Appeal against CNSA 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

The State and complainant_name, son/daughter of complainant_father, resident of complainant_address ... Respondents

APPEAL AGAINST CONVICTION AND SENTENCE BY CNSA COURT DATED conviction_date

Respectfully sheweth:

1. That the Appellant was tried in the CNSA Court, district under cnsa_sections in FIR No. fir_number/fir_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 is annexed as Annexure 'A'.

4. That the Appellant is aggrieved by the conviction and sentence and files the present appeal under Section 48 CNSA 1997 within 30 days of conviction.

5. That grounds_of_appeal.

6. That the prosecution case rested entirely on key_evidence, which is circumstantial, weak, and insufficient to prove guilt beyond reasonable doubt.

7. That chain_of_custody_issues. The alleged narcotics recovered cannot be linked to the Appellant with certainty.

8. That the CNSA Court gravely erred in court_error.

9. That the defence evidence was defence_evaluation by the trial court.

10. That the sentence imposed is sentence_characterization and wholly disproportionate to any misconduct.

That the impugned order suffers from material illegality, irregularity, and is contrary to the record. The findings of the learned forum below are perverse, contrary to evidence, and are not sustainable in fact or in law.

That the present appeal is filed within the prescribed period of limitation computed from the date of communication of the impugned order to the Appellant. The certified copy of the impugned order has been duly obtained and is annexed.

That the Appellant has not previously preferred any appeal, revision, or review against the same impugned order before any other forum, and is approaching this Honourable Court with clean hands.

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 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