Civil Suit for Harassment against Police

Civil Suit for Harassment against Police
Civil Suit for Harassment against Police  

In the name of ALLAH, the most beneficent, the most merciful

 

IN THE COURT OF SENIOR CIVIL JUDGE RAWALPINDI

 

________________________

 

…Plaintiff

Versus

 

1.            ____________________

2.            SHO, Police Station ____________________

3.            __________, ASI, Police Station ___, Rawalpindi.

 

Defendants

 

SUIT FOR PERMANENT INJUNCTION

 

Respectfully Sheweth,

                                        

1.              That the plaintiff joined the company of defendant No.1 in the month March 2020 as Sales Officer.

2.              That due to hardworking and in recognition of best performance of plaintiff, he was promoted to the post of Senior Sales Officer in Grade S-3 w.e.f 01-01-2022.

3.              That unfortunately, on 30-07-2022, when the plaintiff was proceeding towards his office after an amount of Rs. ______________/- against sold mobile phones of the company, when at about  07:00, the plaintiff reached at Murree Road near Faizababad, some robbers committed robbery and snatched the above said amount from the plaintiff. The plaintiff immediately reported the Area ___________of the company and then to police through dialing 15, resultantly an FIR No. _____dated _____offence under section 392 PPC, P.S _____, Islamabad was lodged on the application of plaintiff.

4.              That after happening of above said incident, the company of plaintiff suspended the employment of plaintiff by way of issuance of suspension letter on __________

5.              That the above said robbery incident is under investigation and the plaintiff has been joining the investigation when required.

6.              That now, the defendant No. 1 moved an application to defendant No. 2 against the plaintiff, which was marked to defendant No. 3. On the said application, the defendant No. 3 has been harassing, pressurizing and blackmailing the plaintiff, calling the plaintiff at police station without any legal justification.

7.              That in fact, the above said robbery incident as an unforeseen incident and the plaintiff was not at fault in any manner.

8.              That the acts of defendants are illegal, unlawful, unwarranted and against the law.

9.              That the cause of action accrued few time to time after happening of above said incident, when police started  harassing  the plaintiff on the application of defendant No. 1  which is still continuing.

10.          That the cause of action accrued at Rawalpindi,  offices/ police stations of defendants area  also in Rawalpindi, therefore this Honourable court has jurisdiction to adjudicate upon the matter.

11.          That the proper court fee has been affixed on the plaint.

PRAYER:

 

       Under the circumstances, as stated above, it is most respectful prayed that a decree for Permanent injunction, restraining the defendants from blackmailing, harassing, threatening, putting pressure on the plaintiff in any manner whatsoever, may kindly be passed in favour of plaintiff and against the defendants.  

 

Any other relief which this Honourable court, may deem fit and proper, may also be awarded to the plaintiff.

 

 

Plaintiff

Through       

 

 

                                

VERIFICATION:

Verified on oath at Rawalpindi on ___day of September, 2022 that the contents of the plaint from Para No. 1 to  ____  are true  to the best of my knowledge and belief and rest of the paras are believed to be correct as per information received. 

Plaintiff 


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