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Legal Appeal for Sentence Reversal

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41 views6 pages

Legal Appeal for Sentence Reversal

Uploaded by

kickoffkings110
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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IN THE HONOURABLE LAHORE HIGH COURT,

RAWALPINDI BENCH, RAWALPINDI

Cr. Appeal No. _____/2006

Date of Filing District Whether filed by Stamp


appellant or
advocate
-09-2006 Rawalpindi Malik Waheed
Anjum,
Advocate
Supreme Court

In the matter of:

Jamil Sabir son of Muhammad Sadiq Caste Gujjar r/o


Gujaramal, Tehsil Gujar Khan District Rawalpindi.

…Appellant
Versus
The State
…Respondent
Offence Under Section 9-B in case FIR No. 105
dated 13-07-2004, P.S
Jatli, District Rawalpindi
Sentence 1 Year R.I with fine of Rs.
5000/- and in case of
default, further R.I. 1 month

Benefit of Section 382-B


Cr.P.C was given:

Appeal U/S 48 of CNSA 1997 against


the judgment dated 01-09-
2006 passed by Mr. Sana
Ullah Khan Niazi, Learned
A,S,J, Gujar Khan.
Prayer in Appeal To set-aside the conviction
and sentence and to acquit
the appellant.

Respectfully Sheweth,
1. That the impugned judgment is against the law and
facts borne on the record.

2. That the impugned judgment has resulted into


miscarriage of justice.

3. That Learned Trial Court misread the evidence and


erred in law while awarding conviction and sentence
to the appellant.

4. That the prosecution has miserably failed to prove


its case beyond shadow of doubt against the
appellant.

5. That the conviction and sentence is not


maintainable from the evidence on record.

6. That the recovery from the appellant does not


support the prosecution case.

In view of above, it is humbly prayed that by


accepting the instant appeal impugned order dated 01-
09-2006 may kindly be set-aside and appellant may be
acquitted in the interest of justice.
Appellant
Through
(Malik Waheed Anjum)
Advocate Supreme Court,
Of Pakistan
C.C. No. 15926
Certificate:-
Certified that as per instruction received, this is the first
appeal ever moved before this Honourable Court.

Counsel
IN THE HONOURABLE LAHORE HIGH COURT,
RAWALPINDI BENCH, RAWALPINDI
Cr. Misc No. _______/2006
IN
Cr. Appeal No. _____/2006

Jamil Sabir Vs The State

PETITION U/S 426 Cr.P.C.

Respectfully Sheweth,

1. That the petitioner has been convicted and


sentenced for 1 Years R.I, he is behind the bar
since his date of arrest i.e. 13-07-2004 and he has
been given the benefit of doubt U/S 382-B Cr.P.C.

2. That according to the law, the petitioner is entitled


for the suspension of the sentence.

3. That there is no likelihood for the hearing of the


appeal in the near future.

4. That the sentence is short.

In view of above, it is, most humbly prayed that till


pendency of the appeal, the sentence of the petitioner
may be suspended and the petitioner may be released
on bail.

Petitioner
Through:

(Malik Waheed Anjum)


Advocate Supreme Court,
Of Pakistan
C.C. No. 15926

IN THE HONOURABLE LAHORE HIGH COURT,


RAWALPINDI BENCH, RAWALPINDI
Cr. Misc No. _______/2006
IN
Cr. Appeal No. _____/2006

Jamil Sabir Vs The State

Petition Under Section 151 CPC for Grant of


Exemption from Filing Attested Copies of
Documents

Respectfully Sheweth,

1. That attested copies above documents are not


available with the petitioner at present.

2. That photocopies duly attested by the Counsel


are attached. The matter is urgent one.

It is, therefore, respectfully prayed that petitioner


may be granted exemption from filing attested
documents.

Petitioner
Through

Malik Waheed Anjum


Advocate Supreme Court,
Of Pakistan.
C.C. No. 15926

IN THE HONOURABLE LAHORE HIGH COURT,


RAWALPINDI BENCH, RAWALPINDI
Application for which urgency is claimed should be
submitted the Deputy Registrar before 11 AM and will
ordinary be laid before the judge appointed to dispose of
application of this class on the day following that on which
application is presented
The application may, however, if especially requested and
the reasons for the request stated be submitted for orders
on the day of presentation. In no case, however, will an
application received after 11 a.m. be submitted for orders
on the day of presentation.
To,
The Deputy Registrar,
Lahore High Court,
Rawalpindi Bench,
Rawalpindi.
Cr. A No. ______/2006

Jamil Sabir Vs The State

Petition Under Section 410 Cr.P.C


Sir,
Will you kindly treat the accompanying petition
as an urgent one in accordance with the Provision of
Rules 9, Chapter 3-A, Rules and Orders of the High Court,
Lahore Volume V.

The grounds of urgency are as under:-

Malik Waheed Anjum


Advocate Supreme Court,
Of Pakistan.
C.C. No. 15926
Rawalpindi.
Dated:- __-__-2006

IN THE HONOURABLE LAHORE HIGH COURT,


RAWALPINDI BENCH, RAWALPINDI

Cr. Misc No. _______/2006


IN
Cr. Appeal No. _____/2006

Jamil Sabir Vs The State

INDEX

SR. DESCRIPTION OF ANNEX PAGES


NO. DOCUMENTS
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Petitioner

Through
Malik Waheed Anjum
Advocate Supreme Court,
Of Pakistan.
C.C. No. 15926

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