IN
THE COURT OF IV-ADDL: SESSIONS JUDGE, KARACHI EAST.
S.C No.2112/ 2017
Khursheed
Khan S/o. Daud Khan,
Muslim,
Adult, R/o H.No.R-32,
New
Rehman Abad Al Haider Society,
Drig
Road, Karachi, East ----------------------------------------------Applicant
VERSUS
The
State
----------------------------------------------------------------------Respondent
FIR
No. 345/ 2017.
U/s
324 PPC
P.S.
Shah Faisal Colony.
APPLICATION UNDER SECTION
516-A CR.P.C. FOR HANDING OVER THE CUSTODY OF PISTOL 30 BORE BEARING NO.31106808,
LOAD MAGAZINE AND ORIGINAL LICENSE OF PISTOL.
It is respectfully prayed by the
applicant abovenamed that this Hon’ble Court may be pleased to pass an order
for custody / possession of the above said Pistol and original license to the
applicant on the consideration of following facts and grounds:
FACTS:-
That the applicant is real owner of the pistol in
question and the applicant is also license holder of the same, therefore the
applicant is entitle to obtain physical custody of the pistol on the basis of
Superdiginma.
Photocopy of Arm License &
Arms License Supplementary Document are enclosed herewith and marked as
annexure ‘A/1 & A/2’
That now the Pistol is lying at Police Station Shah
Faisal Colony, the investigation is completed and the Pistol in question is no
further required by this Hon’ble Court.
Hence this application on the following grounds:-
GROUNDS
1.
That the
applicant being real owner and licensee holder of the Pistol in question, is
liable to file this Application in respect of the pistol in question and is
able to obtain physical possession of the same from this Hon’ble Court on the
basis of Superdiginama.
2.
That the
pistol as per prosecution story was recovered from the possession of applicant
and the applicant is last possessor of the pistol and he is entitled for its
custody as provided in law. The applicant requires the pistol for his security
as he had obtained it after completing codal formalities from the concerned
department. The applicant has also danger to his life from the persons who have
issued threats to him.
3.
That the
applicant undertakes to produce the Pistol in question before this Hon’ble
Court or any Court of law if so required and ordered by the Court.
4.
That the
applicant is law abiding and peace loving citizen of Islamic Republic of
Pakistan and he undertakes to cooperate with the investigation agencies.
PRAYER
It is therefore prayed that this Hon’ble Court may
be pleased to pass an order of the Custody / possession of the above said
Pistol and original license to the applicant on the consideration of foregoing
facts and grounds, in the larger interest of justice.
Prayed
accordingly;
APPLICANT
Karachi:
Dated: 23-12-2017 Advocate for the
Applicant.
IN
THE COURT OF IV-ADDL: SESSIONS JUDGE, KARACHI EAST.
S.C No.2112/ 2017
Khursheed
Khan S/o. Daud Khan------------------------------------Applicant
VERSUS
The
State ----------------------------------------------------------------------Respondent
FIR
No.345/ 2017.
U/s
324 PPC
P.S.
Shah Faisal Colony.
.AFFIDAVIT
I, Khursheed Khan S/o. Daud Khan, Muslim, Adult, R/o Karachi, do hereby state on Oath as
under:-
1.
That I am deponent of this affidavit as well as applicant
in the above titled matter, as such am fully conversant with the facts stated
herein.
2.
That I say that the accompanying application U/s 516-A
Cr.P.C. has been drafted and filed under my instructions, contents whereof are
true and correct to the best of my knowledge and belief and same may be treated
as part and parcel of this affidavit.
3.
That I say that I am owner of PISTOL 30 BORE BEARING NO. 31106808 AND ORIGINAL LICENSE, which is booked in the above titled case and is lying at Police Station Shah
Faisal Colony.
4.
That I say that if and when this Hon’ble Court direct
to me, I will produce the said Pistol before this Hon’ble Court.
5.
That I say that I undertake that I will neither sell
out or change the color of the said pistol, till the finalization of the
matter.
6.
That whatever stated above is true and correct to the
best of my knowledge and belief.
Karachi:
Dated: 23-12-2017 DEPONENT
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