In The court of Additional Session Judge Chunian district Kasur.

In Re:- Muhammad Khalid son of Muhammad Is-haq, khokhar by cast Resident of Kot Rao Nazir, Changa Manga.

Vs 1:Rasoolan bibi wife of Hadayet alias Manzoor Ahmad , resident of Hinger-wall, Chack 31 Tehsil Pattoki P.S.Changa Managa. 2:Hadayet alias Manzoor Ahmad , resident of Hingerwall, Chack 31 Tehsil Pattoki P.S.Changa Manga. 3:S.H.O Police Station Changa Manga.

Petition under section 491 Cr.P.C for issuing a writ of Habeas corpus for securing the recovery of person of Mrs Shazia wife of the petitioner from the improper detention of respondent no 1 & 2.

The petitioner respectfully submits as follows.

1:-

That the petitioner was married to Mst Shazia (hereinafter referred to as detenue ) daughter of respondent 1 & 2 on 24-07-2011at the home of respondent no 1 & 2 according to Islamic rites. After the marriage the detenue started living with the petitioner. The detenue is pregnant.

2:-

That the respondent 1 & 2 visited the house of petitioner a day before the last Eid and asked him to let her accompany them for celebrating the Eid festival at their home. As the petitioner could not possibly have any objection to the said proposal, the detinue left for the house of her parents and since then she is with them.

3:-

That on September 11, 2011 the petitioner visited the house of his in-laws for inquiring about the health of his wife, on account of her pregnancy. Respondent no 1 & 2, not only refused to allow the petitioner to see his wife but also held out threats that they were intending to arrange for abortion of the pregnancy of his wife because the wedlock between the petitioner and the detinue has turned something most unwelcomed for them. And further

that it was their intention to sell away the detinue to a wealthy person of their choosing. From the above narration, it is clear that the detinue is being wrongfully, improperly and illegally detained by respondents, against her free-will, with the object of selling her away like the chattel and further that they have intention of inducing abortion of her pregnancy, which design is most result endanger her life. The detinue is thus being illegally, improperly and wrongfully detained, against her free will, by her parents. Since the detinue is lawfully married to the petitioner, he is very much entitled to secure her release from the illegal and improper detention of her parents. likely going to

For

what

have

been

submitted

above, it is very respectfully prayed that by issuing a writ of habeas corpus, either the bailiff of this honorable court ordered to secure release of the person of the detinue from the wrongful detention of respondent no 1 & 2 or respondent no 3 be ordered to do the same and in consequence whereof the person of the detenue may be ordered to be produced before the honorable

court for her being set free and to join the petitioner.

PETITIONER

Muhammad

Khalid

son

of

Muhammad Is-haq, khokhar by cast Resident of Kot Rao Nazir, Changa Manga

Through Counsel. MIAN ARSHID FAROOQ. Advocate High Courts Lahore.

In The Court of Additional Session Judge Pattoki District Kasur.

In Re:

Muhammad Khaild

Vs

Rasoolan bibi etc.

AFFIDAVIT OF:

Muhammad Khalid son of Muhammad Is-haq,

khokhar by cast Resident of Kot Rao Nazir, Changa Manga.

I, THE ABOVE NAMED DEPONENT DO HEREBY SOLEMENLY AFFIRM AND DECLARE AS UNDER:1:- That Habeas petition has been moved in this honorable court, this affidavit may very kindly be treated as a part of the bail petition. 2:- That the contents of the petition are based on truth to the best of my knowledge and belief.
DEPONENT VERIFICATION:VERIFIED ON OATH ON 13-09-2011 AT CHUNIAN, THE CONTENTS OF AFFIDVIT ARE TURE AND CORRECT TO BEST OF MY KNOWLEDGE AND BELIEF

DEPONENT