IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF JUDGE FAMILY COURT, LAHORE.
Mst. ___________ Daughter of ___________ Wife of ___________, Caste ___________, R/o ___________, Tehsil ___________, District ___________, presently residing at ___________, Lahore.
….Plaintiff
V E R S U S
___________ Son of ___________, Caste ___________, R/o ___________, Mouza ___________, Tehsil ___________, District ___________.
….Defendant
SUIT FOR JACTITATION OF MARRIAGE
Respectfully Sheweth:-
1. That the plaintiff belongs to a respectable family and is residing on the above given address.
2. That the plaintiff has contracted marriage with his cousin Muhammad Imran Son of Muhammad Usman, Caste Kanjan, R/o Bhamb, Tehsil Mankera, District Bhakkar, on 24.08.2008 with her free will and consent according to Muhammadan Law. Copy of nikah nama is attached herewith for the kind perusal of this Honourable Court.
3. That the plaintiff started residing with Muhammad Imran as her wife, when this thing came in the knowledge of her family they became inimical towards the plaintiff and her husband and they have threatened that they will kill both of them and have attempted to abduct her from her house on 25.08.2008 but after the intervention of the people of the locality they left the house of the plaintiff.
4. That afterwards the family of the plaintiff has prepared a forged and fictitious nikah nama of the plaintiff with the defendant dated 25.07.2008 and have made her forged signatures on the nikah nama.
5. That no nikah was took place between the parties and the plaintiff is not wife of the defendant, if there is any nikah nama, it is a forged and fabricated document which has no value in the eye of law and the plaintiff is not wife of the defendant. That the plaintiff not appeared before any nikah khawan and nikah registrar and the nikah ceremony never took place, it is a false and concocted story which has been narrated by the defendant in order to blackmail and harass the plaintiff.
6. That the act of the defendant is malafide, illegal, unlawful and is the result of misfenace of the defendant and the learned court has ample power to give the relief to the plaintiff and protect the right and title of the plaintiff.
7. That the plaintiff has no other remedy except to file the present suit in order to protect her right and title.
8. That the cause of action accrued in favour of the plaintiff on 26.08.2008 when the defendant registered a forged FIR that her wife has been abducted, secondly on the refusal of the defendant to accept the genuine request of the plaintiff to restrain and pose himself as husband of the plaintiff and is still accruing on the refusal of the defendant.
9. That the plaintiff is residing at Lahore. Hence this Honourable Court had got jurisdiction to adjudicate upon the matter.
10. That requisite court fee has been affixed on the plaint.
P R A Y E R
It is, therefore, most respectfully prayed that a decree for jactitaion of marriage may kindly be passed in favour of the plaintiff and against the defendant declaring that the plaintiff is not legally wedded wife of the defendant and the alleged nikah nama is a forged and fabricated document.
Any other relief this Honourable Court may deem fit may also be awarded with cost of the suit.
Plaintiff
through
Advocate High Court
VERIFICATION
Verified on oath at Lahore this 23rd day of September 2008 that the contents of paras No. 1 to 7 are correct to the best of my knowledge and remaining paras No. 8 to 10 are true to the best of my belief.
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