IN THE COURT OF SENIOR CIVIL/FAMILY
JUDGE LAHORE.
Shabana Ajmal daughter of Muhammad Ajmal , G-11/3
Islamabad
Plaintiff
Versus
Muhammad Mosin son of Shehbaz Hussain Resident of E-11/2
Islamabad
Defendant
SUIT FOR DISSOLUTION OF MARRIAGE ON THE
BASIS OF KHULA
Respectfully Sheweth : -
1. That the plaintiff was married with the defendant in
accordance with Muslim rites on 10 june 2018 and a
sum of rupees 500,000 /- as prompt dower which still
has not been paid by the defendant to the plaintiff,
copy of nikah nama is enclosed (AS ANNEXURE A).
2. That out of this wedlock no child was born .
3. That the relation between the spouses remained
cordial only few days in the beginning of of the
marriage and after that defendant start beating the
plaintiff on very common house hold matters.
4. That the attitude of the defendant and his family was
very cruel and harsh arrogant and unreasonable
towards the plaintiff, he started making demands
from the plaintiff to bring money form her parents and
on the refusal of the plaintiff he used to beat the
plaintiff mercilessly.
5. That despite the physical and mental torture given to
the plaintiff by the defendant, the plaintiff tried her
level best to reconcile the matter for the sake of her
matrimonial life but the behavior of the defendant
became more harsh and cruel on on 05-09-2014 the
defendant deserted the plaintiff from his house in
wearing apparels only after giving severe beatings to
the plaintiffadn since then the plaintiff is residing on
the above mentioned address without being
maintained by the defendant.
6. That the defendant habitually assaulted the plaintiff
and made her life miserable by cruelty of act and
conduct as she was unable to fulfill the illegal and
immoral demands of the defendant.
7. That the defendant is in the habit of intoxication and
is also involved in criminal activities.
8. That the defendant has never maintained the plaintiff
and they are making their both ends meet by the help
of parents of plaintiff.
9. That due to the attitude of the defendant the plaintiff
has got fixed aversion in her mind against the
defendant and it is now impossible for the plaintiff to
live with the fefendant as his legally wedded wife , as
such the plaintiff seeks dissolution of her marriage on
the ground of * KHULLA * also .
10. That the cause of action has arisen in favour of
the plaintiff and against the defendant firstly at the
time of solemnization of marriage between the
plaintiff and the defendant, secondly in 05-09-2019
when the plaintiff was ultimately deserted by the
defendant from his house after giving severe
beatings to the plaintiff, hence the cause of action is
still continuing to occure.
11. That the plaintiff is now residing at Lahore , so this
honoura ble court has got th entire jurisdiction to
adjudicate upon the matter.
12. That the appropriate court fee has been affixed on
the plaint for the satisfaction of the court.
PRAYER :
In view of the above mentioned facts and
circumstances, it is most respectfully prayed that the
titled suit may very kindly be decreed in favour of the
plaintiff and against the defendant on the
following terms : -
A decree for dissolutionof marriage may kindly be
passed in favour of the plaintiff and against the
defendant with costs.
Any other relief , which this honourbale court deems fit
and proper, in the circumstances of the case, may also
be awarded in favour of the plaintiffs.
Plaintiff
Verification
Verified on oath today the 10th Day of February 2015 that
the Contents of the above paras are True and correct to
the best of my Knowledge and nothing has been
Concealed.
Plaintiff
Through :-
Zohaib Hassan Shah
Advocate High Court
Judicial Complex Islamabad
