Khulla Suit

Advocate High Court
AMC LAW CHAMBER

2-Mozang Road, Lahore.
VERIFICATION:
Verified on oath at Lahore on this day of 3 rd June, 2024 that the contents of
Para 1-11 are correct to the best of my knowledge and those remaining Para No
9-11 are correct to the best of my belief.
Plaintiff
IN THE COURT OF LEARNED SENIOR CIVIL JUDGE WITH POWERS OF

JUDGE FAMILY COURT, LAHORE.
Family Suit No. ___________/ 2024
MST MARIAM ALI IJAZ VERSUS ALI IJAZ
(SUIT FOR DISSOLUTION OF MARRIGE, RECOVERY OF MAINTENACE AND DOWER

(7 TOLA GOLD ORNAMENTS) AND DOWERY ARTICLES OR ITS PRICE OF AROUND
Rs 3,000,000/-)
LIST OF WITNESS ON BEHALF OF PLAINTIFF
1. Lt. Col (R) Raja Fazal Mehdi, father of plaintiff. R/O House 499, Sector C,
Askari 10, Lahore.
2. Raja Ameer Muzzamil Mehdi, Brother of Plaintiff. R/O House 499, Sector C,
Askari 10, Lahore.
3. Plaintiff herself.
Page 1 of 6
SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULA AND
RECOVERY OF DOWRY ARTICLES AS PER LIST APPENENDED :
Respectfully Sheweth:
1. That the above addresses of the parties, as supplied above, are sufficient
for the service of summons and notices.
2. That the plaintiff is a law abiding, honest and well-educated citizen of

Pakistan who hails from respected family. Having successfully completed
her education, the plaintiff conferred with a Bachelor of Science (BS
Biochemistry and Biotechnology). Following the accomplishment, the
plaintiff passed CSS exams and is a gazetted officer, currently serving as
Additional Collector of Customs (OPS)in Pakistan Customs Services.
3. That the Defendant is serving in the Federal Board of Revenue and is a BS

-19 civil servant with a handsome monthly salary, allowances and income
from other sources.
4. That marriage between the plaintiff and defendant No.01 was officially
solemnized on 30-06-2011 in accordance with Sharia and the laws of the
country.
[Copy of Nikahnama is attached here as an Annex A]
5. That after the marriage the plaintiff started to perform her matrimonial
obligations with the defendant but with the passage of time it transpired
Page 2 of 6
to the plaintiff, that the defendant is a not interested to pursue this
marriage but the plaintiff in order to maintain and sustain tried her level
best and bear all the hurdles so that the matrimonial life of the plaintiff be
maintained but no avail.
6. That out of this wedlock, the plaintiff No.01 was blessed with two
daughters and with two sons.
[Copy of birth certificates of all the plaintiffs is attached here as

Annex-B]
7. That the Plaintiff maintained herself with her pay from the marriage till
now and as and whenever, Defendant did not bear any personal expanse
of the plaintiff. It is significant to note that the Defendant, although having
sound financial capacity, has utterly failed to realize his religious, moral
and legal obligations to provide maintenance to the Plaintiff and her
children. Plaintiff, for her own person as well as for the Minors, has
unwaveringly assumed all the financial responsibilities despite the
apparent financial constraints and continues to do so till date.
8. That it came to the knowledge of plaintiff, the defendant has no concern

or concentration towards the minor plaintiffs even to some extent he is
not able to perform his matrimonial/ parental obligations.
Page 3 of 6
9. That the plaintiff requested the defendant to mend his ways on numerous
occasions. Plaintiff also consulted and requested the mother and close
family members of defendant to exercise their influence on defendant to
mend his ways so this marriage could be salvaged but instead defendant
and his family started isolating, targeting, harassing the plaintiff by
continuously picking up fights and construing things that never took place.
The arguments by the defendant resulted in physical, mental, verbal,
psychological and emotional abuse of plaintiff. The defendant kicked the
plaintiff from his house on 26-01-2024 and since then the plaintiff along
with her children is residing with her parents.
10. That the defendant has a behavioral pattern of bipolar tendencies

and switches to a barbaric natured person whenever he pleases. He
always treated the plaintiff no.1 with habitual careless neglect,
condescend and distance and thus made the life of the plaintiff extremely
miserable.
Dowry Articles:
11. That at the time of marriage the parents of the plaintiff gave
precious dowry articles to the plaintiff as per list appended with plaint
valuing Rs.2,000,000- 3,000,000 /-, which are in the possession of the
defendant. Copy of list of dowry articles is attached for the kind perusal of
this Honourable Court.
Page 4 of 6
List of Dowry Articles:
1) Bed set along with side tables.
2) Dressing table.
3) Bedroom chairs & table.
4) Tv console.
5) AC.
6) Curtains, Carpets, Table Lamps.
7) Dinning Sets and crockery.
Gold:
One gold set (7 Tolas), in mother in law’s lockers.
12.That due to above mentioned facts and circumstances, as well as the

atmosphere created by the defendant, great hatred has been developed
in the heart of plaintiff towards defendant and the plaintiff cannot live
with the defendant as his wife, there is no scope left for the parties to
Page 5 of 6
lead a harmonious life in future, within the limits prescribed by Law,
therefore, the plaintiff seeks dissolution of marriage on the basis of
KHULA along with return of afore mentioned dowry items and gold set.
PRAYER:
In view of the above submissions, it is therefore, most respectfully

prayed that a decree for dissolution of marriage on the basis of Khula
may kindly be passed in favor of the plaintiff and against the defendant.
It is further prayed that a decree for recovery of dowry articles and

gold set as per list appended with plaint or its alternative amount of
Rs.5,000,000/- (including the value of gold set) may kindly be passed in
favor of the plaintiff and against the defendant, in the interest of justice.
Any other relief which this Honourable Court deems fit may
also be awarded.
Plaintiff
Through counsel
ABDUL MAJID CHOUDHRY
Advocate High Court
HAFIZ TALHA RANA
Advocate
Page 6 of 6

Khulla Suit

Uploaded by

Copyright:

Available Formats

Khulla Suit

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Khulla Suit

Uploaded by

Copyright:

Available Formats

Advocate High Court

AMC LAW CHAMBER

IN THE COURT OF LEARNED SENIOR CIVIL JUDGE WITH POWERS OF

Family Suit No. ___________/ 2024

MST MARIAM ALI IJAZ VERSUS ALI IJAZ

(SUIT FOR DISSOLUTION OF MARRIGE, RECOVERY OF MAINTENACE AND DOWER

LIST OF WITNESS ON BEHALF OF PLAINTIFF

2. That the plaintiff is a law abiding, honest and well-educated citizen of

3. That the Defendant is serving in the Federal Board of Revenue and is a BS

[Copy of Nikahnama is attached here as an Annex A]

[Copy of birth certificates of all the plaintiffs is attached here as

8. That it came to the knowledge of plaintiff, the defendant has no concern

10. That the defendant has a behavioral pattern of bipolar tendencies

1) Bed set along with side tables.

3) Bedroom chairs & table.

6) Curtains, Carpets, Table Lamps.

7) Dinning Sets and crockery.

One gold set (7 Tolas), in mother in law’s lockers.

12.That due to above mentioned facts and circumstances, as well as the

In view of the above submissions, it is therefore, most respectfully

It is further prayed that a decree for recovery of dowry articles and

Advocate High Court

HAFIZ TALHA RANA

You might also like