Transfer Application of Accountability Case

IN THE HONOURABLE HIGH COURT OF province AT seat

PETITION UNDER SECTION 32-A NAO 1999 FOR TRANSFER OF ACCOUNTABILITY REFERENCE

applicant_name, son of applicant_father, CNIC No. applicant_cnic, resident of applicant_address Applicant Versus The Accountability Judge, original_court_location, and The National Accountability Bureau, Islamabad Respondents

The applicant respectfully submits this petition for transfer of Reference No. reference_number pending before the Accountability Court, original_court_location, to an Accountability Court at requested_court_location or any other court as deemed fit by the Honourable Court.

The applicant is the accused in the above reference. The reference was lodged on reference_date and has been pending determination since pending_period. The applicant apprehends that the continuation of trial at original_court_location would result in grave prejudice and denial of fair trial rights.

Ground 1: Apprehension of Bias. The Accountability Judge at original_court_location is manifestly prejudiced against the applicant. Multiple instances of bias_evidence demonstrate judicial bias. The Judge has specific_bias_instance.

Ground 2: Security and Public Safety. The applicant and his family members have received threat_description and attack_details. The law and order situation at original_court_location is security_assessment. Transfer to requested_court_location would ensure fair trial and personal security.

Ground 3: Judicial Convenience and Expeditious Trial. Transfer of the reference to requested_court_location would result in expeditious disposal of the case. The original court is over-burdened with pending pending_cases_count cases, causing inordinate delay. The requested court has adequate capacity and expertise.

Ground 4: Impartiality and Public Confidence. The transfer would be in the larger interest of justice and would restore public confidence in the dispensation of justice. The applicant and the prosecution shall have equal access to documentary and oral evidence at the requested location.

The applicant submits that Section 32-A of the National Accountability Ordinance 1999 empowers the High Court to transfer any pending reference in the interest of justice. All grounds required for exercise of this discretion are satisfied in the present case.

IN THE RESULT, the applicant respectfully prays that this Honourable Court be pleased to: 1. Grant this petition and allow the transfer of Reference No. reference_number from the Accountability Court, original_court_location, to the Accountability Court, requested_court_location; 2. Direct the Accountability Court, requested_court_location, to take cognizance of the transferred reference and continue trial; 3. Direct the Accountability Court, original_court_location, to transmit the entire case file to the requested_court_location; 4. Such other order as this Honourable Court may deem just and proper. And for such other relief as may be granted.

PRAYER

In view of the foregoing, the Applicant / Petitioner / Complainant most respectfully prays that the Honourable Authority may be pleased to:

(a) Allow the present transfer application and direct that the case bearing reference case_reference be transferred from the Accountability Court at from_court to the Accountability Court at to_court;

(b) Direct that all the records of the case be transmitted to the receiving Accountability Court within such time as this Honourable Court may specify;

(c) Direct that the proceedings continue before the receiving Accountability Court from the stage at which the transfer takes place;

(d) Award costs of the application to the Applicant; and

(e) Pass any other order that this Honourable Court may consider just, fit, and proper.

applicant_counsel_name Advocate for Applicant Enrolled on Roll No. advocate_roll_no Issue dated: filing_date