IN
THE COURT OF _________ FAMILY JUDGE MALIR KARACHI.
F.S No.
/2014.
AAMNA
NAZ ………………………….………………… PLAINTIFF
VERSUS
AYYAZ
Ahmad Khan ………..……………… DEFENDANT
SUIT FOR DISSOLUTION OF
MARRIAGE BY WAY OF KHULA, MAINTENANCE AND DOWRY ARTICLES
The plaintiff, above named, submits as here
under:-
01) That the plaintiff was married with defendant on
02-11-2012, in accordance to Muslim
family laws of Pakistan, against the prompt dower amount of Rs. 10,000/- which
is still unpaid. The copy of Nikahnama
was attached herewith and annexed as annexure
“A”.
02) That the parents and relatives of the plaintiff presented
dowry articles, worth of Rs. 3, 50, 000/= including a Gold Set, Fridge, Washing
Machine, Color Tv, Microwave Oven, Furniture etc, to the defendant, the said
dowry articles are lying in defendant’s house. A list of Dowry Article is
attached herewith and marked as annexure
“B”.
03) That after solemnization of marriage the relations
between the spouses remained harmonious, soon after the marriage the behavior of defendant
with plaintiff was immoral, insulting, and misbehaving, the reasons almighty Allah
knows better or the defendant, and the
relationship between the plaintiff and defendant got worse, as the defendant is
a Boxer as Lance Naik, Unit 5-AK (Kashmir) in Pak Army and used to abuse and
beat the plaintiff, during the tenor of marriage on many occasions the
defendant insulted the plaintiff on pity matters and the defendant neither
maintained her nor paid any money towards the maintenance.
04) That after marriage it was revealed that the
defendant had married prior to marriage with the plaintiff, which was not told
to the plaintiff.
05) That the plaintiff tried her leveled best to be
good devoted house wife and served the plaintiff and his parents like a maid, but
the defendant failed to be good husband and most of time the defendant remains
out of his house due to his employment in Pak Army, but when he comes to home
on leave his attitude towards the plaintiff remains harsh, insulting and during
period of his leave he used to be gambling, drinking and addicted person.
06) That during tenor of the marriage the defendant
hardly used to allow seeing her parents.
07) That if the plaintiff’s marriage with the defendant
is not dissolved and Khula is not granted then the plaintiff shall suffer
irreparable losses or if she is forced
to live with the defendant as a husband and wife then instead of going
to the house of her husband she would prefer to die by committing sue side by
taking poison.
08) That for the
reasons mentioned above the
plaintiff has developed hatred against the defendant and now it is impossible
for the plaintiff to reside as a wife with the defendant within the limits
prescribed by the Almighty ALLAH hence this suits for dissolution of marriage
by way of Khula and for that the plaintiff is ready to forgo her dower amount.
09) That the cause of action for the instant suit
accrued firstly on 02-11-2012, when the plaintiff married to the defendant,
secondly, when the defendant beaten 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.
10) That the plaintiff is residing within local
limits of Police Station _______
that fall within the territorial jurisdiction of this Hon’ble Court.
11) That the proper court fee has been affixed as
per law. Presently the plaintiff 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 dissolve the marriage of the Plaintiff with the defendant by way of
khula.
b) To direct the
defendant to pay past maintenance to the plaintiff at the
rate of Rs. 5,000/= per month from month of November 2012 uptill now and in future
upto iddat period on increment of 20%.
c) To recover all
dowry articles worth of Rs. 350,000/= as per List of Dowry Articles.
d) Cost of the
suit.
e) Any other
relief(s) which may this
Hon’ble Court deem fit.
Karachi.
Dated:___/03/2014. DEPONENT/PALINTIFF
Advocate
for the Plaintiff.
VERIFICATION
I, Mst. AAMNA NAZ D/O.
________________, Muslim, adult, residing at House No. __________________, Karachi,
do
here by verify on solemn affirmation and on oath that whatever stated here in
above is true and correct to best of my knowledge and belief.
DEPONENT/PLAINTIFF
Solemnly affirmed before me on oath
at Karachi on this ____day of March, 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.
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