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BEFORE THE SPECIAL JUDGE BANKING COURT II, LAHORE.

Liaqat Ali son of Muhammad Yasin R/o 1st Floor, Mustafa Plaza, 6/A Fane
Road, Lahore.
…PETITIONER

VERSUS.

1) Farrukh Naeem, Manager (Operation) Bank Al-Falah Ltd.


Regional Headquarter, 30-Baber Block, New Garden Town,
Lahore.
2) M Shafique, Assistant Manager (Operation) Bank Al-Falah Ltd.
Regional Headquarter, 30-Baber Block, New Garden Town,
Lahore.

…RESPONDENTS

CONTEMPT PETITION U/S 39, Rule 2 (3) Read with Section


151 CPC and Section 3, 4 of Contempt
of Court Act.

Respectfully Sheweth:-

1. That the petitioner filed a suit u/s 9 of Financial Institution

(Recovery of Finance) Ordinance, 2001 for declaration, permanent

injunction and rendition of accounts.

2. That on 11-05-2011 in which interim relief was granted by this

honable court with direction “the respondent is restrained to

repossess the vehicle in question bearing registration No. LWP

4929 and shall not adopt coercive measures against the

petitioner as well as file fresh statement of account.” (Certified

copy of the order is Annex)

3. That by the instigation of respondent No 1 the respondent No 2

before filling the suit was also with abusive language at the door of

the house of the applicant.


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4. That the petitioner has not alternate except to file a suit against the

respondent / defendant No 1 for obtaining the legal assistance and

shelter for this honable court.So, the petitioner filed a suit

alongwith stay application in which stay has been granted by this

Hon’ble court in favour of the plaintiff/petitioner against the

respondent No 1.

5. That on 26-04-2011 at about 11:00 am by the instigation of the

respondent No.1 the respondent No.2 along with some Gundas

elements came to the house of the petitioner in his absence and

started shouting with abusive language in very bad manner, on

which the respondent No. 2 was informed that the petitioner /

plaintiff had got a stay order from this honable court by the ladies

but the respondent No. 2 said it is a ficticious stay because they

had no notice from the bank.he is only bound to the intervention of

the bank not to the court. He further stated that he is earning and

getting salary from the bank for his “BADMASHI”. He had no

concern with any court and they have also thousands of advocates

which are in our panel and fighting for us and the bank is paying

them for this purpose

6. That by the instigation of the respondent No.1 the respondent No 2

again came to the house of the petitioner at about 1:00 pm in the

absence of the petitioner and use abusive language to the house

hold ladies and threatened with dire consequences that if they will

not deposit the amount within a day then they will not responsible

for their any act otherwise, the life of the petitioner will be in

severe danger . They went away by threatening the due to

intervening the respectables of the localities.

7. That the act and the behaviour of the respondent No.1 and 2 for not

obeying the order dated 23-04-2011 by this honable court is very

contemptuous and they loyal the honor and dignity of this honable

court in the eyes of public at large by denying the order of this


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honable court so the respondent are liable to be dealt with

contempt of court and punished in accordance with law

PRAYER

It is therefore, most respectfully prayed that the respondents

may please be summoned in person and contempt petition be tried in the

criminal proceedings and he may please be directed to appear in person on

each date of hearing and further due to their contemptuous attitude they

may please be awarded maximum punishment and their salaries may also

be attached.

PETITIONER

Through

(Chaudhry Muhammad Ajmal)


Advocate High Court
Suite No.3 Ist floor, Al-Qadar Centre
1-Mozang Road, Lahore.
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BEFORE THE Hon’ble SPECIAL JUDGE BANKING COURT NO.II,


LAHORE.

In re:

Liaqat Ali VERSUS. Farukh Naeem etc.

(CONTEMPT PETITION U/S 39, Rule 2 (3) Read with Section 151 CPC and
Section 3, 4 of Contempt of Court Act.
.)

AFFIDAVIT OF Liaqat Ali son of Muhammad Yasin R/o 1st Floor,


Mustafa Plaza, 6/A Fane Road, Lahore.

I, the above named deponent do hereby solemnly affirm and declare as


under:-

That the contents of accompanying application are correct and

true to the best of my knowledge and belief and nothing has been concealed or

mis stated thereof.

DEPONENT.
VERIFICATION.

Verified on oath at Lahore on this …… day of April. 2011 that the contents of the
above affidavit are correct and true to the best of my knowledge and belief and
nothing has been kept concealed or mis-stated therein.

DEPONENT.