Suit For Dissolution of Marriage (KHULA)

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 , RECOVERY OF DOWERY ARTICLES, IN ALTERNATIVE ITS PRICE, RS. 3,15,200/-

Respectfully Sheweth:

1. That  the  Plaintiff  was  married  with  defendant  on  14-12-2012 in  accordance  with  Muslim  Family Laws  and  Shariat-e-Muhammadi in consideration of dower amount of Rs 5,000/- which is still out standing against the defendant.

2. That after marriage the plaintiff joined the defendant as his wife and performed matrimonial obligations of her part and the behavior of the defendant towards the Plaintiff remained cordial for few months, thereafter the defendant started picking quarrels with the  Plaintiff  on one or the other pretext without any rhyme, reason and legal justification, furthermore the defendant failed to provide the maintenance even the basic necessities of life, and the Plaintiff being an Eastern women tolerated the behavior / mall treatment of the defendant to save the marital tie and also for the sake of the prestige of her family.

3. That the defendant on 21-12-2013 expelled the plaintiff from his house in three wearing apparels after snatching all the gold ornaments and dowry articles worth Rs. 3,15,200/- since then the Plaintiff residing with her parents at the given address and all the maintenance and expenses of the Plaintiff  are being borne by the parents / brothers of the Plaintiff.
4. That at the time of marriage ceremony the plaintiff was given dowry articles including the gold ornaments valued Rs. 3,15,200/- by her parents as per list attached as Annexure “A” which are also lying with the defendant at his house and at the time of her desertion the plaintiff was not allowed to take single item / article out of the same.
5. That the defendant even during the period of Abadi failed to maintain the Plaintiff and the Plaintiff had to obtain money from her parents to meet the expenses of her basic necessities. It is pertinent to mention here that the Plaintiff was not even allowed to meet or visit the house of her close relatives. It is worth mentioning here that the life of the Plaintiff was made bad to worst by the defendant and his family members.

6. That due to the maltreatment, misconduct, harsh / cruel attitude, non maintenance and misbehavior of defendant, the  Plaintiff  has  developed  such  a hatred  against  the  Defendant  that  it  has  become  impossible  for  the  Plaintiff to  reside  with  the  Defendant  as his wife within  the  limits  prescribed by  ALMIGHTY ALLAH and the  Plaintiff  seeks  dissolution  of  her  marriage  on  the  basis  of  KHULA  and  is  ready  to  forego  her  right  of  Dower and maintenance. 
7. That  the  Plaintiff  asked  the  Defendant  to  dissolve the marriage and to give the divorce to the Plaintiff in writing and to return all the dowry articles and gold ornaments as per list attached as Annexure “A” but  the Defendant refused to do so,  hence  this  suit .
8. That the cause of action accrued to the Plaintiff firstly on 21-12-2013 when the Plaintiff  was turned out in wearing apparels after snatching all the said dowry articles and gold ornaments as per list attached and lastly three days ago when the defendant flatly refused to give divorce in writing and to return the said dowry articles and gold ornaments as per list “Annexure A” the same is continuing.

.     That the Plaintiff is residing at the given address in Rawalpindi and the marriage of the Plaintiff was also solemnized here in Rawalpindi, hence this Honourable Court has got jurisdiction to entertain the suit and adjudicate upon the matter.

    .                   That the prescribed Court fee of Rs.15/= has been affixed on the plaint.

It is, therefore, respectfully prayed that the suit of the Plaintiff may very kindly be decreed with costs as follows:-

a.         For dissolution of marriage on the basis of “Khula”, may kindly be passed in favour of the Plaintiff against the defendant.

b.         For the recovery of dowry articles as per list attached as  “Annexure A” or in alternative its price Rs. 3,15,200/-

Any other relief which this Honourable court deems fit and proper may also be granted to the Plaintiff.

                                                                    Plaintiff  

Through:

Name of Advocate / Lawyer,

     Advocate High Court

Verification:

Verified on oath at Rawalpindi this on ____ day of March, 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