IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

Crl. Rev. No._____________/2000

Mst. Shahana Parveen D/o Muhammad Ramzan, caste Sayal, R/o

Mohallah Nasir Abad, Mumtazabad, Multan.
Petitioner
VERSUS
The State. ………..Respondent

Revision Petition U/s 439/435 Cr.P.C.

against the order dated 7.12.2000 passed
by Mr. Sajjad Ahmad Chawan the
learned A.S.J. Multan, through which
Non-Bailable warrants at the petitioners
were issued on first instance, and bail
bonds were cancelled also.

CLAIM IN APPEAL: - To set aside the impugned

order and petitioner be allowed to
join the
regular proceedings of the case.

Case F.I.R. No. 126/94 Dated: 20.8.94

P.S. Bohar Gate, U/s: 420/467, 468/471 P.P.C.
16/10/7/79(Hadood) 1979

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That the above-referred case was registered against the petitioner

and six others The petitioner was released on bail by the court of
competent jurisdiction.
3. That after submission the challan in court, the petitioner remained
attending the trial court on every date. The petitioner was present
on 7.12.2000 in court, when she feels kidney pain. The petitioner
left the court room at 11.00 a.m. The petitioner went to have
advice from doctor because of fasting and in the meantime case
was called. The petitioner was marked absent instead of attending
first call. Non-bailable warrants of the petitioner were issued, the
bail bonds were cancelled and the surety was also summoned.
The order is Annex “A” and Medical Certificate is Annex “B”.

4. That the impugned order is liable to be set aside inter alia on the
following: -

GROUNDS
a) That the impugned order is against the natural justice
and law of equity.

b) That the impugned order is against norms of criminal

law and justice.

c) That the petitioner remained present on each and every

dated and it was first default on the part of petitioner.

d) That there is a process in the law to procure the

attendance of accused persons and the impugned order
is not according to that scheme of law.

e) That the order and action of trial court is harsh and not
warranted under the law.

f) That another co-accused Rasul Bax could not attend the

court on the two dates due to illness. Instead of
production of Medical Certificate, he was sent to jail. In
this situation the petitioner feels the same apprehension.

g) That the petitioner is a lady and has certain protections

under the law.

Keeping view of the above-mentioned

circumstances, it is respectfully prayed that the order
 dated 7.12.2000 may graciously be set aside, and
petitioner be allowed to join the proceedings of the
case.

Any other relief which this Hon’ble Court deems

fit may please be extended to meet the ends of justice.

Humble Petitioner,

Dated: ___________

(Mst. Shahana Parveen)

Through: -
Hamad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176

CERTIFICATE: -

Certified as per instructions of the client,

that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.

Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Rev. No._____________/2000

Mst. Shahana Parveen Vs The State

AFFIDAVIT of: -
Mst. Shahana Parveen D/o Muhammad Ramzan, caste
Sayal, R/o Mohallah Nasir Abad, Mumtazabad, Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above Revision Petition are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of December 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Rev. No._____________/2000

Mst. Shahana Parveen Vs The State

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Opening Sheet.
3 Revision Petition.
4 Affidavit
5 Copy of order. A
6 Medical Certificate. B
7 Vakalatnama
PETITIONER

Dated: ____________
(Mst. Shahana Parveen)

Through: -
Hamad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Misc. No._____________/T/2000

1. Mst. Shahana Parveen D/o Muhammad Ramzan, caste Sayal,

R/o Mohallah Nasir Abad, Mumtazabad, Multan.
2. Saeed Ahmad S/o Ghulam Muhammad, caste Dogar, R/o
Kotla Gamu, Tehsil Jatoi, District Muzaffargarh.
3. Kalsoom Mai W/o Saeed Ahmad, caste Kalro R/o Kotla
Gamu, Tehsil Jatoi, District Muzaffargarh.
4. Shabbir Ahmad S/o Ameer Bakhshh, caste Baloch, R/o
Mouza Mariwal, District Muzaffargarh.
5. Ghulam Yaseen S/o Allah Bakhshh, caste Daya, R/o Mouza
Makwal Tehsil Jatoi District Muzaffargarh.
6. Murad Khan S/o Muhammad Aslam Khan, caste Pathan, R/o
Jameel Abad, Multan.
………..Applicants
VERSUS
The State. ……..Respondent

APPLICATION U/S 526 CR.P.C.

FOR THE TRANSFER OF CASE.

Case F.I.R. No. 126/94 Dated: 20.8.94

P.S. Bohar Gate, U/s: 420/467, 468/471 P.P.C.
16/10 (E.O.H.O. 1979)

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That the above-mentioned case is pending adjudication in the

court of Mian Sajjad Ahmad Chawan, the learned Addition
Sessions Judge, Multan and the next date of hearing is fixed
20.12.2000.
3. That the above-mentioned case was registered by one
Muhammad Nawaz (since deceased) alleged to be the husband of
the applicant No. 1. He alleged that the applicant No. 1 was
abducted by applicant No. 4 with the help and connivance of
applicants No. 2 & 3. He also alleged that divorce deed was
obtained through fraud by applicant No. 1 with the connivance of
applicants No. 5, 6 & Rasool Bakhsh co-accused.

4. That all the applicants were challaned in this case and challan
was submitted in trial court on 8.6.95. The charge was framed for
the first time on 31.7.97 and subsequently on 14.12.98. The
prosecution evidence was closed on 28.3.2000. Statements of
applicants were recorded on 6.4.2000 and the documentary
defence evidence was adduced by applicant No. 1 on 22.4.2000.
This case was fixed for arguments on 26.4.2000.

5. That the case was adjourned for 12.4.2000. In the meantime, the
learned Presiding Officer was transferred and the case was
adjourned for 22.4.2000, 26.4.2000 and 4.5.2000. The case was
fixed for final arguments on 6.5.2000 in the court of learned
Additional Sessions Judge, Mian Sajjad Ahmad Chawan. The
case was fixed for 22.5.2000 for final judgment. Since then, the
case is adjourned for announcement of judgment for 13 times
(27.5.2000, 12.6.2000, 8.7.2000, 20.7.2000, 21.7.2000,
27.7.2000, 3.8.2000, 9.8.2000, 19.9.2000, 30.9.2000, 13.10.2000
& 28.10.2000). On 16.11.2000, Rasool Bakhshh co-accused
submitted an application for the dispensation of his presence due
to illness and the case was fixed for 23.11.2000. Rasool Bakhshh
co-accused was not present.

6. That on 23.11.2000 and his non-bailable warrants were issued in

first instance along-with cancellation of bail bond and case was
fixed for 30.11.2000. On this date, Rasool Bakhsh co-accused
was not present and the case was fixed for 6.12.2000. Rasool
Bakhsh co-accused appeared on this date with an application for
submission of new bail bond or restoration of previous bonds. He
also submitted a Medical Certificate to substantiate his absence.
 His application was turned down and Rasool Bakhsh co-accused
was sent to judicial lock-up and the case was fixed for 7.12.2000.

7. That on 7.12.2000, the case was called first time at 10.00 A.M.
and all the accused were present in the court. At 11.00 A.M. the
applicant No. 1 felt kidney pain. The applicant No. 1 could not
take any medicine because of fasting and left the court-room for
having advice of doctor. In the meanwhile, the case was called
and the applicant was marked absent. Non bailable warrants were
issued for the attendance of applicant No. 1 bail bonds were also
cancelled.

8. That the applicants seek transfer of above-mentioned case inter

alia on the following: -

GROUNDS

i) That the final arguments were heard by the learned trial

court on 22.5.2000, but the trial court could not
announce judgment.

ii) That during last month of proceedings of the case, the

behaviour of learned trial court became harsh and
passed such orders without any cogent reason.

iii) That the learned trial court did not follow the principles
of natural justice or the procedure regulated by the
Criminal Code, even requested personally to transfer the
case.

iv) That since the period of 1-1/2 month, the prosecution is

threatening the applicants, that the applicants must be
punished, because they have approached the trial court
for this purpose. The applicants explored the matter and
it was found that the prosecution witnesses are
frequently visiting the residence of the learned trial
court.

v) That the applicants have every likelihood for the

announcement of partial judgment.
 vi) That the applicants have no hope for a just, proper and
impartial decision from the learned trial court.

Keeping in view the above-mentioned

circumstances, it is respectfully prayed that the
trial of the case F.I.R. No. 126/94 dated 20.8.94
P.S. Bohar Gate, Multan, may please be
transferred to any other court of competent
jurisdiction.

Any other direction, order or relief which

this Hon’ble Court deems fit, may please be
granted in the interest of justice.

Humble applicants,

Dated: _________

Through: -
Mujeeb-ur-Rehman Hashmi,
Advocate High Court,
District Courts, Multan.
C.C. No. 20691

CERTIFICATE: -

Certified as per instructions of the client,

that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.

Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Misc. No._____________/T/2000

Mst. Shahana Parveen, etc. Vs. The State.

APPLICATION U/S 526 CR.P.C.

FOR THE TRANSFER OF CASE.

Case F.I.R. No. 126/94 Dated: 20.8.94

P.S. Bohar Gate, U/s: 420/467, 468/471 P.P.C.
16/10 (E.O.H.O. 1979)

AFFIDAVIT of: -
Mst. Shahana Parveen D/o Muhammad Ramzan, caste
Sayal, R/o Mohallah Nasir Abad, Mumtazabad, Multan.

I, the above-named deponent do hereby solemnly

affirm and declare on oath as under: -

1. That the names and addresses of the parties have correctly

been given for the purpose of their summons and citations.

2. That the above-mentioned case is pending adjudication in the

court of Mian Sajjad Ahmad Chawan, the learned Addition
Sessions Judge, Multan and the next date of hearing is fixed
20.12.2000.

3. That the above-mentioned case was registered by one

Muhammad Nawaz (since deceased) alleged to be the husband
of the applicant No. 1. He alleged that the applicant No. 1 was
abducted by applicant No. 4 with the help and connivance of
applicants No. 2 & 3. He also alleged that divorce deed was
obtained through fraud by applicant No. 1 with the connivance
of applicants No. 5, 6 & Rasool Bakhsh co-accused.

4. That all the applicants were challaned in this case and challan
was submitted in trial court on 8.6.95. The charge was framed
for the first time on 31.7.97 and subsequently on 14.12.98.
The prosecution evidence was closed on 28.3.2000.
Statements of applicants were recorded on 6.4.2000 and the
 documentary defence evidence was adduced by applicant No.
1 on 22.4.2000. This case was fixed for arguments on
26.4.2000.

5. That the case was adjourned for 12.4.2000. In the meantime,

the learned Presiding Officer was transferred and the case was
adjourned for 22.4.2000, 26.4.2000 and 4.5.2000. The case
was fixed for final arguments on 6.5.2000 in the court of
learned Additional Sessions Judge, Mian Sajjad Ahmad
Chawan. The case was fixed for 22.5.2000 for final judgment.
Since then, the case is adjourned for announcement of
judgment for 13 times (27.5.2000, 12.6.2000, 8.7.2000,
20.7.2000, 21.7.2000, 27.7.2000, 3.8.2000, 9.8.2000,
19.9.2000, 30.9.2000, 13.10.2000 & 28.10.2000). On
16.11.2000, Rasool Bakhshh co-accused submitted an
application for the dispensation of his presence due to illness
and the case was fixed for 23.11.2000. Rasool Bakhshh co-
accused was not present.

6. That on 23.11.2000 and his non-bailable warrants were issued

in first instance along-with cancellation of bail bond and case
was fixed for 30.11.2000. On this date, Rasool Bakhsh co-
accused was not present and the case was fixed for 6.12.2000.
Rasool Bakhsh co-accused appeared on this date with an
application for submission of new bail bond or restoration of
previous bonds. He also submitted a Medical Certificate to
substantiate his absence. His application was turned down and
Rasool Bakhsh co-accused was sent to judicial lock-up and the
case was fixed for 7.12.2000.

7. That on 7.12.2000, the case was called first time at 10.00 A.M.
and all the accused were present in the court. At 11.00 A.M.
the applicant No. 1 felt kidney pain. The applicant No. 1 could
not take any medicine because of fasting and left the court-
room for having advice of doctor. In the meanwhile, the case
was called and the applicant was marked absent. Non bailable
 warrants were issued for the attendance of applicant No. 1 bail
bonds were also cancelled.
8. That the applicants seek transfer of above-mentioned case
inter alia on the following: -
GROUNDS
i) That the final arguments were heard by the learned trial
court on 22.5.2000, but the trial court could not
announce judgment.
ii) That during last month of proceedings of the case, the
behaviour of learned trial court became harsh and
passed such orders without any cogent reason.
iii) That the learned trial court did not follow the principles
of natural justice or the procedure regulated by the
Criminal Code, even requested personally to transfer the
case.
iv) That since the period of 1-1/2 month, the prosecution is
threatening the applicants, that the applicants must be
punished, because they have approached the trial court
for this purpose. The applicants explored the matter and
it was found that the prosecution witnesses are
frequently visiting the residence of the learned trial
court.
v) That the applicants have every likelihood for the
announcement of partial judgment.
vi) That the applicants have no hope for a just, proper and
impartial decision from the learned trial court.
9. That all the contents of the above affidavit are true and correct
to the best of my knowledge and belief and nothing has been
kept concealed thereto.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
 Crl. Misc. No._____________/T/2000

Mst. Shahana Parveen, etc. Vs. The State.

APPLICATION FOR STAY OF PROCEEDINGS.

Respectfully Sheweth: -
1. That the contents of the main application may please be
treated as the integral part of this application.
2. That the applicants have raised many rational and reasonable
grounds for the transfer of case, and prima facie have a good
arguable case.
3. That the accused persons are entitled to get a fair and just
decision from the court of law.
4. That valuable rights of the applicants are vested with the
result of the case, and judgment under the apprehension may
cause irreparable loss to the rights of the applicants.
It is, therefore, respectfully prayed that the
proceedings in the case may please be stayed till the
final decision of the main application.
Humble Applicants,
Dated: _________

Through: -
Mujeeb-ur-Rehman Hashmi,
Advocate High Court,
District Courts, Multan.
C.C. No. 20691
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
 Crl. Misc. No._____________/T/2000

Mst. Shahana Parveen, etc. Vs. The State.

STAY APPLICATION

AFFIDAVIT of: -
Mst. Shahana Parveen D/o Muhammad Ramzan, caste
Sayal, R/o Mohallah Nasir Abad, Mumtazabad, Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above application are true and correct to the
best of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of December 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Crl. Misc. No._____________/T/2000

Mst. Shahana Parveen, etc. Vs. The State.

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Transfer Application.
3 Affidavit
4 Application u/s 151 C.P.C.
5 Affidavit
6 Vakalatnama

APPLICANTS

Dated: ____________

Through: -
Mujeeb-ur-Rehman Hashmi,
Advocate High Court,
District Courts, Multan.
C.C. No. 20691

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No._____________/2001

Mst. Shahana Parveen D/o Muhammad Ramzan, caste Sayal, R/o

Mohallah Nasir Abad, Mumtazabad, Multan.
Petitioner
VERSUS

1. Home Secretary, Punjab, Lahore.

2. Superintendent Central Jail, Multan.
3. State.
Respondents

Writ Petition under Article 199 of the

Constitution of Islamic Republic of
Pakistan, 1973, with all enabling provision
of law read with Sec-561 Cr.P.C. to award
the Remissions/Special Remissions to the
petitioner, available under the law.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That a case F.I.R. No. 126/94 dated 20.8.94 was got registered at
Police Station Bohar Gate (Multan), under offence of Zina
(E.O.H.) Ordinance 1979 and Sec-467/468/471 P.P.C. against the
petitioner and six others. The trial of case was conducted by the
learned Additional Sessions Judge, Multan (Mr. Sajjad Ahmad
Chawan) and the petitioner was convicted under section 10 (2)
E.O.H. Ordinance No. VII of 1979 for R.I. ten years plus 30
stripes and fine of Rs. 10,000/- and to further undergo six months
S.I. in case of default of fine. Copy of judgment is Annex “A”.

3. That the petitioner filed an appeal in the Federal Shariat Court.

The learned Appellate Court was pleased to reduce the sentence
 of petitioner to 2 years and fine to R. 1,000/- and in default of
payment of fine to undergo S.I. for 3 months. The benefit of Sec-
382/B was also extended in the favour of the petitioner. The copy
of judgment is Annex “B”.

4. That the petitioner is presently confined in the Central Jail,

Multan, for the passing of sentence awarded to her. The petitioner
is a citizen of Pakistan and must be dealt with according to the
law of land. There are so many remissions awarded to the convict
prisoners on the occasions of “Eid-ul-Fitr”, “Eid-ul-Azha”,
Pakistan Day and “Eid Milad-un-Nabi” etc. for which the
petitioner is entitled as like other convicted prisoners. The
petitioner was taken into custody on 20.12.2000 during this
period occasions of “Eid-ul-Fitr”, “Eid-ul-Azha”, Pakistan Day
and “Eid Milad-un-Nabi” have been passed but no remission is
granted to the petitioner.

5. That the petitioner many times requested for the grant of

remissions, but the respondent No. 2 turned down the requests of
the petitioner on the pretext that the case of the petitioner does
not fall within the purview of grant of remissions due to some
circulars and letters issued by the respondents No. 1 and 3. It is
pertinent to point out that the petitioner is never intimated by
such letters and circulars.

6. That the case of petitioner does not fall within the purview of any
restriction or prohibition and petitioner is entitled for the grant of
remissions awarded time to time on different occasions by the
Government. The respondent No. 2 is under statutory obligation
to grant and calculate remissions in the favour of the petitioner
but he failed to do so. The petitioner is left with no other
adequate, efficacious and speedy remedy except to invoke the
extra-ordinary constitutional jurisdiction of this Hon’ble Court
for the redressal of her grievances.

It is, therefore, respectfully prayed that the

respondents may please be directed to award, grant and
calculate the benefit of remissions announced/declared
 by the Government time to time on different occasions,
to the petitioner.

Any other writ, order, direction or relief which

this Hon’ble Court deems fit, may please be extended in
the favour of petitioners to meet the ends of justice.

Humble Petitioner,
Dated: ___________

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No. ______________/2001

Mst. Shahana Parveen Vs. Home Secretary Punjab etc.

AFFIDAVIT of: -
Mst. Shahana Parveen D/o Muhammad Ramzan, caste
Sayal, R/o Mohallah Nasir Abad, Mumtazabad, Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above titled Petition are true and correct to
the best of my knowledge and belief and nothing
has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of June 2001 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No._____________/2001

Mst. Shahana Parveen Vs Home Secretary, Punjab, etc.

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form __ __
2 Stamp Paper worth Rs. 500/- __ __
3 Writ Petition. __ 1-5
4 Copy of judgment. __ 7-17
5 Copy of judgment. A 19-51
6 Dispensation Application. B 53
7 Vakalatnama __ 55

PETITIONER

Dated: .06.2001
(Mst. Shahana Parveen)

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 In re: C.M. No. _____________/2001
In
W.P. No.____________/2001

Mst. Shahana Parveen Vs Home Secretary, Punjab, etc.

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.

Respectfully Sheweth:-
That certified copies of Annexures “A & B” are not
available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
APPLICANT

Dated: __________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

In re: C.M. No. _____________/2001

 In
W.P. No.____________/2001

Mst. Shahana Parveen Vs Home Secretary, Punjab, etc.

DISPENSATION APPLICATION.

AFFIDAVIT of: -
Mst. Shahana Parveen D/o Muhammad Ramzan, caste
Sayal, R/o Mohallah Nasir Abad, Mumtazabad, Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-mentioned application are true and
correct to the best of my knowledge and belief
and nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of June 2001 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No._____________/2001

Shabbir Ahmad S/o Ameer Bakhsh, caste Baloch, R/o Mouza

Maniwala, P.S. Rohilanwali, District Muzaffargarh (confined in
Central Jail, Multan).
Petitioner
VERSUS

1. Home Secretary, Punjab, Lahore.

2. Superintendent Central Jail, Multan.
3. State.
Respondents

Writ Petition under Article 199 of the

Constitution of Islamic Republic of
Pakistan, 1973, with all enabling provision
of law read with Sec-561 Cr.P.C. to award
the Remissions/Special Remissions to the
petitioner, available under the law.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That a case F.I.R. No. 126/94 dated 20.8.94 was got registered at
Police Station Bohar Gate (Multan), under offence of Zina
(E.O.H.) Ordinance 1979 and Sec-467/468/471 P.P.C. against the
petitioner and six others. The trial of case was conducted by the
learned Additional Sessions Judge, Multan (Mr. Sajjad Ahmad
Chawan) and the petitioner was convicted under section 10 (2)
E.O.H. Ordinance No. VII of 1979 for R.I. ten years plus 30
stripes and fine of Rs. 10,000/- and to further undergo six months
S.I. in case of default of fine and U/s 16 seven years R.I. 30
stripes and Rs. 10,000/- fine. Copy of judgment is Annex “A”.

3. That the petitioner filed an appeal in the Federal Shariat Court.

The learned Appellate Court was pleased to reduce the sentence
 of petitioner to 2-1/2 years and fine to R. 1,000/- and in default of
payment of fine to undergo S.I. for 3 months for each count. The
benefit of Sec-382/B was also extended in the favour of the
petitioner. The copy of judgment is Annex “B”.

4. That the petitioner is presently confined in the Central Jail,

Multan, for the passing of sentence awarded to him. The
petitioner is a citizen of Pakistan and must be dealt with
according to the law of land. There are so many remissions
awarded to the convict prisoners on the occasions of “Eid-ul-
Fitr”, “Eid-ul-Azha”, Pakistan Day and “Eid Milad-un-Nabi” etc.
for which the petitioner is entitled as like other convicted
prisoners. The petitioner was taken into custody on 20.12.2000
during this period occasions of “Eid-ul-Fitr”, “Eid-ul-Azha”,
Pakistan Day and “Eid Milad-un-Nabi” have been passed but no
remission is granted to the petitioner.

5. That the petitioner many times requested for the grant of

remissions, but the respondent No. 2 turned down the requests of
the petitioner on the pretext that the case of the petitioner does
not fall within the purview of grant of remissions due to some
circulars and letters issued by the respondents No. 1 and 3. It is
pertinent to point out that the petitioner is never intimated by
such letters and circulars.

6. That the co-accused filed a W.P. No. 4870/2001, which was

accepted by his lordship Mr. Justice Muhammad Zafar Yasin vide
judgment dated 13.7.2001; and petitioner is entitled for the same
relief. Copy of judgment is Annex “C”.

7. That the case of petitioner does not fall within the purview of any
restriction or prohibition and petitioner is entitled for the grant of
remissions awarded time to time on different occasions by the
Government. The respondent No. 2 is under statutory obligation
to grant and calculate remissions in the favour of the petitioner
but he failed to do so. The petitioner is left with no other
adequate, efficacious and speedy remedy except to invoke the
 extra-ordinary constitutional jurisdiction of this Hon’ble Court
for the redressal of her grievances.

It is, therefore, respectfully prayed that the

respondents may please be directed to award, grant and
calculate the benefit of remissions announced/declared
by the Government time to time on different occasions,
to the petitioner.

Any other writ, order, direction or relief which

this Hon’ble Court deems fit, may please be extended in
the favour of petitioners to meet the ends of justice.

Humble Petitioner,
Dated: ___________

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No._____________/2001

Shabbir Ahmad Vs Home Secretary, Punjab, etc.

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form __ __
2 Stamp Paper worth Rs. 500/- __ __
3 Writ Petition. __ 1-5
4 Copy of judgment of trial court. A 7-17
5 Copy of judgment of appellate court. B 19-49
6 Copy of judgment dated 13.7.2001. C 51-57
7 Dispensation Application. 59
8 Vakalatnama __ 61

PETITIONER

Dated: .08.2001
(Shabbir Ahmad)

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

In re: C.M. No. _____________/2001

 In
W.P. No.____________/2001

Shabbir Ahmad Vs. Home Secretary Punjab etc.

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.

Respectfully Sheweth:-
That certified copies of Annexures “A to C” are not
available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
APPLICANT

Dated: __________

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176