IN THE COURT OF                              JUDICIAL MAGISTRATE, LAHORE

In re:

The State          VS    __________.

APPLICATION UNDER SECTION 249-A Cr.P.C. FOR THE ACQUITTAL OF THE PETITIONER

Respectfully Sheweth:-

1. That the complainant/respondent got registered FIR against the petitioner/accused person under Sections _____ PPC,

2. That the present petitioner are the accused in the above titled case and facing the hardship of the case since for the last more than two years without commission of any offence.

3. That the titled case is false, frivolous, baseless, concocted and was registered by the complainant/respondent with the specific malafide against the petitioner/accused.

4. That no incriminating article was recovered from the petitioner/accused.

5. That no specific role has been attributed to the petitioner/accused.

6. That after couple of years the prosecution could not produce the evidence and the petitioner/accused is facing the hardship of the trial by appearing on each and every date without any progress.

7. That the prosecution has badly failed to prove the case against the petitioner/accused.

8. That there is no material on the file which could be sufficient for the conviction of the petitioner/accused.

9. That even from the contents of the challan, it is crystal clear that the allegation against the petitioner/accused is absolutely baseless and charge against him is groundless.

10. That there are two ingredients of U/s 249-A Cr.P.C one is when the charge has become groundless and the second when there is no probability of conviction of accused and in the instant matter both the ingredients are existing, hence the instant prosecution case is not proceedable in the light of section 249-A Cr.P.C.

11. That in view of above, further proceedings in the matter in hand would be a futile exercise and would only amount to wastage of precious time of this Honourable Court.

12. That petitioner is facing the agony of trial and there is no chance of conviction of the petitioner/accused.

13. That if the application is not accepted the petitioner/accused will suffer an irreparable loss

PRAYER

Under the aforementioned circumstances it is most respectfully prayed that the titled petition may please be accepted and the petitioner/accused may kindly be acquitted in this case under section 249-A Cr.P.C.

Note: This is the first application which is ever moved before this Honorable court.

Petitioner

Through

Advocate High Court

Dated: 00.00.202