The Deputy Inspector General of Police,

Multan Range,
Multan.

Subject: - Registration of Criminal Case of illegal possession of

house & theft of house-hold articles.

Zafar Iqbla Khan Advocate High Court, R/o Street No. 8,

Usmanabad Colony, Multan.
Complainant
Versus
1. Malik Muhammad Ilyas, Inspector Police, presently posted as
Inspector, C.I.A. Khanewal.
2. Khadim Hussain, Head Constable, presently posted at Police
Station Gulgasht, Multan.
3. Muhammad Akram S/o Haji Wahid Bakhsh Khan.
4. Muhammad Nasir sons of
5. Muhammad Nazim Muhammad Akram
All residents of Street No. 8, Usmanabad Colony, Multan.
Respondents/Accused

Respectfully Sheweth: -
1. That on 13.3.2001, at 5 A.M. when I was away from home
and my children were cleaning the house, all the above-
mentioned accused person forcibly and illegally took
possession of my partitioned share of house No. 888/43-K/1,
Usmanabad Colony, Multan and thrown out of some of my
belongings out of the house and after breaking locks of the
rooms inside the house, misappropriated four bags of wheat,
weighing 100 K.G. each and a big box 4 feet X 8 feet wherein
spare beddings and out of season clothes were kept. They
locked the whole house with their own locks. Motive/grudge
for this illegal possession was that accused No. 4 & 5 under
the shelter of accused No. 1 & 2 doing business of adulterated
 mobil oil by packing it in fake printed tins of renowned
companies and supplying the same in the market of Multan,
Shujabad, etc. One day, I used this mobil oil in my own motor
car Suzuki DGB 6000 and the engine of my care ceased
within two days and I had to spend Rs. 12,000/- for its
renovation. I strictly asked respondents No. 4 & 5 to
immediately stop this business. They got annoyed and talked
to respondents No. 1 & 2 who in turn instructed them to take
possession of my house forcibly just to teach me a lesson.

2. That the same day, I made a written complaint to the Ilaqa

Magistrate and to S.P. City (as S.S.P. was away to America).
The learned Magistrate forwarded my application to S.H.O.
P.S. Gulgasht with the following instructions.

”S.H.O. is ordered to treat this application in

accordance with law and submit his progress report
within tow days positively.”

S.P. City also forwarded this application with the direction to

inquire and take legal action. Both these applications were
handed over to S.H.O. Gulgasht who advised me not to get a
case registered and assured me that possession of the house
shall be restored to me within a day.

Both these applications are attached herewith as Annex “A &

A/1” and copy of arbitration award as Annex “B”.

3. That just half an hour of the delivery of this application, the

accused persons received through respondent No. 2 a photo-
state copy of the application and they immediately removed
all drums of adulterated mobil oil along-with counter feit/fake
printed tins and also removed spots of mobil oil on the floor
of the house by washing it with surf and soda ash.

4. That thereafter, S.H.O. P.S. Gulgasht has been making further

promises for restoring me the possession of the house, but he
did never do the needful on the pretext of his being busy in
some important cases and then in Moharram Duty.
5. That Malik Ilyas respondent No. 1 is son in law and Khadim
Hussain respondent No. 2 is brother in law of Muhammad
Akram respondent No. 3. Respondent No. 1 & 2 give shelter
to the three accused in their illegal acts.

6. That accused No. 4 & 5 are well built and Ghunda Type who
threatened me with a Danda in his hand that they would kill
me in case I further pursue the application.

7. That in these circumstances, I understand that S.H.O.

Gulgasht under the strong influence of respondent No. 1 & 2,
have compelled me not to get a criminal case registered and
promised me for restoration of possession, but by his
subsequent conduct, it is evident that his such promise was
fake and only to give undue benefit to respondents and not to
give any relief to me.

8. That respondents No. 1 & 2 are guilty of constant interference

in the functioning of significant institution of law
enforcement. Such irresponsible conduct and abuse of powers
on the part of police officials has resulted in the lack of public
faith in this most important organ of the state rendering me to
be in a state of fear-fullness and dis-trustfullness. I understand
that all this malpractice is due to lack of accountability and
rule of law which is extremely injurious to social justice.

9. That S.H.O. P.S. Gulgahst was legally bound to register the

case against the accused persons without fear or favour but he
shirked his legal obligations under the unwanted influence of
his colleague police officials. As such, I am left feeling
cheated and exploited by the Executive organ of the state
whose foremost duty is to perform the security functions by
bringing the criminals to justice. But instead they have
ventured to violate the law of the land and have threatened the
public peace and order.
10. Sir, I have a genuine right to demand speedy and inexpensive
justice. I need assurance that human rights as guaranteed in
the Constitution of Pakistan are to be held sacred.

Prayer for suitable action.

I also seek relief for restoration of my possession
of my partitioned property as promised by the S.H.O.
Police Station Gulgahst, Multan.

Yours truly,

Zafar Iqbal Khan,

Advocate High Court,
Complainant,
R/o St # 8, Usmanabad
Colony, Multan.
Ph # 523471

Copy forwarded for information and necessary action: -

1. The Governor of Punjab, Lahore.
2. Inspector General of Police, Punjab, Lahore.