KHULA

IN THE COURT OF      FAMILY JUDGE   KARACHI  CENTRAL

F.S.NO.     /2001

Mst.Shabana Uzma D/o. Imran Ahmed (late)

Muslim, adult, R/o. B-2-14 Peoples colony,

North Nazimabad, Karachi ………………………………………    Plaintiff

VERSUS

 

Kashif Ali  son of Perwaiz Ahmed,

Muslim, adult, R/o. R-758, Sector 15-A,

Buferzone, North Karachi ……………………………………….    Defendant

SUIT FOR DISSOLUTION OF

MARRIAGE  BY WAY OF KHULA

    

     The Plaintiff abovenammed respectfully submits as under: -

1.      That the plaintiff abovenamed was married with the defendant at Karachi on 

      15.10.2000 as per Shariat Law and dower amount was fixed Rs.20000/=(Rupees                                                         

      Twenty thousand only) which is still unpaid.

2.      That the relation between the spouses remained harmonious for few days and then the defendant started torture mentally physically and mal-treated theplaintiff, since the marriage was taken place the defendant never maintained her properly.

3.      That since the marriage was taken place the defendandant had not performed matrimonial with the plaintiff but he had relations with other women and some Ghundas elements, the defendant used to order to fulfill his all kinds of wishes, on refusal to beat brutally and severally and miserably turned her out of his house and then used to make apologize and brought her in his house. 

4.      That the defendant used to demand money and on refusal he used filthy language and leveled allegation on her character, and the defendant tried his level best to lead her life as a wanton, so that he may play gamble, due to this attitude towards the plaintiff, it developed hatred against the defendant and it is beyond her control to live with him within limits prescribed by AL-MIGHTY ALLAH.

5.      That the defendant beaten the plaintiff and used filthy language on pity matters and turned her out from his mothers house and asked he will murder her if she came back on                     since then she is residing with her parent and all dowry articles are in the house of defendant, the plaintiff reverse her right to recover the same.

6.      That the defendant beaten the plaintiff and used filthy language on pity matters and turned her out from his house and asked he will murder her if she comes back on         since then she is residing with her parents and all dowry articles

7.      That the cause of action arose firstly when the defendant beat her and used filthy language and turned her from his house on        now the plaintiff feels unsafe for her life.

8.      That under the circumstances mention above it is beyond her control to live together within limits prescribed by AL-MIGHTY ALLAH and plaintiff is ready to waive/forego her dower amount in lieu of KHULA.

9.      That the plaintiff resides within the limits of P.S                 which is within the jurisdiction of this Honble court.

 P  R  A  Y  E  R

  The plaintiff prays for the following relieves: -

A)          That this Honble court may be pleased to dissolve this marriage and to pas judgement and decree in favour of the plaintiff and against the defendant.

B)      That this Honble court may be pleased to dissolve the marriage by way of Khula in that case the plaintiff is prepared to forego her dower amount.

C)      That any other relief which under the circumstances of the case this Honble court deems fit kindly be granted to the plaintiff against the defendant.                                                               

        

        Karachi

        Dated:

PLAINTIFF

S.M. ZUBAIR

ADVOCATE FOR THE PLAINTIFF.