In Pakistan, the 22A 22B petition draft plays a crucial role when the police refuse to register an FIR or fail to conduct a fair investigation. Many citizens are unaware of their legal remedy under Sections 22A and 22B of the Criminal Procedure Code (CrPC), which empowers the Justice of Peace to issue directions to the police.
This comprehensive guide explains the 22A 22B application draft, the proper 22A 22B format, legal requirements, and practical tips to ensure your petition is strong, clear, and effective.
Sections 22A and 22B of the Criminal Procedure Code provide powers to the Justice of Peace to:
Direct the police to register an FIR
Order transfer of investigation
Ensure proper investigation
Protect fundamental rights of citizens
Under Pakistani law, if a Station House Officer (SHO) refuses to register a cognizable offence, the aggrieved person can file a 22A 22B petition before the Sessions Court.
These provisions protect constitutional rights under Article 4 and Article 10A of the Constitution of Pakistan, ensuring access to justice.
You may file a 22A 22B application draft in the following situations:
Police refuse to register FIR despite a cognizable offence.
FIR is not registered after written application.
Police delay investigation intentionally.
Investigation is biased or unfair.
The SHO ignores complaints due to influence or corruption.
The petition is filed before the Additional Sessions Judge (Justice of Peace) in the relevant district.
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A properly structured 22A 22B format should include the following:
Mention the court clearly:
In the Court of Learned Additional Sessions Judge / Justice of Peace, [District Name]
Application under Sections 22A & 22B CrPC for Direction to Register FIR
Name, CNIC, address of petitioner
Name of SHO and police station
Proposed accused (optional but recommended)
Clearly state:
Date of occurrence
Nature of offence
Details of incident
Witnesses (if any)
Evidence (if available)
Mention:
Date of application to SHO
Copy attached as annexure
Police refusal or inaction
State that:
Offence is cognizable
Police are legally bound under Section 154 CrPC
Refusal is illegal and against settled law
Request the court to:
Direct SHO to register FIR
Ensure fair investigation
Grant any other relief deemed appropriate
Below is a general sample for reference purposes:
IN THE COURT OF LEARNED ADDITIONAL SESSIONS JUDGE / JUSTICE OF PEACE, [DISTRICT]
Application under Sections 22A & 22B CrPC for Registration of FIR
Respectfully Sheweth:
That the petitioner is a law-abiding citizen of Pakistan.
That on dated [mention date], the accused persons unlawfully trespassed into the petitioner’s house and caused injuries.
That the matter constitutes cognizable offences under Pakistan Penal Code.
That the petitioner approached SHO Police Station [Name] on [date], but no FIR was registered.
That refusal of police is illegal, arbitrary, and against law.
Prayer:
It is respectfully prayed that this Honorable Court may kindly direct the SHO concerned to register FIR against the accused persons and ensure fair investigation in the interest of justice.
Petitioner
Through Counsel
Date: _______
When drafting a 22A 22B petition, keep these points in mind:
Clearly establish that the offence is cognizable.
Attach copies of written complaint submitted to police.
Attach medical reports (if applicable).
Provide call recordings or CCTV evidence if available.
Avoid emotional or exaggerated statements.
Keep facts precise and chronological.
Courts focus on whether a cognizable offence is disclosed, not on detailed evidence at this stage.
Avoid these errors:
Vague allegations without dates.
Failure to attach annexures.
Incorrect court jurisdiction.
Filing petition without first approaching police.
Including unnecessary lengthy arguments.
A clear and structured 22A 22B application draft increases chances of success.
Once filed:
Court issues notice to SHO.
Police submit report.
Court hears both sides.
If satisfied, court directs registration of FIR.
The Justice of Peace does not determine guilt but only checks whether cognizable offence is made out.
Generally, 22A 22B petitions are decided within:
7 to 30 days (depending on district workload)
Emergency matters may be decided faster.
Though commonly referred together as “22A 22B petition,” they differ slightly:
Section 22A – Administrative powers of Justice of Peace
Section 22B – Duties of police officers and oversight
However, in practice, applications are titled jointly under Sections 22A & 22B CrPC.
Yes, the court may dismiss the petition if:
No cognizable offence is made out.
Matter is purely civil dispute.
Petitioner has ulterior motives.
FIR is already registered.
Therefore, drafting must be legally sound and fact-based.
While not mandatory, hiring a criminal lawyer is advisable because:
Proper drafting improves acceptance.
Legal grounds are framed correctly.
Court arguments are presented professionally.
Many dismissed petitions are due to poor drafting rather than weak cases.
Use formal legal language.
Number each paragraph.
Attach annexures with marking (Annex-A, Annex-B).
Mention relevant PPC sections.
Keep prayer specific and clear.
A strong 22A 22B application draft reflects seriousness and credibility.
Usually nominal court fee stamp is required (varies by province).
Yes, through revision petition before High Court.
Normally SHO represents police, but accused may appear in some cases.
No, it is a pre-FIR remedy for direction to register FIR.
A properly prepared 22A 22B petition draft ensures that justice is not denied due to police inaction. Understanding the correct 22A 22B format and legal requirements can significantly improve the outcome of your application.
If your complaint involves a cognizable offence and the police refuse to act, filing an application under Section 22A 22B CrPC is your lawful right. Always ensure your petition is fact-based, supported with documents, and drafted according to legal standards.
By following the structure and guidance provided in this article, you can confidently prepare a professional and effective 22A 22B application draft that meets court expectations and protects your legal rights.
A 22-A 22-B Petition is one of the most commonly filed legal remedies in Pakistan’s criminal justice system. It is filed under Sections 22-A and 22-B of the Code of Criminal Procedure (Cr.P.C.), 1898, before the Justice of Peace or the Session Judge. The primary purpose of this petition is to seek directions for the registration of a First Information Report (FIR) when the police refuse to register a complaint regarding a cognizable offence.
A 22-A 22-B Petition draft generally includes the complainant’s personal details, a brief description of the incident, the role of the accused persons, and the refusal or inaction of the concerned police station. The petitioner requests the Honourable Court to direct the Station House Officer (SHO) to register the FIR and initiate investigation in accordance with law.
Under Section 22-A(6) Cr.P.C., the Justice of Peace has the power to issue appropriate orders when the police fail to perform their legal duties. Section 22-B Cr.P.C. further strengthens this authority, ensuring that every citizen has access to justice and that police officials act within their legal boundaries.
When drafting a 22-A 22-B petition, it is important to maintain clarity, attach supporting documents such as the written application to the police, CNIC copies, and any evidence of the occurrence. Engaging a qualified criminal lawyer in Pakistan can greatly improve the chances of success.
In short, 22-A 22-B petition draft helps protect citizens’ legal rights, ensures accountability of law enforcement, and upholds the rule of law in Pakistan.
Respectfully Sheweth : –
The addresses of the parties provided at the beginning of the petition are accurate and adequate for the purposes of notice and service.
That the brief facts leading to the present case are that the petitioner submitted an application having diary no, ___ Dated: _________ before the respondent seeking the registration of FIR (a copy of which is attached hereto) against the accused’s namely ___
That the contents of the application sufficiently establish the commission of a cognizable offense and sufficient to prove that cognizable offense has been made out as serious allegations leveled against the nominated accused.
That the petitioner visited the police station to provide a comprehensive account of the incident; however, Despite the petitioner's repeated efforts, the respondent has refused to register a criminal case and is continuously delaying the matter under various pretexts and unequivocally declined to initiate the registration of the case as per Law.
That all the individuals named in the attached application have allegedly engaged in constituting offenses as delineated in the said application, these all offenses are cognizable.
That registration of a case in the cognizable offense under the provision of section 154 Cr.PC, is the statutory duty of officer/ in-charge of police to enter any complaint either written or verbal in the shape of FIR, but in the present case, the respondent miserably failed to discharge his duty in accordance with the law.
That registration of case is an independent right of any person and such person can report the matter to in charge of the concerned police station who is duty bound under section 154 Cr.PC to record the version of the petitioner and conduct the investigation in accordance with the law, but in the instant case nothing has been done on the part of respondents, therefore he committed illegality.
That the word ‘shall’ in section 154 Cr.PC clearly indicates that it has been used in a mandatory sense and does not allow any discretionary powers to the officer/ in-charge of the police station, and such officer has no other choice but to register complaint in the prescribed manner. It is submitted with regard that the respondent neither registered the FIR not informed the petitioner of non-registration of case, therefore respondent did not act in accordance with the law, being public functionary.
That the supreme court has time and again held that the police are duty-bound to register a criminal case on receiving an application about a cognizable offense. The law laid down in supreme court 2007 PLD 539 about the registration of the FIR is very much clear on the subject the respondent has not acted in accordance with law.
That non-registration of a criminal case by the respondent not only constitutes a breach of legal provisions but also constitutes an abuse of the process of law.
PRAYER:
In these circumstances, it is respectfully prayed that the Application Under Section 22-A Cr.PC is accepted and respondent may please be directed to proceed in accordance with the law in line with section 154 Cr.PC by registering a criminal case against the culprits mentioned in the application in accordance with the law in the interest of justice.
Any other relief that this honorable court deems just and equitable in the circumstances of the case may be granted.
Petitioner
Through
Counsel
_______________
Advocate High Court
