Appeal 302

IN THE HONOURABLE LAHORE HIGH COURT,
RAWALPINDI BENCH, RAWALPINDI
Cr. Appeal No. _____/2006
Date of Filing District Whether filed by Stamp

appellant or
advocate
-09-2006 Rawalpindi Malik Waheed
Anjum,
Advocate
Supreme Court
In the matter of:
Miran Baksh son of Khuda Baksh, resident of Village

Pindori, P.S. Chauntra, District Rawalpindi.
(Now confined in Central Jail, Adiala, Rawalpindi)
…Appellant
Versus
1. The State
2. Qadeer Ahmad son of Ghulam Mohammad.
R/o Village Pindori, P.S. Chauntra, District
Rawalpindi.
…Respondents
Offence Under Section 302 (b) PPC.

Sentence Death, to pay a
compensation of Rs.
300,000/- to legal heirs of
deceased, in default R.I. for
six months
Appeal U/S 410 Cr.P.C against the
judgment dated 20-09-06
passed by Rana Nisar
Ahmad Khan, Learned
A,S,J, Rawalpindi in
private complaint titled as
Shakeel Ahmad Vs Miran
Baksh etc.
Prayer in Appeal To set-aside conviction and
sentence and to acquit the
appellant.
Respectfully Sheweth,
1. That the allegations as contained in the private
complaint are that appellant and five others
murdered one Tanvir Iqbal, who died at the spot and
the accused then fled away from the spot. The
complainant firstly lodged FIR No. 91 dated 30-05-
2001 and then filed private complaint.
2. That appellant and five others were challaned to
court, charge against them was framed, to which
they pleaded not guilty hence the prosecution
evidence was summoned. After recording
prosecution evidence, statement of the accused
persons, the Learned A,S,J, Rawalpindi vide
impugned judgment acquitted five other co-accused
persons while convicted and sentence the appellant
hence this appeal.
GROUNDS
a. That prosecution has miserably failed to

substantiate the charge against the appellant.
b. That three agencies investigated the case and

found the appellant quite innocent.
c. That the prosecution did not produce important
witness of the case who was present when the
injury was received by the deceased. Driver Javed
and Masood Akhtar were also not produced.
d. That during the investigation they gave their

statements that some unknown person has
committed the murder. This was reason that both
these witnesses were not produced by the
prosecution.
e. That Miran Baksh at the time was seriously

injured and plaster was available on his right leg,
so he cannot even sit in the vehicle if the actual
version is compared.
f. That learned trial court on the same evidence

acquitted five others while on the same evidence,
convicted and sentenced the appellant.
g. That learned trial court has discussed the defence

taken by the appellant side and did not observe
the settled principle of justice that prosecution is
duty bound to prove its case beyond shadow of
doubt.
h. That the impugned judgment relating to the

conviction of the petitioner is against law and
facts of the case.
i. That appellant is liable to be acquitted.
j. That no offence is proved against the appellant.

PRAYER
In view of above, it is respectfully prayed that

appeal may be accepted and appellant may be
actuated.
Appellant
Through
(Malik Waheed Anjum)
Advocate Supreme Court,
Of Pakistan
C.C. No. 15926
Certificate:-
Certified that as per instruction received, this is the first
appeal ever moved before this Honourable Court.
Counsel
Cr. Misc No. _______/2006
IN
Jamil Sabir Vs The State
PETITION U/S 426 Cr.P.C.
1. That the petitioner has been convicted and

sentenced for 7 Years R.I, he is behind the bar
since his date of arrest i.e 13-07-2004 and he has
been given the benefit of doubt U/S 382-B Cr.P.C.
2. That according to the law, the petitioner is entitled

for the suspension of the sentence.
3. That there is no likelihood for the hearing of the

appeal in the near future.
4. That the sentence is short.
In view of above, it is, most humbly prayed that till

pendency of the appeal, the sentence of the petitioner
may be suspended and the petitioner may be released
on bail.
Petitioner
Through:
(Malik Waheed Anjum)

Of Pakistan
C.C. No. 15926
Application for which urgency is claimed should be

submitted the Deputy Registrar before 11 AM and will
ordinary be laid before the judge appointed to dispose of
application of this class on the day following that on which
application is presented
The application may, however, if especially requested and
the reasons for the request stated be submitted for orders
on the day of presentation. In no case, however, will an
application received after 11 a.m. be submitted for orders
on the day of presentation.
To,
The Deputy Registrar,
Lahore High Court,
Rawalpindi Bench,
Rawalpindi.
Cr. A No. ______/2006
Petition Under Section 410 Cr.P.C

Sir,
Will you kindly treat the accompanying petition
as an urgent one in accordance with the Provision of
Rules 9, Chapter 3-A, Rules and Orders of the High Court,
Lahore Volume V.
The grounds of urgency are as under:-
Malik Waheed Anjum

Of Pakistan.
C.C. No. 15926
Rawalpindi.
Dated:- __-__-2006

INDEX
SR. DESCRIPTION OF ANNEX PAGES

NO. DOCUMENTS
1. Appeal 1-2
2. Judgment “A” 3-8
3. Petition U S 426 C r.P.C “B” 9
4. Vakalatnama 10
Petitioner
Through
Malik Waheed Anjum

Of Pakistan.
C.C. No. 15926

Cr. Misc No. _______/2006

IN
Petition Under Section 151 CPC for Grant of

Exemption from Filing Attested Copies of
Documents
1. That attested copies above documents are not

available with the petitioner at present.
2. That photocopies duly attested by the Counsel

are attached. The matter is urgent one.
It is, therefore, respectfully prayed that petitioner

may be granted exemption from filing attested
documents.
Petitioner
Through
Malik Waheed Anjum

Of Pakistan.
C.C. No. 15926

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IN THE HONOURABLE LAHORE HIGH COURT,

RAWALPINDI BENCH, RAWALPINDI

Cr. Appeal No. _____/2006

Date of Filing District Whether filed by Stamp

In the matter of:

Miran Baksh son of Khuda Baksh, resident of Village

(Now confined in Central Jail, Adiala, Rawalpindi)

Offence Under Section 302 (b) PPC.

1. That the allegations as contained in the private

complaint are that appellant and five others

murdered one Tanvir Iqbal, who died at the spot and

the accused then fled away from the spot. The

complainant firstly lodged FIR No. 91 dated 30-05-

2001 and then filed private complaint.

2. That appellant and five others were challaned to

court, charge against them was framed, to which

they pleaded not guilty hence the prosecution

evidence was summoned. After recording

prosecution evidence, statement of the accused

persons, the Learned A,S,J, Rawalpindi vide

impugned judgment acquitted five other co-accused

persons while convicted and sentence the appellant

hence this appeal.

a. That prosecution has miserably failed to

b. That three agencies investigated the case and

d. That during the investigation they gave their

e. That Miran Baksh at the time was seriously

f. That learned trial court on the same evidence

g. That learned trial court has discussed the defence

h. That the impugned judgment relating to the

i. That appellant is liable to be acquitted.

j. That no offence is proved against the appellant.

In view of above, it is respectfully prayed that

Jamil Sabir Vs The State

PETITION U/S 426 Cr.P.C.

1. That the petitioner has been convicted and

2. That according to the law, the petitioner is entitled

3. That there is no likelihood for the hearing of the

4. That the sentence is short.

In view of above, it is, most humbly prayed that till

(Malik Waheed Anjum)

Application for which urgency is claimed should be

Jamil Sabir Vs The State

Petition Under Section 410 Cr.P.C

The grounds of urgency are as under:-

Malik Waheed Anjum

IN THE HONOURABLE LAHORE HIGH COURT,

Jamil Sabir Vs The State

SR. DESCRIPTION OF ANNEX PAGES

Malik Waheed Anjum

IN THE HONOURABLE LAHORE HIGH COURT,

Cr. Misc No. _______/2006

Jamil Sabir Vs The State

Petition Under Section 151 CPC for Grant of

1. That attested copies above documents are not

2. That photocopies duly attested by the Counsel

It is, therefore, respectfully prayed that petitioner

Malik Waheed Anjum

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