IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF JUDGE FAMILY COURT, LAHORE.
Mst. ___________ Daughter of ___________, Resident of, ___________, Lahore.
….Plaintiff
V E R S U S
___________ Son of ___________ Resident of ___________, Lahore.
….Defendant
SUIT FOR DISSOLUTION OF MARRIAGE
ON THE BASIS OF KHULLA
Respectfully Sheweth:-
1. That the plaintiff was married with the defendant on 04.12.2010 in accordance with Muslim Law against dower of Rs. 5,000/- which was paid on spot and the nikah was registered with the concerned union council.
2. That the behavior, conduct of the defendant was cordial only for few years with the plaintiff, afterwards the defendant started beating and quarreling with the plaintiff on petty household matters, which the plaintiff beard only in order to intact her marriage.
3. That in January 2016 the defendant after severe beating kicked out the plaintiff from his house in three wearing apparels and the plaintiff take shelter in her uncle’s house where she is presently residing.
4. That the life of the plaintiff became miserable by defendant’s cruel conduct.
5. That now plaintiff has developed hatred in her mind against the defendant and she cannot live with the defendant within prescribed limits of ALMIGHTY ALLAH.
6. That the plaintiff seeks dissolution of marriage on the ground of Khulla.
7. That respectables of the plaintiff’s family approached the defendant and requested him to divorce the plaintiff but defendant flatly refused them. Hence, this suit.
8. That the cause of action accrued in favour of the plaintiff against the defendant firstly, when marriage was solemnized, secondly, when defendant tortured the plaintiff and kicked out the plaintiff from his house and lastly, a day before filing of this suit when defendant flatly refused to divorce the plaintiff, which is still continuing.
9. That the plaintiff is residing in Lahore, therefore, this Honourable court has got the jurisdiction to adjudicate upon the matter.
10. That the requisite court fee of Rs. 15/- has been affixed on the plaint.
PRAYER
Under above narrated circumstances, it is, therefore, most respectfully prayed that a decree for dissolution of marriage on the basis of “Khulla” may very kindly be passed in favour of the plaintiff and against the defendant.
Costs of the suit may also be awarded.
Any other relief which this Honourable Court deems fit may also be awarded.
Plaintiff
|
Advocate High Court
Plaintiff
IN THE COURT OF SENIOR CIVIL JUDGE, WITH POWERS OF JUDGE FAMILY COURT, LAHORE.
In re:
___________ VS ___________
(SUIT FOR DISSOLUTION OF MARRIAGE)
LIST OF WITNESS
ON BEHALF OF PLAINTIFF
1. Muhammad Aslam Son of Ghulam Qadir Resident of House No. 6, Mian Meer Pind, Dharampura, Lahore.
2. Sughran Bibi Wife of Muhammad Aslam Resident of House No. 6, Mian Meer Pind, Dharampura, Lahore.
3. Sadiq Son of Babu Lal Resident of House No. 6, Mian Meer Pind, Dharampura, Lahore.
4. Plaintiff herself as witness will corroborate the contents of the plaint.
The witnesses will support the version of the plaintiff.
Plaintiff
through
Advocate High Court