IN THE COURT
OF FAMILY JUDGE AT KARACHI WEST
F.S. No. / 2019
Sana
D/o
Muslim,
Adult, R/o ABC
Saeedabad,
Baldia Town,
Karachi.
---------------------------------------------------------PLAINTIFF
VERSUS
Karim Bux
S/o
Imam Din,
Muslim,
Adult, R/o XYZ
Gali
No: 3, Darya Abad, Liari,
Karachi---------------------------------------DEFENDANT
The plaintiff abovenamed most respectfully begs to
submit as under:-
1. That the plaintiff was married with the defendant
on 11-07-2019, at Karachi, according to the Muslim Family Law, against the
dower amount of Rs.100,000/-, which is still unpaid.
Photocopy of Nikahnama is enclosed
herewith and marked as annexure ‘A’.
2.
That after
Nikah, took place and marriage was duly consummated between the spouses, while
from the said wedlock there is no issue was born.
3.
That after
some time of marriage, defendant changed his behaviour and showed his true
colors of his eyes and started rude behaviour with the plaintiff and made her
life miserable day by day.
4.
That the
defendant used to torture, abuse & maltreat the plaintiff but the plaintiff
having no alternate shelter endured all that just under the hope that by the
passage of time the defendant will realize his responsibilities and resultantly
in future a happy & normal matrimonial life will start for the plaintiff
but all such hopes of the plaintiff went in vain due to continuous habitual
misconduct, maltreatment, ill attitude, immoral and financial demands and
illegal activities of the defendant.
5.
That after one month of Nikah, the
defendant beaten kicked out the plaintiff from his house and since then he
neither made any contact with the plaintiff nor sent single penny in lieu of
maintenance.
6.
That neither the defendant ever did not
provide plaintiff any love or affection nor the defendant performed his legal
& moral matrimonial obligations towards the plaintiff as prescribed under
Islam. Further that the plaintiff had tried her level best to incline the defendant for
desisting from his immoral demands, ill attitude, unlawful conduct, illegal financial demands and
un-human behaviour and to realize him the matrimonial responsibilities laid
upon him by Almighty Allah, but due to obstinacy of the defendant all sincere
efforts of the plaintiff remain result less.
7.
That now the plaintiff has developed
serious hate in her heart against the defendant and now under the circumstances, she will preferred to die instead of
rejoining the defendant as his wife, hence this suit for dissolution of
marriage by way of khula.
8.
That plaintiff is ready to forgo her
dower amount in lieu of Khula granted by this Hon’ble Court.
9.
That the cause of action has arisen to
the plaintiff against the defendant for filing the instant suit firstly when
soon after the marriage, the defendant started maltreatment, abuse, harass and
beaten the plaintiff on petty matters, secondly after the one month of marriage
when the defendant beaten and kicked out the plaintiff from his house and since
then he neither made any contact nor sent single penny in lieu of maintenance
and the same cause of action is still continued day to day till the
instant suit of the plaintiff is decreed as prayed.
10. That the plaintiff is residing at the above
mentioned address, within the territorial limits of P.S. Saeedabad,
which is within the jurisdiction of this Hon’ble Court.
11. That the proper Court fee as prescribed under the
law has been affixed on the plaint.
PRAYER
It is, therefore, respectfully prayed that this
Hon’ble Court may graciously be pleased to pass a Judgement
and Decree in favour of the plaintiff and against
the defendant as follows.
a). To dissolve the plaintiff’s
marriage with the defendant by way of Khula, as the plaintiff is ready to forgo
her dower amount in lieu of Khula.
b). To
grant cost of the Suit or any other relief(s) which this Hon’ble Court under
the facts and circumstances of the matter may deem fit and proper.
PLAINTIFF
Karachi.
Dated:
-11-19 ADVOCATE
FOR THE PLAINTIFF
IN THE COURT
OF FAMILY JUDGE AT KARACHI WEST
F.S. No. / 2019
Sana---------------------------------------------------------PLAINTIFF
VERSUS
Bilawal Khan--------------------------------------------DEFENDANT
LIST
OF WITNESSES
1. Plaintiff. She
will corroborate the
Version
of the Plaintiff.
2. Support
the Version
of Plaintiff.
3. ------------do----------
Karachi:
Dated: -11-2019 Advocate for the plaintiff
IN THE COURT
OF FAMILY JUDGE AT KARACHI WEST
F.S. No. / 2019
Sana----------------------------------------------------------------PLAINTIFF
VERSUS
Bilawal Khan---------------------------------------------------DEFENDANT
AFFIDAVIT.
I, Mst. Sana D/o Muhammad Siraj, Muslim, Adult, R/o Karachi, do hereby state on Oath
as under:
1.
That I am
plaintiff in the above titled suit and deponent of this affidavit as such am
fully conversant with the facts of the matter deposed to below.
2.
That the
accompanying suit for dissolution of marriage by way of Khula has been drafted and
filed under my specific instructions & on my behalf and
the contents whereof are true and correct and the same may please be treated as
part of this affidavit for the sake of brevity.
3.
That whatever stated above is true and correct
to the best of my knowledge and belief.
Karachi:
Dated: -11-2019 DEPONENT
No comments:
Post a Comment