IN
THE COURT OF _________ FAMILY JUDGE
MALIR KARACHI.
F.S No. /2014.
AZRA
BIBI .………….……………… PLAINTIFFS
VERSUS.
M.
SHEHBAZ KHAN …………………….....
DEFENDANT
SUIT FOR RECOVERY OF MAINTENANCE
The plaintiff, above named, submits as under:-
1.
That the
plaintiff No.1 was marriage with defendant on 11-09-2011, in accordance to Muslim family laws of
Pakistan, against the dower amount of 100,000/- which is still unpaid. The copy of Nikahnama
was attached herewith and annexed as “A”.
2.
That after
solemnization of marriage one
issue namely Sadaf,
was
born on 23-06-2012, during the tenor of
marriage the relationship between the plaintiff and defendant got worse, as on
the third day of the marriage the defendant started abusing the plaintiff and
beat the plaintiff as well, as the defendant was in toxic condition and asked
about the paper for divorce, and after two days of this incident the plaintiff
went to the house of her mother, and the plaintiff returned back to the house
of the defendant on 20-09-11. But during the tenor of marriage on many
occasions insulted the plaintiff on bitty matters, but in the year2012, the
disputes got so worse the defendant in anger cut the nerve of his hand, the
relative of the defendant took him to the Hospital for treatment, afterwards
the plaintiff and the defendant went to house of the mother of the plaintiff
for taking rest in the house, but after two days time the defendant again made
a fight with the plaintiff and her family members, and went back to his house
and since then he never have contacted the plaintiff, nor paid any money
towards the maintenance of her and the minor child, and since then the
plaintiff is raising the minor by earning the bread and butter for her. The copy of the birth certificate was
attached and annexed “B”.
3.
That since 2012, the defendant never contacted
the plaintiff nor paid any money towards the maintenance of her and the minor
child, and since then the plaintiff is raising the minors by earning the bread
and butter for her.
4.
That the defendant is
working in private factory and his earning is Rs. 20,000/= every month, the
plaintiffs claim maintenance for Plaintiff No.1 @ Rs. 4000/= from 11-09-2011 and maintenance for Plaintiff No.2 @ Rs. 4000/= since her
birth.
5.
That the cause of action for the instant suit
accrued firstly on 11-09-2011, when the plaintiff married to the defendant,
secondly, when the defendant left the house of the plaintiff mother in the year
2012. And the cause of action is still continuing as the defendant did contact
the plaintiff for any consolidation.
6.
That the plaintiffs are residing within local
limits of Police Station QUAIDABAD that
fall within the territorial jurisdiction of this Hon’ble Court.
7.
That the proper court fee has been affixed as
per law.
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 direct the defendant to pay past maintenance to the plaintiffs at the
rate of Rs.4,000/= per month from 11-09-2011, up till now and in future upto
iddat period.
b.
to direct the defendant to pay past
maintenance to the plaintiffs at the rate of Rs.4,000/= per month since her
birth on increment of 10% in
future till her marriage.
c.
Cost of the suit.
d.
Any other relief(s)
which may this Hon’ble Court deem fit.
Karachi
Dated:____/01/2014.
PALINTIFF
