In the Court of Senior Civil Judge
with the Powers of Judge Family Court
(name of the city).
Name and correct
present address
......... Plaintiff
V E R S U S
Name and correct
present address
......... Defendant
SUIT FOR DISSOLUTION OF MARRIAGE, RECOVERY
OF MAINTENANCE ALLOWANCE AND DOWRY ARTICLES.
Respectfully
Sheweth:
1-
That the addresses of the parties are given
true and correct for the service /notice upon the parties through this
Honorable Court when and so required.
2-
That the
Marriage/Nikah inter-parties was solemnized on 23.03.0000 according to Muslim
Law. At the time of marriage an amount of Rs. 500,000/- was fixed as a “Haq
Mehar” between the parties. Thereafter the plaintiff went to defendant’s home
to fulfill her matrimonial obligations.
3-
That the Plaintiff has been residing with the Defendant for about few
months. It is pertinent to mention here that no child has been born out of wed-lock.
4-
That at the time of marriage the parents of the plaintiff had
given the Dowry Articles and Gold Ornaments to the plaintiff as per list
attached with the plaint are in the custody of the defendant at his home.
5-
That the defendant has happened to be a man of suspicious mind and
he has always been suspecting the normal life style of the plaintiff with
suspicious. Moreover, the defendant is habitually used to physical beating the
plaintiff on patty matters and also having always nonchalance attitude towards
the plaintiff. Thus the spouses have not been enjoying very harmonious
matrimonial life and the defendant has always been giving physical and mental
torture to the Plaintiff.
6-
That the defendant has un-chastity and prohibited degree relation
with the ill-repute woman. The plaintiff mentally disturbed owing to eternal
triangle and intriguing of the defendant
7-
That the plaintiff dis-liked the defendant because the defendant
has mis-behaved and turned out the plaintiff from his house. Thereafter, the
plaintiff came to her parent’s home in a miserable condition after facing the
great difficulties.
8-
That the Plaintiff has developed hatred against the Defendant due
to his ill habits and promiscuous relation and obnoxious attitude.
9-
Thus the Plaintiff is entitled for divorce from the Defendant on
the basis of “KHULA” on the following grounds inter-alia:-
i.
That the Plaintiff has developed hatred against the Defendant and
the Plaintiff cannot lead a harmonious life with the Plaintiff within the
prescribed limits of Allah.
ii.
That the defendant has not paid any coin as maintenance allowance
to the plaintiff since last 10-months whereas the defendant has very good
financial position and easily pay an amount of Rs.10,000/- per month.
iii.
That the plaintiff is not ready to live with the defendant, as the
defendant turned out the plaintiff from his house without any shelter.
iv.
That the plaintiff is also entitled to grant the decree for
dissolution of marriage on the basis of “KHULA”.
v.
That the plaintiff has a lot of abhorring to the defendant owing
to his woo and illicit relation and habit of womanize.
8.
That the plaintiff is entitled to recover the dowry articles total
amounting to RS.5,74,345/- as per
list.
9.
The plaintiff is also entitled to recover the maintenance
allowance from the defendant @ Rs.10,000/- per month from July 0000 to date the
decree of dissolution of marriage and along- with the period of “Iddat”.
10.
That the cause of action arose to the Plaintiff firstly when the
marriage inter parties was held on 23.03.0000 and secondly when the defendant turned
out the plaintiff from his house and lastly time to time when the Defendant
refuse to give the maintenance allowance and divorce and the same is continued
still.
11.
That the Plaintiff is residing at Faisalabad and the cause of action also arose
at (name of the city) and as this
learned court has the exclusive jurisdiction to hear and determine the present
suit.
12.
That the value of the suit for the purposes of court fee and
jurisdiction is fixed at Rs.400/= on which proper court fee has been paid up
according to the Family Court Act.
It is,
therefore, respectfully prayed that a decree for Dissolution of marriage,
recovery of maintenance allowance @ Rs.10,000/- per month from July 0000 to
date the decree of dissolution of marriage and along with the period of Iddat
and recovery of dowry articles amounting to Rs.5,74,345/- as per list attached with the plaint, may please be
ordered to be passed in favor of the Plaintiff against the Defendant.
It is
further prayed that the copy of the decree may be sent to the concerned Union
Council for implementation of the same in the relevant record. The costs of the
suit may also be awarded to the Plaintiff against the Defendant.
It is also
prayed that any alternate relief to which this learned Court deems fit may also
be granted to the plaintiff.
Plaintiff
Through:
Counsel
VERIFICATIONS:
Verified
on oath at Faisalabad
on 20.05.0000 that the contents of the above paras are true and correct to the
best of my knowledge and belief.
Plaintiff
In the Court of Senior Civil Judge
with the Powers of Judge Family Court
(name of the city).
Name and correct
present address
......... Plaintiff
V E R S U S
Name and correct
present address
......... Defendant
SUIT FOR DISSOLUTION OF MARRIAGE, RECOVERY
OF MAINTENANCE ALLOWANCE AND DOWRY ARTICLES.
AFFIDAVIT
Name
of the plaintiff and address
I, the above named deponent do, hereby solemnly
declare and affirm as under:
That the
contents of the accompanying application are true and correct to the best of my
knowledge and belief and nothing has been concealed.
Deponent
Verification:
It is verified on oath at Faisalabad on 15-05-0000 that the contents of
the affidavit are true and correct to the best of my knowledge and belief and
nothing has been concealed.
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