circumstances not only the applicant is being punished unjustly but the precious time of this Honourable Court is also being wasted. 

 

3.               That the applicant has also moved an application bearing No. PU021221-454544 dated 13^th December 2021, for inquiry of above said false and frivolous FIR, which is entrusted to the Honourable District Police Officer Raheem Yar Khan, hence the applicant along with documentary evidence has to appear before the Inquiry Officer for proving the above said FIR to be false.   (Proof of pendency of application for inquiry is annexed).

 

4.               That the complainant is a dishonest person, who was earlier transferred/Posted as Deputy Director Anti Corruption, District Raheem Yar Khan from the Post of Assistant Commissioner,  and then to Head Office as OSD, and then AC City Faisalabad and currently he is posted in Chief Secretary Officer as OSD.  The applicant has filed application bearing No. PU010921-45454411  against the complainant for initiating departmental proceedings which is now pending in Services & General Administration Department (S&GAD), Punjab, Lahore. (Proof is annexed).

 

5.               That due to the above said reasons, the applicant would not be able to appear before this Honourable Court hence seeks exemption from his personal appearance only for 16-12-2021.

 

6.               That the applicant assures this Honourable Court that on the next whatever fixed by this Honourable Court, the applicant shall appear before this Honourable Court without any excuse.

 

 

PRAYER:

Keeping in view the circumstances as stated above, it is therefore most humbly requested that the applicant’s personal appearance in the above titled case, may kindly be exempted only for 16-12-2021, in the interest of justice.

It is further prayed that keeping in view the pendency of inquiry of said false FIR before the District Police Officer/ Inquiry Officer, and pendency of other application detailed above, the next date in the titled case may kindly be fixed for any date of March/ April 2022 so that in this period, the Inquiry Officer would be conclude his Inquiry and give his findings in the prescribed time i.e 90 days.

 

Applicant/ Accused

 

                            Through Counsel

 

 

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