SAMPLE OF PETITION UNDER SECTION 22-A/22-B Cr.P.C FOR SEEKING DIRECTION AGAINST RESPONDENTS NOT TO HARASS THE PETITIONERS ILLEGALLY / UNLAWFULLY

IN THE COURT OF DISTRICT & SESSIONS JUDGE, LAHORE

PETITION NO._______________/2014

1.    Name of girl wife of ---------, daughter of ---------

2.    Name of boy son of ------------,

Both residents of ------------------

…PETITIONERS

Versus

1.    S.H.O Police Station -------------.

2.    Name of father and brothers of girl

…RESPONDENTS

PETITION UNDER SECTION 22-A/22-B Cr.P.C FOR SEEKING DIRECTION AGAINST RESPONDENTS NOT TO HARASS THE PETITIONERS ILLEGALLY / UNLAWFULLY

Respectfully Sheweth:-

1.    That both the petitioners are sui-juris/major and contracted marriage inter se on 20.12.2014, in accordance with Islamic rites and are living as husband and wife happily. Copy of Nikah Nama is attached herewith.

2.    That the petitioners have contracted marriage inter se with their own free will and consent and no element of pressure or coercion ever exercised by either party to the other.

3.    That the parents of the petitioners are un-happy against the marriage of the petitioners and to take revenge of this unhappiness, are intending to get involve the petitioners into false and frivolous cases before the respondent No. 1 while concealing the fact of marriage between the petitioners. The respondent No. 1 is causing illegal and unlawful harassment at the instruction of parents of the petitioners.

4.    That the respondent No. 1 is acting illegally and unlawfully while causing undue harassment to the petitioners instead of the fact that the petitioners are husband and wife and living happily.

5.    That there is no speedy, adequate and efficacious remedy available except to invoke the jurisdiction of this Honourable Court.

PRAYER:

In view of the above submissions, it is, therefore, most respectfully prayed that the application may kindly be accepted and the respondent No. 1 may kindly be ordered to be restrained from causing illegal harassment to the petitioners on the behest of respondents’ No. 2 to 5 as the petitioners are husband and wife inter se having Islamic and lawful contract of marriage in the shape of Nikah.

Any other relief to which this Honourable Court may deems fit may also be awarded.

PETITIONERS

Though

Counsel Name

Advocate

Dated: