To:

The Station House Officer (S.H.O)
Police Station (Area)
Lahore

Subject: Request for Lodging an FIR against Mr. _______________ and Mr. _______________ for Illegal Dispossession, Criminal Trespass, Theft, Criminal Intimidation, and Violation of Court Stay Order

Ref No: __________
Date:  20-April-2025

Sir,

I, ____________________, a law-abiding citizen and rightful co-owner of the disputed property situated at ________________________, most respectfully submit that I have been residing in the said property for the last 20 years. The property was jointly purchased in the year 2002 by my sisters on my behalf while I was residing abroad. I solely financed the entire purchase and construction of the house and have maintained peaceful possession of a portion of the said property since then.

Due to the persistent misbehavior, harassment, and threats from the accused persons—Mr. _______________ and Mr. _______________, I was compelled to file Civil Suit No. _____________ before the Honorable Civil Court for the partition of the property. The court, after hearing the matter, graciously passed a status quo / stay order, restraining both parties from altering the possession of the property until the next hearing scheduled for ______________, before the Court of Mr. _____________, Civil Judge, Lahore.

However, in willful defiance of the said court order, on [Date], during my absence from Lahore with my family, the above-named accused unlawfully entered my portion of the house. As per information obtained from neighbors, they broke the locks of the portion under my possession, illegally trespassed, and are suspected to have stolen gold ornaments and valuable documents, including imported items, with an estimated value of Rs. 3 crore.

Upon return, my family found the main door locked from the inside. When they attempted to access the premises, the accused physically assaulted my innocent son and daughter. Consequently, my son made an emergency call to 15 at approximately 6:00 PM on [Date].

On [Date], when I personally returned and attempted to enter the premises to recover my belongings, the accused again attacked me, physically restrained me, and deprived me of access to both moveable and immovable property, despite the valid stay order issued by the honorable court.

This blatant violation of court orders, criminal trespass, theft, and intimidation by the accused individuals is a matter of grave concern and injustice. It not only undermines the rule of law but also endangers the safety of me and my family.

Therefore, it is my humble request that an FIR be immediately registered against Mr. _______________ and Mr. _______________ under the following legal provisions:

1. Section 3 of the Illegal Dispossession Act, 2005 – For unlawful dispossession from property;

2. Section 441 of the Pakistan Penal Code (PPC) – For criminal trespass;

3. Section 379 PPC – For theft of gold ornaments, valuables, and documents worth Rs. 3 crore;

4. Section 506 PPC – For criminal intimidation and issuing threats to life and property;

5. Section 188 PPC – For disobedience to an order duly promulgated by a public servant (i.e., court stay order).

I also request that necessary action be taken to:

• Recover the possession of the property which was unlawfully occupied;

• Recover the stolen items;

• Provide protection to me and my family, as we are facing constant threats;

• Prevent further escalation of violence or damage.

If any harm comes to me or my family, I hold my brother-in-law Mr. _______________ solely responsible for the consequences.

Attached Documents:

1. Copy of the court stay order;

2. Copies of monthly paid utility bills of the property (proof of possession);

3. Copy of the local commission’s inspection/report.

I trust in the efficiency and justice of the Punjab Police and hope for swift and lawful action in this matter.

Yours sincerely,
[Your Full Name]
CNIC No: ___________________
Contact: ____________________
Address: ____________________