Before The Session Judge Mohmond

BEFORE THE SESSION JUDGE MOHMOND
Cr.R.No._______/2020
Dawajan S/o Sefat

R/O Aipi Kor Dawezai Tehsil Padialai, District Mohmond.
.. . Petitioner/Complainant
Versus
1. Rahim S/o Tamin
R/O Aipi Kor Dawezai Tehsil Padialai, District Mohmond
2. The State. .. . Respondents
__________________
REVISION PETITION U/S 439 A Cr.P.C

AGAINST THE IMPUGNED JUDGMENT
AND ORDER DATED 08.01.2020 PASSED
BY THE LEARNED JUDICIAL
MAGISTRATE-11 MOHMOND,
WHEREBY THE COMPLAINT
OF PETITIOER / COMPLAINANT
HELD NOT MAINTAINABLE AND
DISMISSED.
Prayer-In-Revision:
2
On acceptance of this revision petition, the

impugned judgement and order dated
08/01/2020 passed by the learned judicial
magistrate-11 mohmond my kindly be set-
aside, the complaint of the
petitioner/complainant be maintained for

further proceeding according to law and
fair trail opportunity be provided to the
petitioner/complainant according to law.
___________________
Respectfully Sheweth:
The facts of the case are as under:
1. That the petitioner/complainant is the permanent resident of

Aipi Kor Dawezai Tehsil Padialai, District Mohmond and is
owner of large number of land, while the respondent No1.is
residing in city Lahore and visited the village in a special
occasion. the disputed land is also surrounded by the land of
petitioner/complainant situated in village Aipi kor dawezai
Pandiali.
2. That the respondent No.1 purchased 08 (jerab) land in the

middle of the land of the petitioner/complainant with bad
intention. To this effect the petitioner/complainant file a suit of
pre-emption in the court of civil judge-11which is still pending.
3. That there was a previous dispute between the parties and due
to which he purchased this property, on which several times
quarreled occurred between the parties and apprehension of
breach of peace is there.
4. That there was a breach of piece on this disputed land to this

effect the complainant filed a complaint u/s 145 Cr.p.c in the
subordinate court and he sent that the complaint to the police
for legal proceedings, and the police gave the detail in the naqal
mad, which support the version of the complainant, despite that
the learned Judicial \magistrate without considering the merits
of the case dismissed the complaint, held, not maintainable.
3
(Attested copy of the impugned judgment dated 08/01/2020 is

Annexed as Annexure “A”)
Now the petitioner/ complainant approaches this

Honourable Court, inter alia, on the following amongst other
grounds;
G R O U N D S:
A. That the impugned order and judgment dated 08/01/2020 of

Judicial Magistrate-11 Mohmond which is against law, facts
and evidence available on record.
B. That the impugned order and judgment dated 08/01/2020 of

Judicial Magistrate-11 Mohmond is neither appropriate, nor in
consonance with the provisions of law.
C. That the facts and circumstances also support the version the
petitioner/ complainant.
D. That the petitioner/ complainant seeks leave of this Honourable

Court to raise additional grounds at the time of arguments.
It is, therefore, most humbly prayed that

on acceptance of this revision petition, the
impugned judgement and order dated
08/01/2020 passed by the learned judicial
magistrate-11 mohmond my kindly be set-
aside, the complaint of the
petitioner/complainant be maintained for
further proceeding according to law and
fair trail opportunity be provided to the
petitioner/complainant according to law.
Petitioner/Complainant
Through
Jehan Parwar
&
Syed Shakeel Ahmad
Dated: 12/02/2020 Advocate
High Court,
4
C E R T I F I C A T E:
As per instructions of my client petitioner/ complainant no such like

revision petition has earlier been filed before this Honourable Court.
Advocate
BEFORE THE PESHAWAR HIGH COURT, PESHAWAR
Cr.R.No._______/2016
Junas Khan .…………………………... . Petitioner/Complainant

Versus
Qazi Ilyas-ul-Haq & another. ... . . . . . . . . . . . . . . Respondents
I N D E X
S.No Description of Documents Annex Pages

1. Opening Sheet A
2. Revision Petition 1-5
3. Copy of judgment dated 15.11.2016 “A” 6-16
passed by learned ASJ-IV, Nowshera
4. Wakalatnama 17
Petitioner/Complainant
Through
Muhammad Saeed Khan

Advocate
High Court, Peshawar
Dated: 25.11.2016 Cell: 0300-9020797
(A)
Opening Sheet for Criminal Revisions

(U/S 439 Criminal Procedure Code)
IN THE PESHAWAR HIGH COURT, PESHAWAR
(Judicial Department)
Criminal Revision No._____________/2016
District Date of Whether filed by complainant in Stamp on

Filing person or by pleader or agent petition
Petition
Peshawar 25.11.2016 Muhammad Saeed Khan Nil

Advocate, Peshawar
Junas Khan .…………………………............. . Petitioner/Complainant

Versus
Qazi Ilyas-ul-Haq & another. ... . . . . . . . . . . . ……….. . . Respondents
Appeal against the order of: Additional Sessions Judge-IV, Nowshera
Dated: . . . . . . . . . . . . . . . 15.11.2016
Charge u/s: . . . . . . . . . . . 302/324/ 34 PPC
Sentence: . . . . . . . . . . . . Accused/ respondent No.1 was convicvted and

sentenced u/s 302 PPC for life imprisonment
alongwith fine of Rs.2,00,000/- to be paid to the
legal heirs of both the deceased, benefit of
Section 382-B Cr.PC was also extended to the
accused
Prayer: . . . . . . . . . . . . . . On acceptance of this revision petition, the

imprisonment awarded to convict/ respondent
No.1 by the learned Additional Sessions Judge-IV
Nowshera vide order dated 15.11.2016 Session
case No.7 of 2016 may very graciously be
enhanced to major penalty of death alongwith
compensation amount may also be enhanced
according to law.
(GROUNDS OF REVISION ARE ATTACHED)

Before The Session Judge Mohmond

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BEFORE THE SESSION JUDGE MOHMOND

Dawajan S/o Sefat

2. The State. .. . Respondents

REVISION PETITION U/S 439 A Cr.P.C

On acceptance of this revision petition, the

petitioner/complainant be maintained for

The facts of the case are as under:

1. That the petitioner/complainant is the permanent resident of

2. That the respondent No.1 purchased 08 (jerab) land in the

4. That there was a breach of piece on this disputed land to this

(Attested copy of the impugned judgment dated 08/01/2020 is

Now the petitioner/ complainant approaches this

A. That the impugned order and judgment dated 08/01/2020 of

B. That the impugned order and judgment dated 08/01/2020 of

D. That the petitioner/ complainant seeks leave of this Honourable

It is, therefore, most humbly prayed that

As per instructions of my client petitioner/ complainant no such like

Junas Khan .…………………………... . Petitioner/Complainant

S.No Description of Documents Annex Pages

Muhammad Saeed Khan

Opening Sheet for Criminal Revisions

District Date of Whether filed by complainant in Stamp on

Peshawar 25.11.2016 Muhammad Saeed Khan Nil

Junas Khan .…………………………............. . Petitioner/Complainant

Appeal against the order of: Additional Sessions Judge-IV, Nowshera

Charge u/s: . . . . . . . . . . . 302/324/ 34 PPC

Sentence: . . . . . . . . . . . . Accused/ respondent No.1 was convicvted and

Prayer: . . . . . . . . . . . . . . On acceptance of this revision petition, the

(GROUNDS OF REVISION ARE ATTACHED)

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