IN THE LAHORE HIGH COURT, LAHORE
Constitutional Jurisdiction

W.P. No. ______ of 20____

Mst. ____________ wife of ____________, Resident of House No. ______, Street No. ______, ______________ Lahore Cantt.
 …Petitioner

Versus

1. Senior Superintendent of Police, ____________.

2. Senior Superintendent of Police, District ____________.

3. Superintendent of Police, Tehsil ____________, District ____________.

4. Station House Officer, Police Station ____________, Tehsil ____________, District ____________.

      …Respondents

PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF PAKISTAN, 1973

Respectfully Submitted:

Brief Background

1. That the petitioner is a widow aged about ___ years and is a respectable citizen of the Islamic Republic of Pakistan. She is presently residing at ____________ along with her family.

2. That a son of the petitioner, namely ____________, is allegedly a fugitive of law and is wanted by the ____________ Police in several criminal cases including that of murder.

3. That in search of the petitioner’s son, the police of ____________ has been consistently raiding the house of the petitioner and harassing and humiliating her and her family members. It is pertinent to mention that the petitioner has had no contact with her said son for several years and had even publicly proclaimed this fact through a newspaper publication.

4. That the petitioner has repeatedly approached the higher police authorities of District ____________ against this unlawful and humiliating conduct of respondent No. 4, but to no avail.

5. That the actions of respondent No. 4 (hereinafter referred to as the impugned actions) are illegal, arbitrary, and without lawful authority, on the following among other:

GROUNDS

I. That the impugned action is against the facts of the case and contrary to the applicable law.

II. That the conduct of respondent No. 4 is violative of the principles of justice, equity, and good conscience and is therefore bad in law.

III. That despite the petitioner being a widow having no connection whatsoever with her fugitive son, respondent No. 4 continues to harass and humiliate her. The impugned action is arbitrary, oppressive, and unjust.

IV. That the conduct of respondent No. 4 is mala fide, abominable, and contrary to law. Respondent No. 4, along with other police officials, has been harassing the entire family of the petitioner, including her daughters, without any lawful justification.

V. That the impugned action of the respondents violates the fundamental rights of the petitioner guaranteed under Articles 4, 9, 14, and 25 of the Constitution of the Islamic Republic of Pakistan, 1973, including the right to life, liberty, dignity, and equal protection of law.

VI. That it is a settled principle that public authorities can exercise only such powers as have been lawfully conferred upon them and cannot act whimsically or beyond their jurisdiction. The actions of respondent No. 4 are without lawful authority and of no legal effect.

VII. That the impugned conduct also violates Articles 2-A and 4 of the Constitution, which secure the rule of law and protection of citizens from arbitrary acts.

VIII. That the actions of respondent No. 4 offend the principles of natural justice and due process, thereby violating the fundamental rights guaranteed under Articles 4, 18, and 25 of the Constitution.

IX. That the petitioner has no other adequate or efficacious remedy except to invoke the constitutional jurisdiction of this Honourable Court under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973, as the matter involves the abuse of statutory powers by public functionaries and illegal harassment of the petitioner and her family.

PRAYER

In view of the foregoing, it is most humbly prayed that this Honourable Court may kindly be pleased to:

a) Direct the respondents not to harass, humiliate, or abuse the petitioner or her family in any manner whatsoever;

b) Declare that the impugned actions of the respondents are without lawful authority and of no legal effect; and

c) Grant any other relief deemed just and proper by this Honourable Court in the circumstances of the case.

Petitioner
Through Counsel:

_________________________
Advocate High Court
Address: ________________________________
Phone: _____________________

Drawn & Filed by:

Advocate High Court
Office: ________________________________
Lahore

Note: Certified as per instructions that this is the first petition being filed before this Honourable Court relating to the instant cause.

Advocate