IN THE COURT OF FAMILY JUDGE KARACHI CENTRAL
F.S.NO. /2001
Mst. NAHID
D/o. Imdad Ali,
Muslim, adult, R/o. House No.20,
Block – 18, KDA Colony,
Karachi …………………………………… Plaintiff
VERSUS
Muhammad AAMIR
Son of Muhammad Ismail,
Muslim, Adult, R/o. House No. L-1/A-47,
Surjani,
Karachi ……………………………… Defendant
SUIT FOR DISSOLUTION OF
MARRIAGE BY WAY OF KHULA
The Plaintiff abovenamed states as under: -
1. That the Plaintiff was married with the Defendant at Karachi, in August 2002, as per Shariat Law, in consideration of dower amount of Rs.25,000/=(Rupees Twenty Five Thousand only) which is still unpaid, and one male issue, AMMAN, aged about three & half month, was born out of this wedlock. Nikahnama is in custody of the Defendant.
2. That rukhsati took place at same day, and relation between the spouses remained harmonious for few days and then the defendant started to inflict mental & physical torture and mal-treated the Plaintiff, since the marriage was taken place the defendant never maintained her properly, but the Plaintiff tried to lead a harmonious married life, she served the Defendant as well his parents, brother
3. s and sister as a servant besides this she loved him so much, but the whole family of the Defendant spare no opportunity to degrade her, on false complaints made by the whole family the Defendant used to beat her severally.
4. That since the marriage took place the Defendant did give permission to see with her parents, sisters, brothers, hardly 3/4 times she met them in presence of any one member of his family.
5. That the defendant used to come with his friends seems to be ghundas and ordered to fulfill all kinds of wishes of them, on refusal to beat brutally and severally and miserably and then used to make apologize.
6. That in present month the Defendant, on some pity reason, on instigation of his mother & sister the Defendant beaten her beastly and turned her out, alongwith sucking baby in three clothes, from his house, due to this she had to take shelter in the house of the plaintiff’s father and since then she is living with her parents, while all the dowry articles and golden ornaments worth of Rs.56000/= are lying in the Defendant’s house, she reserves the right to recover the same separately.
7. That now it is not possible for the plaintiff to live together a harmonious married life. The Plaintiff has developed hatred toward the defendant as such she cannot live together according to the limits prescribed by Al-Mighty ALLAH, the Plaintiff is prepared to forgo her dower in consideration of dissolution of marriage by way of Khula.
8. That the cause of action accrued to the plaintiff when the Defendant turned her out of his house, she is residing within limits of P.S _________________, which is within jurisdiction of this Hon’ble Court.
9. That the prescribed court fees stamps has affixed as the suit is valued in accordance with the provision of Family Court Act.
PRAYER
It is respectfully prayed that this Hon’ble Court may be pleased to pass Judgment and Decree in favoure of the Plaintiff against the Defendant claims: -
A) To dissolve the marriage by way of Khula.
B) Costs of the suit.
C) Any other relief, which this Hon’ble Court deems fit and proper in the circumstances of the case.
Karachi.
Dated: ---/---/04.
P L A I N T I F F
S.M. Zubair
Advocate for the Plaintiff
VERIFICATION
I, Mst. NAHID D/o. Imdad Ali, Muslim, adult, resident of Karachi, do hereby verify and state on oath that whatever stated above is true correct to the best my knowledge and belief.
Karachi
Dated: ----/0 /04.
Deponent/Plaintiff
The deponent identified by me.
SM ZUBAIR
(ADVOCATE)
Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2004, by the deponent abovenamed who is identified by Mr. S M ZUBAIR, Advocate whom I know personally.
The contents of the Plaint have been read over and explained to the Deponent in Urdu too and he/she seems to be understood the same and set his/her signature/thumb impression.
COMMISSIONER FOR TAKING AFFIDAVITS
DOCUMENTS FILED : NIL.
DOCUMENTS RELIED UPON : ALL RELEVANT DOCUMENTS
ADDRESS OF DEFENDANTT : AS PER TITLE OF THE SUIT.
FOR SERVICE.
ADDRESS OF THE COUNSEL : 31, BARI CHAMBERS, Near Jama
FOR DEFEND Cloth, Robson road, Karachi
IN THE COURT OF FAMILY JUDGE KARACHI CENTRAL
F.S.NO. /2001
Mst. NAHID …………………………………… Plaintiff
VERSUS
Muhammad AAMIR ……………………………… Defendant
AFFIDAVIT
I, Mst. NAHID D/o. Imdad Ali, Muslim, adult, resident of Karachi, do hereby state as under: -
1. That I am the Deponent/Plaintiff of this affidavit and as such am fully conversant with the facts of the matter deposed herein.
2. That I say that was married with the Defendant at Karachi, in August 2002, as per Shariat Law, in consideration of dower amount of Rs.25,000/=(Rupees Twenty Five Thousand only) which is still unpaid, and one male issue, AMMAN, aged about three & half month, was born out of this wedlock. Nikahnama is in custody of the Defendant.
3. That whatever stated above and in the accompanying Plaint is true and correct to the best of my knowledge and belief.
Karachi.
Dated: - ---/----/04.
DEPONENT
Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2004, by the deponent abovenamed who is identified by Mr. S M ZUBAIR, Advocate whom I know personally.
COMMISSIONER FOR TAKING AFFIDAVITS
IN THE COURT OF FAMILY JUDGE KARACHI CENTRAL
F.S.NO. /2001
Mst. NAHID ……………………………………...... Plaintiff
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