IN THE COURT OF _________ FAMILY JUDGE MALIR KARACHI.
F.S No. /2014.
SADAF ………………………….………………… PLAINTIFFS
VERSUS
M.
SHEHBAZ KHAN ………..……………… DEFENDANT
SUIT
FOR MAINTENANCE
The plaintiff, above named, submits as under:-
1.
That the
plaintiff was marriage with defendant on 11-09-2011, in accordance to Muslim family laws of
Pakistan, against the dower amount of 100,000/- which is still unpaid. The copy of Nikahnama
was attached herewith and annexed as “A”.
2.
That after
solemnization of marriage one
issue namely Sadaf was born on
23-06-2012, during the tenor of marriage
the relationship between the plaintiff and defendant got worse, as on the third
day of the marriage the defendant started abusing the plaintiff and beat the
plaintiff as well, as the defendant was in toxic condition and asked about the
paper for divorce, and after two days of this incident the plaintiff went to
the house of her mother, and the plaintiff returned back to the house of the
defendant on 20-09-11. But during the tenor of marriage on many occasions
insulted the plaintiff on bitty matters, but in the year2012, the disputes got
so worse the defendant in anger cut the nerve of his hand, the relative of the
defendant took him to the Hospital for treatment, afterwards the plaintiff and
the defendant went to house of the mother of the plaintiff for taking rest in
the house, but after two days time the defendant again made a fight with the
plaintiff and her family members, and went back to his house and since then he
never have contacted the plaintiff, nor paid any money towards the maintenance
of her and the minor child, and since then the plaintiff is maintaining her
daughter. The copy of the birth certificate was attached and annexed “A”.
3.
That since 2012, the defendant never
contacted the plaintiff nor paid any money towards the maintenance of her and
the Suckling child and since then the plaintiff.
4.
That a suit for
Dissolution of marriage by way of Khula is pending before II FJ Karachi Malir.
5.
That the cause of action for the instant
suit accrued firstly on 11-09-2011, when the plaintiff married to the
defendant, secondly, when the defendant left the house of the plaintiff mother
in the year 2012. And the cause of action is still continuing as the defendant
did not contact the plaintiff for any consolidation.
6.
That the plaintiff is residing within local
limits of Police Station __________________ that fall within
the territorial jurisdiction of this Hon’ble Court.
7.
That the proper court fee has been affixed
as per law. That presently I am
residing at the address as given in the plaint.
PRAYER
It is therefore, very humbly
and respectfully prayed that this Hon’ble Court may kindly be please to pass
judgment and decree in favor of the plaintiff and against the defendant as
under:-
a.) To direct the defendant to pay past maintenance to the
plaintiff No. 1 at the rate of Rs. 5,000/= per month from month June 2012
uptill now and in future on increment of 20% p/a.
b.) To direct the defendant to pay past maintenance to the
plaintiff No. 2 at the rate of Rs. 5,000/= per month from month of September 2011
uptill now and in future upto iddat period on increment of 20%. p/a.
c.)
Cost
of the suit.
d.)
Any
other relief(s) which may this Hon’ble Court deem fit.
Karachi
Dated:____/04/2014.
PALINTIFF
Advocate for the Plaintiff.
VERIFICATION
I,
AZRA BIBI D/O. __________________,
Muslim, Adult, R/O, _________________________________, Karachi, do here by state on oath and on solemn affirmation as here
under:-
Karachi.
Dated:14/ /2014
Deponent/Plaintiff
The deponent identified by me
S M ZUBAIR
(ADVOCATE)
Solemnly
affirmed before me on oath at Karachi on this ____day of January, 2014 by the
deponent, who is identified by S.M. ZUBAIR
Advocate who is personally known to me.
COMMISSIONER FOR TAKING AFFIDAVITS.
Documents
filed: annexure
“A”
& “B”
List
of witnesses: Annexure
“C”
Documents
relied upon: Original of
above
Address
of parties: As in
the title of Plaint.
