Quashment of FIR (Section 561-A CrPC)

IN THE HIGH COURT OF jurisdiction, district

Criminal Petition No. _____ of year

petitioner_name, son/daughter of petitioner_father, resident of petitioner_address, holding CNIC No. petitioner_cnic ... Petitioner

VERSUS

1. complainant_name, son/daughter of complainant_father, resident of complainant_address 2. The State, through Inspector General of Police, district 3. The Investigating Officer, Police Station police_station, district ... Respondents

PETITION UNDER SECTION 561-A OF THE CODE OF CRIMINAL PROCEDURE 1898 FOR QUASHMENT OF FIR

Respectfully sheweth:

1. That this Honourable Court is seised of the inherent jurisdiction under Section 561-A CrPC to quash any FIR, proceedings, or conviction which lacks prima facie evidence of commission of the offence or where the proceedings are malicious, vexatious, or an abuse of the process of the Court.

2. That FIR No. fir_number dated fir_date was registered at Police Station police_station, district against the Petitioner under penal_section of the Penal Code 1860. A copy of the FIR is annexed as Annexure 'A'.

3. That the allegations contained in the FIR do not, upon their face, disclose the commission of any cognizable offence. The facts alleged are either wholly insufficiently detailed or are civil in nature.

4. That specific_grounds and therefore no offence is made out from the contents of the FIR.

5. That the Respondent No. 1 has filed the present FIR with manifest mala fide intent and ulterior motives to harass and wrongfully persecute the Petitioner. The complaint is motivated by personal animosity or commercial rivalry.

6. That civil_dispute_details This matter is essentially civil in nature and ought not to have been presented as a criminal offence. The police and investigating agencies have no jurisdiction to entertain the same.

7. That the registration of the FIR and the consequent investigation constitute a clear abuse of the process of the Court and will cause irreparable injury to the Petitioner's reputation, business, and livelihood if allowed to proceed.

8. That this Honourable Court has repeatedly exercised its inherent jurisdiction under Section 561-A CrPC to quash FIRs which are manifestly vexatious, oppressive, or which do not disclose the commission of any cognizable offence.

PRAYER

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

(a) Invoke its inherent jurisdiction under Section 561-A CrPC and quash FIR No. fir_number dated fir_date registered at Police Station police_station, district;

(b) Restrain the Investigating Officer from proceeding further in the investigation of the aforesaid FIR; and

(c) Grant such further and other relief deemed just and proper in the circumstances of the case.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of paragraphs 1 to 8 of the above petition are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ petitioner_name Petitioner Through: _____________________________ counsel_name Advocate