Complaint Offence Under Section 493-A PPC

1
IN THE COURT OF LEARNED ILLAQA JUDICIAL

MAGISTRATE, P.S MARGALA ISLAMABAD
MST TEHSINA JAHAN daughter of Saif Ullah Khan, resident

of House No.21, Main Complex Road, G-8/2, Islamabad.
Complainant/ petitioner
Versus
1. Tariq Sultan son of Sultan Khan, resident of House

Nio.7, Street No.37, F-8/1, Islamabad=.
2. SSP Islamabad.
3. SHO P.S Margala Islamabad through SSP Islamabad.
4. Mumtaz Baig, ASI P.S Margala Islamabad through SHO
P.S Margala Islamabad.
5. The State
Respondents
COMPLAINT OFFENCE UNDER SECTION 493-A PPC
IN CASE
FIR No 276
Dated 23-05-2009
U/s 493-A PPC
P.S Margala Islamabad
2
Respectfully Sheweth:-
1. That the complainant was married with respondent No.1

on 26-11-2000 against Dower amount of Rs.1,000/-. (A
copy of NIKAH NAMA is attached herewith as Annex-
A).
2. That after marriage, the complainant and the respondent
No.1 started living as Husband and wife.
3. That due to differences, the respondent No.1 divorced
her on 24-07-2006. (A copy of Divorce Deed is attached
herewith as Annex-B) and thereafter on 02-09-2006 he
revoked the same through in writing and started living as
husband and wife. (A copy of revocation deed duly
signed by the respondent No.1 is attached herewith as
Annex-C).
4. That on 07-05-2008, the complainant received a notice
from Arbitration Council Islamabad directing therein to
appear there on 14-05-2008. The complainant appeared
there on 14-05-2008. The complainant appeared before
Arbitration Council Islamabad, the officials appraised
the complainant that the respondent No.1 on 02-05-

3
2008 vide diary No.2899 moved an application to the
office of the ADLG & RD Islamabad through his
counsel that divorce certificate be issued on the basis of
divorce already pronounced and the complainant got
recorded her statement if respondent No.1 wishes to
divorce her, then afresh divorce deed may be sent to the
complainant, however the complainant and respondent
No.1 had been living as husband and wife.
5. That a friend of respondent No.1 appraised to the
complainant that respondent No.1’s version is that he
has divorced the complainant.
6. That the complainant went to the office of Arbitration
Council on 11-04-2009 and was astonished to know that
on 05-08-2008 divorce certificate had been issued,
which was not within the knowledge of the complainant.
7. That confronting the above mentioned situation, the
complainant filed an application requesting for lodging
of FIR against the respondent No.1 before SHO P.S
Margala Islamabad, containing the following version:-

4
8. That the police Margala investigated the matter and an
FIR No.276 P.S Margala dated 23-05-2009 U/o 493-A
PPC was registered against the respondent NO.1. (A
copy of FIR is attached herewith as Annex-D
9. That the complainant got produced witnesses i.e. her
real son Waqas Ali Khan S/o Imtiaz Ali Khan, Khan
Sarwar S/o Gul Sarwar and the I.O. did not record the
statement Zubair Saifullah Khan S/o Saifullah Khan.
10. That the complainant produced bundle of documents
before the I.O including Revocation Deed but the
respondent No.4 in connivance with the respondent No.1
did not consider the same and most of the documents
were not attached with the file.
11. That the respondent No.1 had very close relationship
with the police officials. The respondent No.2 t0 5 have
failed to act in accordance with law and Police Order
2002 and they have neither arrested respondent No.1 nor
any action was taken against respondent No.1.

5
12. That the complainant had been contacted to the
respondents No.2 to 4 for further progress but the
respondent No.4 and other respondents No.2, 3 and 5
did not listen even a single word of the complainant and
somehow it came to know that the respondent No.1 has
submitted discharge report before Illaqa Magistrate
which is against law and facts of the case and the same
is pending and next date of hearing is fixed for
07-11-2009.
13. That the respondent No.4 investigated the matter with

dishonestly, malicious investigation, willful connivance
of police officials with respondent No.1.
14. That the respondent No.2 to 5 seems to be helpless to

take any action against respondent No.1.
15. That the respondent No.1 is nominated in the FIR and is

connected with the commitment of offence.
16. That the complainant is a working lady, whose emotions

were badly ruptured and heinous cognizable offence was
committed by respondent No.1.
17. That the complainant is not satisfied with the

investigation carried out by respondent No.4 and has
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submitted Discharge report before Illaqa Magistrate,

that’s why it necessitated to file complaint against the
respondents.
PRAYER
In view of the above, it is therefore respectfully prayed that

respondents may kindly be summoned before this Honourable
Court and be proceeded in accordance with law and be punished
under section 493-A PPC, in the interest of justice.
Complainant
Through
(CH.TARIQ MAHMOOD BABAR)

Advocate High Court Rawalpindi
CERTIFICATE
It is to certified that this is the first compliant against the
respondents before this Honourable Court.
Counsel
7

MST TEHSINA JAHAN Vs: Tariq Sultan etc
AFFIDAVIT
I, MST TEHSINA JAHAN daughter of Saif Ullah Khan,

resident of House No.21, Main Complex Road, G-8/2, Islamabad
do hereby solemnly affirm and declare as under:-
That the contents of accompanying complaint are true and correct

to the best of my knowledge and belief and nothing has been
concealed therefrom.
Verified on Oath at Islamabad on _____ day of NOV-2009, the

contents of abovesaid affidavit are true and correct.
Deponent
8

MST TEHSINA JAHAN Vs: Tariq Sultan etc
CALENDAR OF WITNESSES
i. Mst Tehsina Jahan (complainant)
ii. Waqas Ali Khan son of Imtiaz Ali Khan
iii. Khan Sarwar S/o Gul Sarwar.
iv. Zubair Saifullah Khan S/o Saifullah Khan
v. Record Clerk Chairman Arbiration Council ICT

Islamabad through Authorized Officer, office of
ADLG&RD Islamabad alongwith complete record of
case No.MFL-ID/2008/153.
vi. Complete Record alongwith SMS of Mob.No.0333-5117002
The witnesses shall make statement before this Honourable Court

in support of the version of the complainant.
Complainant
Through
(CH.TARIQ MAHMOOD BABAR)

9
Advocate High Court Rawalpindi

Complaint Offence Under Section 493-A PPC

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1

IN THE COURT OF LEARNED ILLAQA JUDICIAL

MST TEHSINA JAHAN daughter of Saif Ullah Khan, resident

1. Tariq Sultan son of Sultan Khan, resident of House

COMPLAINT OFFENCE UNDER SECTION 493-A PPC

1. That the complainant was married with respondent No.1

2. That after marriage, the complainant and the respondent

No.1 started living as Husband and wife.

3. That due to differences, the respondent No.1 divorced

her on 24-07-2006. (A copy of Divorce Deed is attached

herewith as Annex-B) and thereafter on 02-09-2006 he

revoked the same through in writing and started living as

husband and wife. (A copy of revocation deed duly

signed by the respondent No.1 is attached herewith as

4. That on 07-05-2008, the complainant received a notice

from Arbitration Council Islamabad directing therein to

appear there on 14-05-2008. The complainant appeared

there on 14-05-2008. The complainant appeared before

Arbitration Council Islamabad, the officials appraised

the complainant that the respondent No.1 on 02-05-

2008 vide diary No.2899 moved an application to the

office of the ADLG & RD Islamabad through his

counsel that divorce certificate be issued on the basis of

divorce already pronounced and the complainant got

recorded her statement if respondent No.1 wishes to

divorce her, then afresh divorce deed may be sent to the

complainant, however the complainant and respondent

No.1 had been living as husband and wife.

5. That a friend of respondent No.1 appraised to the

complainant that respondent No.1’s version is that he

has divorced the complainant.

6. That the complainant went to the office of Arbitration

Council on 11-04-2009 and was astonished to know that

on 05-08-2008 divorce certificate had been issued,

which was not within the knowledge of the complainant.

7. That confronting the above mentioned situation, the

complainant filed an application requesting for lodging

of FIR against the respondent No.1 before SHO P.S

Margala Islamabad, containing the following version:-

8. That the police Margala investigated the matter and an

FIR No.276 P.S Margala dated 23-05-2009 U/o 493-A

PPC was registered against the respondent NO.1. (A

copy of FIR is attached herewith as Annex-D

9. That the complainant got produced witnesses i.e. her

statement Zubair Saifullah Khan S/o Saifullah Khan.

10. That the complainant produced bundle of documents

before the I.O including Revocation Deed but the

respondent No.4 in connivance with the respondent No.1

did not consider the same and most of the documents

were not attached with the file.

11. That the respondent No.1 had very close relationship

with the police officials. The respondent No.2 t0 5 have

failed to act in accordance with law and Police Order

2002 and they have neither arrested respondent No.1 nor

any action was taken against respondent No.1.

12. That the complainant had been contacted to the

respondents No.2 to 4 for further progress but the

respondent No.4 and other respondents No.2, 3 and 5