KHULA

IN THE COURT OF ­­_________ FAMILY JUDGE  KARACHI  ____________.

Family Suit No. …/04

Nazia,

Adult, R/o. Nomaish

Karachi ………………………………………………………………….. PLAINTIFF

 

VERSUS

Muhammad Wasim,

Muslim, adult, R/o. Siraj Colony,

Karachi …………………………………………………………..…..…   DEFENDANT

SUIT FOR DISOLUTION OF MARRIAGE BY WAY OF KHULA

The plaintiff abovenamed states as under: -

1.          That on 07.02.2002 the defendant married the plaintiff at Karachi, on agreed dower amount of Rs.50,000/=(Rupees Fifty Thousand only)which was payable on demand. Photo copy of Nikahnama is filed herewith and marked "A'.

2.          That the Defendant was a Christian and his name was William S/o. Inayat the defendant approached the plaintiff and assured him that she loves the plaintiff and she may marry with the plaintiff if he embraces Islam her that they will lead a harmonious married life and defendant loves her so much and cannot live without her. The defendant also insisted that both of them shall not consult their parents for consent and approval of the marriage and the plaintiff shall accompany the defendant to City Court and after completing the formalities to perform Nikah and she will convince her parents for this marriage.

3.          That the plaintiff is living with mother and younger brother and sister the defendant was staying with the plaintiff upto June1999 as soon as the defendant came to know that the plaintiff and insisted for abortion which the plaintiff refused and also the relations become strained. The defendant has not paid anything towards her maintenance.

4.          That the defendant has not given anything except a pair of clothes and a ring at the time of Nikah.The defendant on plaintiff's demand for payment of dower threatened her for dire consequences unless she forgo the dower amount.

5.          That the defendant then started harassing the plaintiff was very much upset and  made application to the police that the defendant is likely to grievously hurt or kill her so the protection may be given to the plaintiff and his family. The defendant has made life of the plaintiff most miserable by his acts and deeds. The plaintiff is less than eighteen (18) years and passing sleepless nights in fear. She is also entitled to exercise option of puberty.

6.          That it is not possible for the plaintiff to live together a harmonious married life. The defendant has committed fraud and now continued threatening plaintiff and her mother as such the plaintiff has developed hatred to the defendant as such she cannot live together according to the limits of God.Icase of dissolution of marriage by way of Khula the plaintiff is prepared to forgo her dower and maintenance.

7.          That the cause of action accrued to the plaintiff within jurisdiction of this Hon'ble Court at P.S.Rizvia, Karachi on 21.3.1999 when the Nikah was performed and subsequently when the defendant stopped coming to the plaintiff's house and insisted for abortion of the child the plaintiff conceived and also otherwise the life of the plaintiff become more miserable due to defendant's conduct and started hating him.

8.          That the prescribed court fees stamps has affixed as the suit is valued in accordance with the provision of Family Court Act.

9.          That the plaintiff prays for the following relief.

• a)      That the marriage of the plaintiff with the defendant may kindly be dissolved.
• b)   That in alternative the marriage of the plaintiff with the defendant may kindly be dissolved by way of Khula in that case she is prepared to forgo her dower and maintenance.
• c)    That any other relief which under circumstances of the case the Hon'ble court may deems fit kindly be granted to the plaintiff against the defendant.

Karachi.

Dated:

DEPONENT

S.M.ZUBAIR

Advocate for the Plaintiff

VERIFICATION

I, Mst. Nazia D/o. Abdul, Muslim, adult, R/o. Karachi, do hereby verify and state on oath that whatever stated above is true correct to the best my knowledge and belief.

Karachi    

Dated: ----/07/11.                                                              

Deponent/Plaintiff

The deponent identified by me.

S.M.  ZUBAIR

 (ADVOCATE)

      

                  Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2011, 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.

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