Suit for Maintenance

IN THE COURT OF II ND. FAMILY JUDGE AT KARACHI CENTRAL

F.S. No.             /2012

 

1.        Mst. AAMNA Aftab

D/o. Muhammad Aftab,

W/o. Qamar Afzal,

Muslim, adult, R/o. House No.      ,

Block-5,

Liaqatabad,

Karachi.

2.        NOOR

daughter of Qamar Afzal

Muslim, Minor though Plaintiff No.1

Who is his real mother.     …………….……………                                 PLAINTIFFS

VERSUS

Qamar Afzal

Son of Afzal ,

Muslim, adult, R/o. Flat No. 6-A,

Block-5,

Liaqatabad,

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

SUIT FOR MAINTENANCE

The Plaintiff, above named, submits as under:-

1)    That the Plaintiff, above named, was married with the Defendant, above named, at Karachi, on 08-10-2007, and nikah was solemnized verbally before family members and other witnesses, in consideration of dower amount of Rs.25000/= which is still unpaid. Rukhsati took place at same day, but this nikah was registered on 18-12-2011.  Photocopy of Nikahnama is attached herewith and marked annexure “A”.

2)    That after rukhsati, relations between the spouses remained harmonious married life for few years and then the Plaintiff’s husband started to inflict mental & physical torture and mal-treated the Plaintiff No.1, and started to suspect her character on instigation of in-laws family members and his friends.

3)    That out of this wedlock one female issue namely Noor was born on 10.10.2011, but the defendant disowned her daughter, above named, and the defendant turned out her with above said, newly born baby from his house and said until it is proved that he is father of the newly born minor, above named, he will not rejoin her and he will divorce her.

4)    That the defendant did not maintained the plaintiff No.1 & 2 properly since 10.10.2011 to upto now.

5)    That due to circumstances mentioned above it is very difficult and beyond the plaintiff’s control to save her harmonious matrimonial life and maintain herself alongwith the minor above named.

6)    That the Plaintiffs are residing within limits of P.S Liaqatabad, which is within jurisdiction of this Hon’ble Court.

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

PRAYER

Due to circumstances mentioned above, 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 direct the defendant to pay past maintenance to the plaintiff No.1 & 2 at the rate of Rs.2,000/= per month from 10.10.2011 up till now and in future on increment of 10% p/a.

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:13/04/2012.

PLAINTIFF No.1

PLAINTIFF No.2

through her mother

S M  ZUBAIR

Advocare for the Plaintiff.

VERIFICATION

I, Mst. AAMNA Aftab W/o. Qamar Afzal, 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: 13/04/12.                                                              

Deponent/Plaintiff

The deponent identified by me

S M  ZUBAIR

(ADVOCATE)

Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2012, by the deponent above named 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 she seems to be understood the same and set his/her signature/thumb impression.

COMMISSIONER FOR TAKING AFFIDAVITS

DOCUMENTS FILED                    :    Annexure P/1 to P/      .

DOCUMENTS RELIED UPON      :   ALL RELEVANT DOCUMENTS  

ADDRESS OF DEFENDANTT      :   AS PER TITLE OF THE SUIT.

FOR SERVICE.

ADDRESS OF THE COUNSEL     :   31, BARI CHAMBERS, NearJama  

FOR DEFENDANT                              Cloth, Robson road, Karachi.

          FOR IMMIDIATE USE ONLY IN COURT

IN THE COURT OF II ND. FAMILY JUDGE AT KARACHI CENTRAL

F.S. No.             /2012

 

Mst. AAMNA Aftab      …………….……………                                PLAINTIFFS

VERSUS

Qamar Afzal          …………….……………                                  DEFENDANT

AFFIDAVIT

I, Mst. AAMNA Aftab W/o. Qamar Afzal, Muslim, adult, R/o. Karachi, do hereby state on oath as under:-

1.    That I am the Plaintiff No.1 in the above matter and as such am fully conversant with the facts of the matter deposed herein.

2.    That I say that I have neither CNIC and nor I applied for CNIC yet.

3.    That whatever stated above is true and correct to the best of my knowledge and belief.

Karachi.

Dated: -13/04/2012.

Deponent/Applicant

Identified by me

S M  ZUBAIR

(ADVOCATE)

Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2012, by the deponent above named 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 she seems to be understood the same and set his/her signature/thumb impression.

COMMISSIONER FOR TAKING AFFIDAVITS