District Standing Medical Board Application against MLC

District Standing Medical Board Application against MLC 

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

 

Draft of Application for constitution of District Standing Medical Board for reexamination of injuries in MLC

 

If some one on the basis of self inflicted injuries has lodged false FIR against you, you can challenge that MLC (Medico Legal Certificate) by way of filing an application before concerned Magistrate with the request to constitute District Standing Medical Board for reexamination of alleged injuries.

 

 

IN THE COURT OF ILLAQA MAGISTRATE P.S SADDAR BERONI, RAWALPIDI

 

Saleem Akbar Ahmed son of Malik Ahmed Nabeel Butt R/o House No. 5454557, Street No. 257, Sitara Market, Rawalpindi

             

Applicant

 

Versus

 

The State

 

Respondent

 

APPLICATION FOR CONSTITUTION OF DISTRICT STANDING MEDICAL BOARD FOR REEXAMINATION OF INJURY NO. 2 (MLC NO. 2266/2020) IN CASE FIR NO. 406 DATED 15-05-2020 OFFENCE UNDER SECTIONS 337G, 279, 354,452,147,427,149 PPC P.S SADDAR BERONI, RAWALPINDI

 

Respectfully Sheweth:

 

1.               That on 13-05-2020 at about 6:45 PM, the complainant’s brother namely Jamil Malik Gujar, aggressively and forcefully hit the main gate of the applicant’s house. The applicant and his brother namely Rehan Malik Gujar opened the gate. Said Jamil Ahktar Gujar started abusing and quarrelling with applicant and his brother and alleged that the leg of his son age about 2 years has been broken due to vehicle (Carry Dabba) of applicant bearing No. RIS-11000 parked near his house.  The applicant and his brother proceeded to the said vehicle and found screen wind of vehicle damaged.

2.               That the applicant and his brother requested the said Jamil Malik Gujar and his other family members present there, to produce the alleged injured child but they did not do so rather they all started quarrelling with applicant and his brother. The applicant reported the matter to 15 Police through his Mobile No. 00332-22445587, upon which, 2 policemen reached at the spot but they did not do any legal proceedings against the persons and directed the applicant to file application to concerned police post. It is wroth mentioning here that before arrival of 15 Police Officials, another person wearing Muhafiz Police uniform (relative of Jamil Malik Gujar) reached at the place of occurrence and straightened pistol towards the applicant & his brothers and threatened of being killed.

 

3.               That on same day, without any delay, the applicant filed written applications dated 13-05-2022 to concerned police post as well as Police Station but no legal proceedings was taken on said applications.

 

4.               That two days after happening of above stated incident, the said Jamil Malik Gujar in connivance with his relative Muhfiz Police Official and by joining hands with local police, got lodged above said false and frivolous FIR against the applicant, his brother and others.

 

5.               That in the said FIR, besides leveling other false allegations, it is also alleged that applicant while driving his Suzuki Carry Dabba run over the leg of injured child namely Maqsood Butt aged about 2 years.

 

6.               That in fact, neither the said vehicle was being driven by applicant nor was vehicle run over the leg of said alleged injured child.

 

7.               That in the said MLC, following has been opined by the Doctor:-

 

“Incomplete Fracture is seen in (R) Fibula”

 

The opinion of Doctor itself negates the version of complainant in FIR because if a heavy weight Suzuki Carry Dabba of 550 K.G run over the leg of a child of 2 years old, it would not cause only “Incomplete Fracture” in right Fibula rather would damage the whole leg.

 

Furthermore, Fibula is a very weak bone and as per science, a fibula fracture can be caused even due to a rolled ankle or an awkward landing.

 

8.               That the injured child might have been fallen down to earth or might have hit the vehicle of applicant’s parked vehicle.

 

9.               That, as per Injury No. 2 in said MLC, the doctor observed as under:-

 

“Tenderness and Swelling in lower right leg”

               

In the said injury, the doctor has not observed any abrasion on any part of the right leg of alleged injured, which also leave a question mark on the veracity of version of the complainant in FIR because if a Tyre of any vehicle run over any part of a human body, it would cause also abrasion on that part of body but in the instant case, the doctor has not observed any abrasion mark on the leg of alleged injured child.

 

10.         That the motive behind breaking the vehicle is that the applicant parked his vehicle near complainant’s house which might have disturbed them. 

 

11.         That the motive behind registration of FIR is that the said persons wanted to save their skin and to counter the application dated 13-05-2020 filed by applicant.

 

Under the above circumstances, it is therefore respectfully prayed that an order for constitution of District Standing Medical Board may kindly be issued for reexamination of injury No. 2 as per MLC No. 2266/2020 to bring clear picture and to meet the ends of justice.  

 

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

 

Applicant

Through

 

Counsel

Advocate High Court 

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