Correction of Nikah Nama (Civil Suit)

IN THE COURT OF LEARNED SENIOR CIVIL JUDGE, RAWALPINDI

Mst. ABC D/o DEF W/o XYZ R/o House No. 111, Street No. 1, Satellite town, Rawalpindi.

Plaintiff

Versus

1. XYZ S/o JKL R/o House No.      111, Street No. 1, Satellite Twon, Rawalpindi.
2. MNO, Nikah Khawan / Nikah Registrar Union Council No. 111, R/o Satellite Town, Rawalpindi.
3. Nazim Union Council No. 111, Satellite Twon, Rawalpindi.
4. Secretary Union Council No. 111 Satellite Twon, Rawalpindi.   

Defendants

SUIT FOR DECLARATION AND MANDATORY INJUNCTION(Correction of Nikah Nama)

Respectfully Sheweth:-

1.         That the marriage of the Plaintiff with the Defendant No. 1 was solemnized according to Shariat-e-Muhammadi and Muslim family laws on 15-02-2014, in consideration of dower amount of Rs. 500,000/- to be paid on the demand which amount of dower has not yet been paid to the Plaintiff by the Defendant No. 1.

2.         That the Nikah of the Plaintiff with the Defendant No. 1 was solemnized / recited and got registered by the Defendant No. 2 being Nikah Khawan and Registrar of the constituency. Copy of the same is annexed herewith as Annexure-“A”.  

3.         That at the time of filling-in the Nikah Deed of  the Plaintiff with the Defendant No. 1. The columns No. 15 to 20 and 22 remained incomplete / blank / unattended by the Nikah Khawan / Nikah Registrar i.e Defendant No. 2. The Plaintiff asked the Defendant No. 2 to fill-in the said columns of Nikah Deed (Annexure –“A”) as under:-

a.         Column No. 15 :-        Nil

b.         Column No. 16 :-        Nil

c.         Column No. 17 : -      Rs. 3000/- per month as pocket money.

d.         Column No. 18 : -       Yes, as per Shariah and Muslim Family Laws. 

e.         Column No. 19 :-        Nil

f.          Column No. 20 :-        Nil

g.         Column No. 22 :-        Nil

           

4.         The Plaintiff asked the Defendants a number of times to do the needful as stated in para No. 3 supra and also to get the same incorporated in the relevant / concerned record so kept and maintained by the Defendant No. 3 and 4, but the defendants are adamant not to do so and now after adopting procrastinate attitude refused to do so, hence the suit.

5.         That the cause of action accrued to the plaintiff firstly on 15-02-2014 when the Nikah with the Defendant No. 1 was solemnized and then when the Defendant asked the Defendants No. 2 to 4 to do the needful as stated in para No. 3 supra and finally a week ago when the Defendants No. 2 to 4 flatly refused to accede the said genuine / lawful request of the Plaintiff and the same is continuing.

6.         That the parties are residing at the given respective addresses, the Nikah of the Plaintiff with the Defendant No. 1 was also solemnized and cause of action is also accrued here in Rawalpindi, hence this Honourable Court has got jurisdiction to entertain the suit and adjudicate upon the matter.

7.         That the suit valuation for the purpose of court fee and jurisdiction is fixed Rupees two thousand which is exempted from levy of court fee.

Prayer:

It is therefore respectfully prayed that a decree for Declaration to the effect that the columns No. 15 to 20 and 22  of the Nikah deed (Annexure A) of the Plaintiff with the Defendant had been rendered incomplete / blank / unattended by the Defendant No. 2 without any cogent reason and lawful justification and as a consequential relief a mandatory injunction directing the the Defendant No. 2 to fill-in the said columns No. 15 to 20 and 22 as per detail given in para No.3 supra and also to get the same incorporated in the relevant / concerned record so kept and maintained by the Defendant No. 3 and 4,  and after incorporating the needful in the said relevant record, issue the certified copies of the same to the Plaintiff, may kindly be passed in favour of the plaintiff against the defendants with costs .

Any other relief which with this Honourable court may deem fit and proper in the circumstances of the case may also be granted to the plaintiff against the defendants, in the interest of justice.

Plaintiff

                                                                        Through:

(NAME OF ADVOCATE / LAWYER)

Advocate High Court.

VERIFICATION:

Verified on oath at Rawalpindi on this 8^th day of

October, 2014 that the of contents Para No. 1 to 4

are true and correct to the best of our knowledge

and belief  and rest of the paras on the  information received.

                                    Plaintiff

           

IN THE COURT OF LEARNED SENIOR CIVIL JUDGE, RAWALPINDI

Mst. ABC                             Versus                          XYZ etc

                                                                                            

SUIT FOR DECLARATION

(Correction of Nikanama)

AFFIDAVIT

I, Mst. ABC D/o DEF W/o XYZ R/o House No. 111, Street No. 1, Satellite town, Rawalpindi , do hereby solemnly affirm and declare that the contents of above captioned Suit are true and correct to the best of my knowledge and belief and nothing has been concealed thereto.

DEPONENT

Further verified on oath this day of_____ October, 2014 at Rawalpindi that the contents of above said affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed thereto.

                                                DEPONENT