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14 November 2019 ·

Draft/Specimen/Format: Noor Law Associates

Private Complaint under section 200 CrPC before Magistrate Criminal lawyer
***************************************
IN THE COURT OF CONCERNED LEARNED AREA MAGISTRATE,
LAHORE Exploring the World of Law
Lawyer & law firm
PRIVATE COMPLAINT NO:____________/2018
___, RESIDENT OF ____, LAHORE.
….…Complainant
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VERSUS
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i. ____, SON OF UNKNOWN
ii. ____, DUGHTER OF UNKNOWN
BOTH RESIDENTS OF ____, LAHORE.
Muneeb Law Book House
……Respondents
Book shop
COMPLAINT UNDER SECTION 200 CRPC
RESPECTFULLY SHEWETH,
1. That the addresses of the parties of the purpose of issuance of
Yasir Shami & Nasir Afro
summons/warrants issued by this Honorable court have correctly been given
above. See more of The Legal Mentors - TLM on Facebook Public figure

2. That through the instant complaint, the complainant humbly seeks

indulgence of this learned court for summoning and conviction of the
Êrtugŕul ghazi
respondents/ accused Logpersons
In or
for committing heinous Create
crimes and takingNew
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in their hands
3. That succinctly stated facts giving rise to the filing of complaint in hand are
that the complainant is in peaceful possession of upper portion of the
Federal Board of Revenue
property situated at ______, Lahore. The complainant is a retired banker
Government organisation
and he has been delivering lectures at various universities and private
colleges since his retirement. The complainant obtained above mentioned
property at rent and he has been enjoying the possession of the same as a
Pakistan Legal Advisory
peaceful tenant.
Lawyer & law firm
4. That respondent/ accused no. 2 dwells at the lower portion/ ground floor
of aforesaid property as tenant. The respondent no. 2 is running an unknown
and suspicious business at the place of her residence and her customers
Punjab Judicial Academy
often visit the portion occupied by her even at odd hours. The complainant
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and his family members had requested the respondent no. 2 to mend her
ways of business because the complainant and his family members were
facing severe problems due to frequent visits of her customers. However,
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she never paid any heed to the requests of the complainant. On the contrary,
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she carried on her suspicious business and activities.
5. That the married daughter of the complainant, namely _____ resides at
____(out of Pakistan) with her husband but for the purpose of her education
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she is living with the complainant at his residence these days. The daughter
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of the complainant is doing her MBA Marketing from Punjab University. On
26th of January 2018 at about 1:00pm when the daughter of the complainant
tried to park her car in the porch she was forbidden by the respondent no. 2
HIAS
to do the same because respondent no. 2 wanted one of her customers to
Non-profit organisation
park the car in the porch but the daughter of the complainant refused to let
any outsider park his car inside the house. The complainant also reached
the spot and he once again requested the respondent no. 2 to leave her
mysterious activities. The respondent no. 2 threatened the complainant and Recent post by Page
his daughter that she would teach both of them a lesson but the complainant
and his daughter left the spot and went to their residence that is upper
portion of the house. The Legal Mentors - TLM
6. That after half an hour someone knocked at the door of the upper portion 6 June at 13:35
of the property, wherein, the complainant resides; the daughter of the
15 unusual but seriously effective Tips to
complainant went to open the door. When the daughter of the complainant improve your communication skills
opened the door she found respondent no. 1 along with three unknown
persons standing at the door. The moment she opened the door
8 11 shares
respondent/accused no. 1 grabbed the daughter of the complainant from her
hair, when the complainant tried to release her from her clutches,
Share
Respondent No. 1 kicked the complainant, snatched his phone and locked
the door from outside and took away the daughter of the complainant to the
lower portion of the house. The respondents along with two unknown The Legal Mentors - TLM
persons beat the daughter of the complainant. While respondent no.1 had 4 June at 17:50
grabbed the daughter of the complainant through her hair, respondent no. 2
snatched heavy gold chain with diamonds from her neck and then after See photo
beating her they locked her in a room and kept her in illegal detention,
moreover, they opened the motor vehicle of the daughter of the complainant 13 1 comment 9 shares
Toyota Corolla and took away registration book of the vehicle along with the
Laptop of Apple company of latest model owned by the daughter of the Share
complainant which was placed at the rear seat of aforesaid vehicle.
7. That the complainant was detained in the upper portion along with his
wife, he made much noise but of no use, therefore, he couldn’t resist while The Legal Mentors - TLM
his daughter was being detained and beaten up. After a while, other 4 June at 17:17
daughter of the complainant, namely _______ reached the premises
See photo
unlocked the complainant and thereafter the complainant along with other
daughter went to the lower portion and rescued the daughter of the
complainant. The respondent no. 1 flew away with diamond and gold chain, 11 3 comments 8 shares
laptop and original documents of aforesaid vehicle. The police also reached
the spot and the complainant also submitted an application for registration of Share
FIR against the culprits i.e. respondents but due to some unknown reasons
they failed to take any action against the respondents. Copy of application
submitted to police is appended herewith. English (UK) · िह ी · ‫ · اردو‬ಕನ ಡ ·
8. The illegal and unlawful acts of the respondent amount to heinous മലയാളം
offences and crimes and they also took away valuable items of value more
than one million, therefore, they are liable to be prosecuted inter-alia under Privacy · Terms · Advertising · AdChoices ·
following sections: Cookies · More
i. 149, PPC-1860: Unlawful assembly Facebook © 2020
ii. 347, PPC-1860: Wrongful confinement to extort property, or constraint to
illegal act
iii. 354, PPC-1860: Assault and criminal force to women with intent to
outrage her modesty
iv. 386, PPC-1860: Extortion by putting a person in fear of death or grievous
hurt
v. 356, PPC,1860: Assault and Criminal force in attempt to commit theft of
property carried by person
PRAYER
In aforementioned circumstance, it is humbly prayed the respondents may
be summoned and punished in accordance with the law.
COMPLAINANT
Through
ZEESHAN AHMAD MALIK
Advocate High Court

“THE LEGAL MENTORS”

66/3, HAJVERY COMPLEX, 2-MOZANG ROAD, LAHORE.
CERTIFICATE:
It is certified that upon instructions of our client, it is the first private
complaint filed before this Learned Court.
ADVOCATE

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