Complaint of Corrupt Practice

TO THE CHIEF ELECTION COMMISSIONER ELECTION COMMISSION OF PAKISTAN ISLAMABAD

COMPLAINT OF CORRUPT PRACTICE Constituency: constituency_name Election: election_type election_date

COMPLAINT OF CORRUPT PRACTICE UNDER SECTION 167 OF THE ELECTIONS ACT 2017

Complainant: complainant_name, complainant_address Candidate Against Whom Complaint Is Filed: candidate_name Party: party_name Constituency: constituency_name

VERSUS

1. The complainant hereby submits this formal complaint to the Election Commission of Pakistan alleging that candidate_name, a candidate in the election_type held on election_date for constituency_name, has engaged in corrupt practices in violation of Section 167 read with Sections 168 and 169 of the Elections Act 2017.

PRAYER

2. The candidate has offered monetary inducements to eligible voters in constituency_name to secure their votes. Multiple credible witnesses have attested to the fact that the candidate or representatives acting on the candidate's behalf distributed cash sums of between PKR bribery_amount_min to PKR bribery_amount_max to voters in exchange for their votes. These acts constitute bribery under Section 168(1)(a) of the Elections Act 2017.

3. The candidate has used threats and intimidation to coerce voters into casting votes in the candidate's favour. In particular:

4. (a) The candidate threatened that votervoters_mention would be deprived of government assistance programs if they did not vote for the candidate.

5. (b) The candidate made public statements that those who voted against the candidate would be subject to legal prosecution on fabricated charges.

6. (c) The candidate's supporters physically intimidated minority voters at polling stations.

7. These acts constitute undue influence under Section 168(1)(b) of the Elections Act 2017.

8. The candidate's campaign workers engaged in personation by impersonating eligible voters and casting votes in their names. Evidence of forged voter lists and unauthorized ballot papers has been preserved and is available for inspection.

9. The candidate has made false statements of fact in campaign materials and public speeches with the intent to secure votes:

10. (a) The candidate falsely claimed to have obtained a medical degree from a foreign university, whereas the candidate's actual educational qualifications fall short of this claim.

11. (b) The candidate falsely stated that the candidate had contributed PKR false_contribution to public welfare projects, whereas no such contribution has been made.

12. (c) The candidate made false promises regarding development projects that are factually impossible given budget constraints and technical feasibility.

13. The candidate deliberately employed religious and sectarian language to divide voters and incite communal tension. Specifically, the candidate made statements that sought to delegitimize opposition candidates by falsely attributing to them views contrary to Islamic principles. Recorded instances of such statements are attached hereto.

14. The complainant has secured statements from witness_count independent witnesses, including election observers, media personnel, and members of the general public, who are prepared to testify before the Election Commission regarding the corrupt practices described above. Affidavits from these witnesses are attached hereto as Annexures.

15. The complainant has preserved photographic and video evidence of vote-buying incidents, campaign rallies where inflammatory rhetoric was used, and copies of campaign materials bearing false claims. All such evidence is available for inspection.

16. These corrupt practices have compromised the fairness and credibility of the electoral process in constituency_name. The result of the election should not be permitted to stand if obtained through these unlawful means.

WHEREFORE, the complainant respectfully prays that the Election Commission of Pakistan may be pleased to: (a) Take cognizance of the corrupt practices alleged herein; (b) Conduct a full and impartial investigation into the allegations; (c) Disqualify candidate_name from contesting elections for a period of proposed_disqualification_years years as provided under Section 169 of the Elections Act 2017; (d) Declare the election result in constituency_name null and void and order a fresh election; (e) Pass such further orders as the Election Commission may deem fit and proper in the circumstances of the case.

VERIFICATION

I, complainant_name, do hereby solemnly declare that the contents of the above complaint are true and correct to the best of my knowledge, information, and belief. I make this solemn declaration conscientiously believing the same to be true and by virtue of the Statutory Declarations Ordinance, 1960.

Signed: ___________________ Name: complainant_name Date: filing_date Place: filing_place Phone: complainant_phone