Appeal against Accountability Court Conviction

IN THE HIGH COURT OF jurisdiction, division

Appeal No. _____ of year

appellant_name, son/daughter of appellant_father, resident of appellant_address, holding CNIC No. appellant_cnic ... Appellant

VERSUS

1. The State, through the Prosecutor, National Accountability Bureau 2. complainant_name, son/daughter of complainant_father, resident of complainant_address ... Respondents

APPEAL AGAINST CONVICTION AND SENTENCE BY ACCOUNTABILITY COURT DATED conviction_date

Respectfully sheweth:

1. That the Appellant was tried before the Accountability Court, district under nab_sections in NAB Inquiry No. inquiry_number, Case FIR No. case_fir_number/case_year and was convicted on conviction_date by learned trial_judge_title trial_judge_name.

2. That the Appellant was sentenced to sentence_description and directed to pay fine_amount as fine.

3. That the Appellant obtained a certified copy of the impugned judgment dated conviction_date. A copy of the impugned judgment is annexed as Annexure 'A'.

4. That the Appellant is aggrieved by the conviction and sentence and files the present appeal under Section 32 NAB Ordinance 1999 on the following grounds:

grounds_of_appeal

5. That the Accountability Court gravely erred in convicting the Appellant on key_evidence which is circumstantial, weak, and insufficient to establish guilt beyond reasonable doubt.

6. That procedural_errors. These procedural irregularities have violated the Appellant's right to fair trial.

7. That the prosecution evidence consisted solely of witness_characterization, which contained evidence_defects.

8. That the defence evidence was either wholly ignored or gravely misappreciated by the Accountability Court, thereby violating the fundamental principle of just appreciation of evidence.

9. That misapplication_of_law.

10. That the sentence imposed is sentence_characterization and is therefore excessive and wholly disproportionate to the gravity of the alleged misconduct.

LIMITATION: The present appeal is filed within the period of limitation prescribed by the parent statute, computed from the date of communication of the impugned order to the appellant. The certified copy of the impugned order has been obtained and is annexed.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:

(a) Allow the present appeal and set aside the conviction of the Appellant recorded on conviction_date;

(b) Acquit the Appellant of all charges levelled against him/her;

(c) In the alternative, reduce the sentence imposed to alternative_sentence;

(d) Suspend the sentence pending disposal of this appeal; and

(e) Grant such further and other relief deemed just and proper in the circumstances.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of paragraphs 1 to 10 of the above appeal are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ appellant_name Appellant Through: _____________________________ counsel_name Advocate