Legal Drafting HW2

IN THE COURT OF CIVIL AND FAMILY JUDGE,
KARACHI (EAST)
Family Suit No. of 2014
Sonia Shah ,Muslim ,Adult

daughter of Muhammad Talib Ali,
resident of A- 53, Pioneer Park City,
Gulstan-e-Juahar, Block 8,
Karachi ..….. . . . . . . . . . . Plaintiff
Versus
Irtaza Habib
son of Syed Nisar Ali Hashmi
resident of B-09,
Shaheen Complex,
Karachi. . . . . . . . .…………. Defendant
Abdullah son of Irtaza habib aged 8 years

Hamza son of Irtaza Habib aged 3 years……Minors
SUIT FOR DISSOLUTION OF MARRIAGE

BY WAY OF KHULA ,RETURN OF DOWRY
ARTICLES,BRIDAL GIFTS, PAST AND FUTURE
MAINTENANCE.
It is respectfully submitted on behalf of the Plaintiff named
above, as under:
1) That the Plaintiff is a law abiding citizen of Pakistan and
belongs to an educated and respectable family that enjoys
high esteem and good reputation in the society.
2) That the plaintiff was married with defendant on 10-12-2012
according to Sunni Muslim law, against a deferred dower
amount of Rs.50,000/- (Rupees fifty thousand), which has
not been paid to the plaintiff, and out of this wedlock two
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sons namely Abdullah, aged 08 years, and Hamza, aged 03
years, were born.
3) That the marriage between the plaintiff and the defendant
was an arranged one and the initial 4 years of the marriage
passed smoothly. However, thereafter the Defendant’s
attitude towards the plaintiff became indifferent and with the
passage of time his behavior worsened which gave rise to
serious irreconcilable differences between the parties and
this made the life of the Plaintiff miserable.
4) That the Defendant used to torture the Plaintiff mentally and
even physically abused the Plaintiff on petty issues which
were not tolerable in any way but the Plaintiff bore all this
humiliating attitude of the Defendant for the sake of her
children so that they may not be deprived of the love and
affection of their father, but few days ago defendant kicked
out plaintiff from his house with children and plaintiff is now
residing at her father’s house with minors and all expenses
of plaintiff and children are bored by plaintiff’s father.
5) That at the time of marriage of plaintiff with the defendant,
the dowry articles were given by the parents of the plaintiff
to the plaintiff amounting to Rs. 4,00,000/-, list of which was
prepared at the time of rukhsati and the same was duly
acknowledged by the father of the defendant. Photo copy of
List of jehaiz articles , and other items including bridal gits
given to the plaintiff are attached hereto and marked as
annexure “A”
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6) That the at the time of marriage the Plaintiff was given heavy
and expensive gifts which are in the possession of
defendants and he is not in mood to return.
7) That for the last six months the plaintiffs is residing at her
father’s house no any maintenance is given to defendant
neither to children all the expenses of children are bored by
plaintiff's father, the minor No.1 is school going his past 3
months school fees is due and from past 3 months the
minors No.2 is sick and all medical expenses are bored by
plaintiff's father here is the list of medical expenses of both
minors:
Expenses of Minor No. 1
School Fees: 6000
Qari sahib Fees: 1500
Milk per month: 4500
Lunch at school: 1500
Medication and misc expenses: 5000.
Total = 18500
Expenses of Minor No.2
Diaper per month: 3000 per month
Hospital treatment: 30000
Ors Misc. Expenses and daily routine expenses: 4000
Total= 37000
8) That for the facts and circumstances, mentioned
hereinabove, and because of the unwarranted, insulting,

4
and cruel attitude of the defendant, and due to the ordeal
faced by the Plaintiff, she has developed extreme dislike and
hatred against the Defendant and therefore, the Plaintiff
cannot live with the Defendant as a wife under the
prescribed limits of Almighty Allah. Hence, this suit.
9) That the plaintiff is ready to forgo dower in lieu of Khula.
10) That the Plaintiff is residing at Karachi within the limits of
Gulistan-e-Johar, Block 8, Police Station and therefore, this
Hon'ble Court has jurisdiction to adjudicate upon this matter.
11) That the prescribed Court Fees has been affixed
accordingly.
PRAYER
it is therefore, most respectfully prayed in the interest of
Justice, equity and good conscience by the above named plaintiff
that this Hon'ble Court may be pleased to pass Judgment and
Decree in favour of the Plaintiff and against the Defendant as
follows:-
a) A decree to dissolve the marriage of the plaintiff by way of
Khula on the grounds of cruelty and non-maintenance.
b) Recovery Dowry articles and Bridal gifts
c) Past and Future maintenance
d) Any other additional relief(s) as this Hon’ble Court may
deem fit in the circumstances of the case.

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e) Award costs of the suit.
Karachi. PLAINTIFF
Dated: 15-1-2014
ANNEXURE “A”
S.No Items Amount
01 Gold Set 4,00000
02 Room Set 250000
03 Bridal Gifts 100000+
04 Electronic Home 300000

Appliances
05 Crockery Items 50000

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IN THE COURT OF CIVIL AND FAMILY JUDGE,

Family Suit No. of 2014

Sonia Shah ,Muslim ,Adult

Abdullah son of Irtaza habib aged 8 years

SUIT FOR DISSOLUTION OF MARRIAGE

It is respectfully submitted on behalf of the Plaintiff named

1) That the Plaintiff is a law abiding citizen of Pakistan and

belongs to an educated and respectable family that enjoys

high esteem and good reputation in the society.

2) That the plaintiff was married with defendant on 10-12-2012

according to Sunni Muslim law, against a deferred dower

amount of Rs.50,000/- (Rupees fifty thousand), which has

sons namely Abdullah, aged 08 years, and Hamza, aged 03

years, were born.

3) That the marriage between the plaintiff and the defendant

was an arranged one and the initial 4 years of the marriage

passed smoothly. However, thereafter the Defendant’s

attitude towards the plaintiff became indifferent and with the

passage of time his behavior worsened which gave rise to

serious irreconcilable differences between the parties and

this made the life of the Plaintiff miserable.

4) That the Defendant used to torture the Plaintiff mentally and

even physically abused the Plaintiff on petty issues which

humiliating attitude of the Defendant for the sake of her

children so that they may not be deprived of the love and

affection of their father, but few days ago defendant kicked

residing at her father’s house with minors and all expenses

of plaintiff and children are bored by plaintiff’s father.

5) That at the time of marriage of plaintiff with the defendant,

the dowry articles were given by the parents of the plaintiff

to the plaintiff amounting to Rs. 4,00,000/-, list of which was

prepared at the time of rukhsati and the same was duly

acknowledged by the father of the defendant. Photo copy of

List of jehaiz articles , and other items including bridal gits

given to the plaintiff are attached hereto and marked as

and expensive gifts which are in the possession of

defendants and he is not in mood to return.

father’s house no any maintenance is given to defendant

neither to children all the expenses of children are bored by

plaintiff's father, the minor No.1 is school going his past 3

months school fees is due and from past 3 months the

minors No.2 is sick and all medical expenses are bored by

plaintiff's father here is the list of medical expenses of both

Expenses of Minor No. 1

School Fees: 6000

Qari sahib Fees: 1500

Milk per month: 4500

Lunch at school: 1500

Medication and misc expenses: 5000.

Expenses of Minor No.2

Diaper per month: 3000 per month

Hospital treatment: 30000

Ors Misc. Expenses and daily routine expenses: 4000

8) That for the facts and circumstances, mentioned

hereinabove, and because of the unwarranted, insulting,

and cruel attitude of the defendant, and due to the ordeal

faced by the Plaintiff, she has developed extreme dislike and

hatred against the Defendant and therefore, the Plaintiff

cannot live with the Defendant as a wife under the

prescribed limits of Almighty Allah. Hence, this suit.