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APPLICATION UNDER s.

249A CrPC FOR ACQUITTAL OF THE ACCUSED PERSON

IN THE COURT OF MR. ______, LEARNED JUDICIAL MAGISTRATE 1ST CLASS, LAHORE.
In Re:
STATE VERSUS _____
.
.
FIR NO : ____
UNDER SECTIONS :______
DATED : _____
POLICE STATION :____
DISTRICT :_____
.
.
APPLICATION UNDER SECTION 249-A Cr.P.C. FOR ACQUITTAL OF THE APPLICANT/ ACCUSED
PERSON.
Respectfully Sheweth:
1. That the titled criminal case is pending for adjudication before this Learned Court for today i.e. 29.05.2014.
2. That the complainant/respondent got registered FIR against the applicant/accused person under Sections 406
& 506 PPC, wherein, it has been alleged by the complainant that his wife and her sister and brother entered
into an agreement to sell of House No. ____ _________, Lahore with one Mr. ______ for a total consideration
of Rs. 51,50,000/- and an amount of Rs.20,00,000/- was paid by the vendee through cheques and the cheques
were entrusted to the applicant. Moreover, it has been alleged by the complainant that the amount was
withdrawn by the applicant and the amount was misappropriated.
3. That the applicant humbly seeks indulgence of this Learned Court for his acquittal in titled complaint inter-
alia on the following:
GROUNDS
i. That a bare perusal of the FIR would reveal that no offence whatsoever has been committed by the applicant.
ii. That the FIR discloses liability of civil nature, if any, therefore, invoking jurisdiction of criminal courts
amounts to abuse the process of law.
iii. That if material available on the record is brought in the evidence, there is no probability of conviction of
the applicant on the basis of that record, therefore, it is in the interest of justice that the applicant may be
acquitted at this stage.
iv. That the applicant has been involved in this case falsely and he has nothing to do with the commission of
alleged offence.
v. That there is nothing available on record against the applicant.
vi. That the charge/accusation against the applicant is goundless, therefore, commencement of trial would not
serve ends of justice.
vii. That in the wider interest of justice and to nip the evil in the bud, it is necessary that the applicant may be
acquitted before any further step taken in continuation of the trial.
viii. That the complainant has no locus standi to file titled complaint.
ix. That the applicant humbly seeks indulgence of this Honourable Court for raising additional grounds at the
stage of arguments.
PRAYER
In aforementioned circumstances, it is humbly prayed from this Honourable Court that instant application may
kindly be accepted and the applicant may be acquitted.
APPLICANT
Through
Zeeshan Ahmad Malik
Advocate High Court