Suit for Dissolution of Marriage (Before Consummation Of Marriage) (Rukhsati)

IN THE COURT OF LEARNED JUDGE, FAMILY COURT, RAWALPINDI.

Mst.  ABC d/o DEF w/o XYZ, Resident of House No. 84 Street. No. 12, Block No. B, Satellite Twon, Rawalpindi.

       Plaintiff …………………

                                                                        Vs.   

XYZ s/o WXY  Resident of House No. 85 Street. No. 10, Block No. D, Satellite Twon, Rawalpindi.

Defendant………

SUIT FOR DISSOLUTION OF MARRIAGE (Before Rukhsati)(Before Consumation of Marriage)

Respectfully Sheweth:

1. That  the  plaintiff  was  married  with  defendant  on  26-02-2013 in  accordance  with  Muslim  Family Laws  and  Shariat-e-Muhammadi in consideration of dower amount of Rs 50,000/-  which has not yet been paid to the Plaintiff by the Defendant.

2. That only the Nikah ceremony of the Plaintiff with defendant took place on 26-02-2013, and the marriage was not consummated as no Rukshati has yet been taken place.

3. That at the time of Nikah ceremony the defendant told the plaintiff that he is residing and serving in Sharjah, UAE and his monthly salary in Pakistani currency is Rs. 90,000/- and the defendant also stated himself to be M.A in qualification, which later on proved to be false one as the defendant is neither residing / serving in Sharjah  nor he is M.A in qualification, rather it is revealed that the defendant is not a man of good conduct and is not serving anywhere and has no source of income at all, rather the defendant uses to sit idle.
4. That after the Nikah the defendant took the gold ear rings of the plaintiff on the pretext that he is in need of some money and also promised to prepare another  good pair of ear rings for the plaintiff but  the defendant could not fulfill his promise, rather sold the said ear ring of the plaintiff and did not return the same till date. It is pertinent to mention here that the defendant also started to demand a New Toyota Car and a well furnished house in dowry, which facts also show the greedy nature of the defendant.

5. That the defendant about one month after the Nikah also started to put certain restrictions upon the plaintiff, to leave her job of Office Executive in advertising company “Soft Media Adevertiser”, Rawalpindi, Pakistan and also that after Rukshati the plaintiff shall have to leave her parents and other close relatives including her real maternal aunt where the plaintiff is residing, for ever. The defendant on the refusal of the plaintiff to accede his said illegal and frivolous demands / restrictions, became very furious and started to abuse plaintiff and her parents with bad names on telephone.

6. That the plaintiff due to the above said fraudulent conduct, misbehavior and greedy nature  of the defendant, has created such a hatred in her mind and it has become impossible to live with the defendant  (after the Rukshati) as his wife within the prescribed limits of all Mighty Allah. The plaintiff also seeks dissolution of her marriage (Nikah) even on the basis of Khula in order to get writ of said dread full tie and the plaintiff is ready to forgo her right of dower.

7. The plaintiff a week ago asked the defendant to divorce the plaintiff but the defendant flatly refused to do so, rather threatened the plaintiff for dire consequences in case the plaintiff seeks dissolution of marriage (Nikah) through court, hence this suit.

8. That the cause of action accrued to the plaintiff as against the defendant firstly when the plaintiff came to know about the fraudulent conduct, greedy nature and also about  illegal and frivolous demands / restrictions and finally a week ago when the defendant flatly refused to divorce the plaintiff and the same is continuing.

8. That the plaintiff is residing at the given address in Rawalpindi, hence this Honourable Court has got jurisdiction to entertain the suit and adjudicate upon the matter.

9.            That the prescribed Court fee of Rs.15/= has been annexed with the plaint.

It is, therefore, respectfully prayed that a degree for dissolution of marriage on the basis of khula may kindly be passed in favour of the plaintiff against the defendant with costs.

                                                                                    Plaintiff

                                                             

Through:

  Name of Advocate / Lawyer,

     Advocate High Court

Verification:

Verified on oath at Rawalpindi this 2nd May, 2014

that the contents of paras from 1 to     are true and

correct to the best of my knowledge and belief

and the remaining Paras are believed to be true

and correct through information received by me.

Plaintiff