Writ Petition for Mandamus (FIR Registration)

IN THE HONOURABLE HIGH COURT OF province AT seat WRIT PETITION NO. _____ OF year Under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973

Writ Petition No. _____ of year

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

VERSUS

respondent_name, Station House Officer, police_station, and THE STATE ... Respondents

WRIT PETITION FOR MANDAMUS

The Petitioner respectfully submits:

1. That this petition is filed under Article 199(1)(a)(i) of the Constitution seeking a Writ of Mandamus to direct the Respondent to register a First Information Report (FIR) in respect of the complaint made by the Petitioner.

2. That on complaint_date, the Petitioner submitted a written complaint to the police_station describing the facts and circumstances of an alleged offence.

3. complaint_details

4. That the alleged facts constitute an offence under relevant_sections of the Pakistan Penal Code.

5. That despite the said complaint, the Respondent has refused or failed to register an FIR, thereby violating the Petitioner's fundamental right to access justice.

6. That denial_reasons.

7. That the Respondent has acted in violation of Section 154 of the Code of Criminal Procedure 1898 and the settled position of law that the Police are mandated to register an FIR where a cognizable offence is disclosed.

8. That the Petitioner has no other adequate remedy available, and a Writ of Mandamus is the only recourse.

9. That this Honourable Court has jurisdiction under Article 199 to issue the writ.

PRAYER

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

(a) Issue a Writ of Mandamus directing the Respondent to register an FIR on the basis of the Petitioner's complaint;

(b) Direct the Respondent to conduct a proper investigation into the alleged offence;

(c) Declare that the refusal to register the FIR is unlawful and without authority; and

(d) Pass such other order as may be deemed just and proper.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that the contents of the above petition are true and correct to the best of my knowledge and belief.

_____________________________ petitioner_name Petitioner Date: ______________ Through: _____________________________ counsel_name Advocate for the Petitioner