CNSA Forfeiture of Property Application

IN THE LEARNED CONTROL OF NARCOTIC SUBSTANCES SPECIAL COURT, district

Forfeiture Application No. application_number Date filed: filing_date

Applicant: The State of Pakistan through Federal Narcotics Control Board / investigating_agency Against: respondent_name son/daughter of respondent_father, resident of respondent_address

APPLICATION FOR FORFEITURE OF PROPERTY UNDER SECTION 21, CONTROL OF NARCOTIC SUBSTANCES ACT 1997

1. This application is filed for forfeiture of property derived from or used in commission of narcotic drug trafficking offences, pursuant to Section 21 of the Control of Narcotic Substances Act 1997.

2. That respondent_name is accused of offence_description, in contravention of Sections relevant_cnsa_sections of the Control of Narcotic Substances Act 1997.

3. That investigations conducted by investigating_agency have established that respondent_name engaged in drug_trafficking_activity, resulting in the recovery of contraband_description.

4. That the property sought to be forfeited comprises: forfeitable_property_details, with estimated value of property_value_pkr Pakistani Rupees.

5. That the aforesaid property was directly derived from proceeds of drug trafficking, or alternatively, was knowingly used as an instrumentality in the commission of narcotics offences.

6. That upon arrest of respondent_name, the following items were recovered from recovery_location: items_recovered, bearing specific recovery reference numbers and dates as per seizure memo dated seizure_memo_date.

7. That forensic and chemical analysis of seized substances confirmed presence of substance_type with quantity substance_quantity, establishing clear nexus to drug trafficking.

8. That respondent_name has admitted involvement in admitted_conduct, providing clear admissions of knowledge and control over the forfeitable property.

9. That Section 21 of CNSA 1997 grants this Honourable Court plenary authority to order forfeiture of property_category derived from drug trafficking or used as instrumentalities in commission of narcotic offences.

10. That no innocent person has asserted any legal claim over the property, and full ownership rights are vested in respondent_name alone.

11. That the proceeds or value of such forfeiture shall be credited to the Consolidated Fund of Pakistan, in accordance with statutory mandate.

PRAYER

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

(a) Allow this application and order forfeiture of the following property to the Federal Government:

detailed_forfeiture_list

(b) Direct that the forfeited property be transferred to the Control of Narcotic Substances Board or such other authority as this Court deems appropriate;

(c) Order that proceeds from sale of forfeited property be credited to the Consolidated Fund in accordance with Section 21 CNSA 1997; and

(d) Grant such other and further relief as this Honourable Court may deem just and proper in the circumstances of the case.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that I have personally perused the case file, seizure memos, and investigation reports, and the contents of the above application are true and correct to the best of my knowledge and belief.

_____________________________ applicant_name applicant_designation applicant_organization Date: ______________ Through: _____________________________ counsel_name Advocate for the Applicant