In the Court of Sessions Judge, Lahore. Petition No:- of 2015 Mst................wife of Muhammad ..............
,
resident of House No:-35, Mohallah Block Nashtar Colony, Lahore Tehsil and District Lahore. Petitioner
Versus 4 1. 2. The SHO , Police Station Kot Lakhpat, Lahore. ..................Sulahri son of ................., r/o No:-
9 Morcha, near Madra Millat School Chungi Amar Sidhu, Lahore. Respondents . **Habeas Corpus
petition u/s 491 CrPC for the Recovery and production of detenues
namely ................., ................., ................., ................., .................and .................Ali sons and daughters,
from the illegal and improper confinement of the Respondent No:-2 to be produced before this Hon’ble
Court and be set for at liberty. . Respectfully Sheweth:- 1. That the addresses of the parties given at the
head of the petition are true and sufficient for effecting their services. 2. That the Petitioner is the real
mother of detenues namely..................and .................Ali. 3. That brief facts pleading to the instant
petition are that Respondent No:-2 on 30.05.2014 took away son of the Petitioner and since then has
kept him in illegal detention and has not produce him before any Court so far. 4. That ....... Ali is a
Rikshaw Driver and on 30.5.2014 a passenger namely Sameel Veera Ejaz wife of Ejaz resident of Garden
Town, Lahore hired is Rikshaw from the Main Gate of Sheikh Zaid Hospital, Lahore for Garden Block,
Garden Town, Lahore and when the Rikshaw was moving toward the Garden Block two unknown young
men stopped the Rikshaw and on gun point snatched away the some valuable gold ornament and
mobile cell phone from the passenger Sameel Veera Ejaz and they fled away with the valuables articles
and upon this the passenger Sameel Veera Ejaz asked ....... Rikshaw Driver to go to Police Station Garden
Town Lahore where she got registered a case FIR No:-510/2014 Offence u/s ………PPC dated 30.5.2014
since then the son of the Petitioner is in the illegal custody of the police although he is not required by
the police is connection with any inquiry or investigation of any criminal case but Respondents by
abusing his position as a public servant has illegally detain his with a mala fide intention in just to
blackmail and is as illegal gratification for realising his son from their illegal confinement threatened is
that otherwise he will involve his son in false criminal cases and demanding Rs.50000/. 5. 5 That it is
pertinent to mention here that there is no anyone criminal case is registered against ....... Ali regarding
this matter. 6. That the Petitioner has no other efficacious or speedy remedy available to him except to
invoke the original criminal jurisdiction by this Hon’ble Court. PRAYER It is, therefore, most respectfully
prayed that petition may kindly be accepted and the Respondents be directed to produced the
detenue ....... Ali before this Hon’ble Court and be set at liberty in the interest of justice. Any other relief
which this Hon’ble Court deems fit and proper be given. Certificate:- Dated:-30.06.2014 Petitioner
Through: Advocate, High Court, Lahore. This is to certified that as per instructions provided by my client
this is first petition on the subject before this Hon’ble Court. Advocate.
