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: