Application to Unfreeze Bank Accounts

IN THE ACCOUNTABILITY COURT, district

Miscellaneous Application No. _____ of year

applicant_name, son/daughter of applicant_father, resident of applicant_address, holding CNIC No. applicant_cnic ... Applicant

VERSUS

The Director General, National Accountability Bureau, through his/her authorized representative ... Respondent

APPLICATION FOR DIRECTION TO DE-FREEZE BANK ACCOUNTS UNDER SECTION 12 NAB ORDINANCE 1999

Respectfully sheweth:

1. That the Applicant is aggrieved by the freezing of his/her bank account(s) vide NAB freezing order dated freezing_order_date, bearing reference freezing_reference_number.

2. That the following bank account(s) have been frozen: bank_account_details. The said accounts form the lifeline of the Applicant's family, containing account_contents.

3. That the freezing of accounts was made under Section 12 NAB Ordinance 1999 in NAB Inquiry No. inquiry_number, Case FIR No. case_fir_number/case_year.

4. That freezing_justification.

5. That the Applicant has been coop_status in NAB's investigations and has provided all documents and information sought by the investigation officer.

6. That the freezing order was never justified by showing how the frozen accounts form proceeds of corruption or assets acquired as a result of misconduct. Section 12 freezing is preventive in nature and must not become indefinite punishment.

7. That hardship_circumstances.

8. That reasonable access to the frozen accounts is a fundamental right guaranteed under Article 24 of the Constitution. Indefinite freezing without judicial oversight violates this right.

9. That the Applicant is willing to furnish any security or undertaking that this Honourable Court deems appropriate to ensure compliance with NAB directives.

10. That de-freezing of accounts would serve the ends of justice and cause no prejudice to NAB's investigation, as the Applicant has remained cooperative throughout.

PRAYER

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

(a) Set aside or modify the freezing order dated freezing_order_date;

(b) Direct NAB to de-freeze the bank account(s) of the Applicant forthwith, or in the alternative, allow limited access for essential household and medical expenses;

(c) Fix a reasonable timeline for NAB to conclude its investigation and restore full access to the Applicant's accounts; and

(d) 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 application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ applicant_name Applicant Through: _____________________________ counsel_name Advocate