Strengthen Legal Application

Revised Application:
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IN THE COURT OF FAMILY JUDGE KHAIRPUR
Cr. Application No. _____ of *
Ali Gohar S/o Ali Hyder by caste Magsi, Adult Muslim, R/o Village Magsi near Shah Hussain Bypass, Taluka District Khairpur
Applicant
VERSUS
Mst Rani Bano D/O Late Gul Bahar by Caste Maitlo, Adult Muslim, R/O KTM Officers Colony Luqman Khairpur
Muhammad Hassan
State Department Officer
DSP Complaint Cell Khairpur
S.H.O P-S B Section Khairpur
District and Sessions Judge Khairpur
Respondents
APPLICATION UNDER SECTION * CONTEMPT OF FAMILY COURT CLAUSE (BB) OF THE FAMILY COURTS ACT
The Applicant respectfully submits as under:
*. That prior to this, no application of like nature has been filed before this honorable Court.
*. That the Applicant is a law-abiding citizen of Pakistan and resides at the above-captioned address within the territorial jurisdiction of this Honorable Court.
*. That the Applicant, Ali Gohar, is the ex-husband of Mst. Rani Bano and is currently involved in a family case appeal pending before the 4th Additional Sessions Judge, Khairpur, concerning the return of dowry and other family matters.
False Allegations and Misleading Information:
*. That the Respondents, Mst. Rani Bano and Muhammad Hassan, filed a *-A & B application for an FIR against the Complainant at the District and Sessions Judge Khairpur, misguiding the court by falsely stating that the Complainant was in a drunken condition at the family court on *-*-*, using abusive language and engaging in a fight.
*. However, this incident never occurred; the court diary confirms that the Complainant peacefully met with his minor daughters as per the court's order and left without any disturbance. Even if such an incident had taken place, it falls under the jurisdiction of this honorable family court by the Family Courts Act under Section *, contempt of family court clause (BB), and not under *-A & B or any other law.
Failure to Verify Claims and Legal Procedures:
*. The judge did not verify the claims or follow the legal procedure, leading to an FIR being filed against the Complainant based on misleading information.
*. The Respondents also altered the real father's name and caste of the applicant, listing him as Ali Gohar S/o Allahyar, caste Mangrio, instead of his real identity, Ali Gohar S/o Ali Hyder, caste Magsi, resulting in no court notice being served to him.
*. The DSP complaint cell issued summons to a non-existent person, and the Additional Sessions Judge 3rd allowed the application without verification from the family court. This perjury and misguidance not only targeted the applicant but also undermined the judicial system of District Khairpur.
*. That the DSP acted solely based on the misleading information provided by the respondents, without independently verifying the details of the applicant's real name and identity, which resulted in the issuance of a summons to a non-existent person. This lack of due diligence and verification by the DSP constitutes gross negligence and misconduct in public office.
Prayer:
The Applicant respectfully prays as under:
A) In light of the above, it is respectfully requested that this Honorable Court take necessary legal action against the Respondents for perjury under sections *, *, *, *, *, *, *, *, *, *, *, and * of the Pakistan Penal Code for providing false information with the intent to mislead public authorities.
B) To direct the SHO to submit a complete and accurate report regarding the FIR, in accordance with the court’s order, to the Judicial Magistrate before whom the FIR is pending, ensuring that the report reflects the true facts and that proper legal procedures are followed.
Khairpur,
Applicant
Dated: - -*
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