IN THE COURT OF FAMILY JUDGE DADU.
Family Suit No: of 2016
Mst: Tahira Naz daughter of
Ghulam Shabir, By caste Panhwar, Muslim, Adult, Resident of Housing Society Daro
Union council N. 4 Road Taluka & District Dadu-----------------------------------------------------------Plaintiff.
Versus
Ali Mohammad son of Shafi Mohammad, By caste Shaikh,
Muslim, Adult, Resident of Village Waleed Shaikh Daro Union Council Mondar Taluka
& District Dadu
SHO P.S B Section ---------------------------------------------------Defendant
SUIT FOR DISSOLUTION OF MARRIAGE
ON THE BASIS OF GROUND OF KHULLA,
MAINTENANCE & RECOVERY OF DOWRY
ARTICLES.
The
plaintiff named above respectfully submits as under:-
1. That the parties are Muslims.
2. That the defendant has Kiryana Shop and earns about
30,000 Rs per month.
3. That the plaintiff was married with the defendant on 06.01.2016
at Dadu according to Muslim Law against the dower amount of Rs.50,000/-, which
has not been paid by the defendant to the plaintiff.
4. That out of this wed lock Plaintiff was Pregnant but
due to violence of defendant, the Pregnancy of 6 weeks were expired.
5. That after the Nikah Rukhsati took place and the
plaintiff started living with the defendant as his legally wedded wife. The
defendant maintained the plaintiff for some time, but after that the defendant
failed to maintain the plaintiff properly and maltreated the plaintiff on petty
matters. He used to torture her physically and mentally.
6. That after one month of marriage the defendant at the
instance of his parents after maltreating the plaintiff drove her away from his
house in three clothes asking her that she is not more wanted to the defendant.
7. That at the time of marriage the parents of the
plaintiff had given her articles of DOWRY (DAJ) which the defendant did not
return to the plaintiff. All the Dowry articles are lying in the house of the
defendant. Inspite of the repeated demands by the plaintiff. The defendant did
not return the dowry articles to the plaintiff.
8. That the defendant did not allow the plaintiff to
visit her parents. The plaintiff complained the behavior of the defendant to
her parents, and asked the defendant to maintain properly, but he did not pay
any head. Inspite of that the defendant took the plaintiff and kept her in
Village Waleed Shaikh Daro, and asked her that she is not more wanted to him.
9. That the plaintiff is living with her parents since
last one month and the defendant was
failed to maintain her and he has never visited nor he has performed marital
obligation with her.
10. That the parties can not live as husband and wife any
more within the Limits prescribed by God. Hence this suit.
11. That the cause of action arisen to the plaintiff to
file suit in the month of February, 2016 when the defendant left the plaintiff
at her parents house in three clothes asking her that she is not more wanted to
him.
12. That the cause of action and the parties are reside
within the jurisdiction of this Honourable court, therefore, this Honourable
court has the jurisdiction to entertain the suit.
13. That for the purpose of court fee. The court fees of
Rs.15/- is affixed on the plaint.
14. That the plaintiff prays for Judgment and decree as
under:-
a) That the Honourable court may kindly be pleased to decree the suit against he defendants and
dissolve the marriage of the plaintiff on the ground of Khulla.
b) The defendant may be directed
to pay maintenance allowance at the rate of Rs.10000/- per month from the month
of January 2016 till the decision of the suit.
c) That the defendant may be
directed to return the Dowry articles to the plaintiff according to the list of
Dowry articles.
d) Costs.
e) Any other relief which the court deems fit and fair be granted to the
plaintiff.
Plaintiff.
Dadu.
Dated: .
.2016. Advocate
For plaintiff.
VERIFICATION
I, Mst: Tahira daughter of Ghulam Shabir, by caste Panhwar, Muslim,
Adult, Resident of Housing Society Daro Road Dadu Town, do hereby verify on
oath that whatever is stated in the plaint from para No:1 to 14 is true and
correct to the best of my knowledge and belief.
Verified
this the 10 th day of the month of March, 2016 at Dadu.
Deponent.
The
deponent is known to me and is identified by me to the commissioner for taking
affidavit.
Affirmed
ON SA before me. The deponent is identified by Mr. MUJJAN ALI PANHWAR, Advocate, who is known to me personally.
The
contents of the plaint were first truly and audibly read over and explained to
deponent that she understands well and he appears to have understood. She
admitted the contents of plaint to be true and correct and put her
signature/RTI on it in my presence.
Commissioner for taking affidavit
Documents filed Nil.
Documents relied upon. All the relevant documents concerning the
suit
will be produced lateron
Address of the parties is same as mentioned in the
title of the plaint.
Address of the counsel is same as shown in vakalatnama.
Advocate
For the plaintiff.
List of witnesses.
1)
Plaintiff herself.
2)
Mother of Plaintiff
3) Ghulam Qadir Shaikh
Note:- All the
witnesses will support the version of the plaintiff.
Advocate
For the
plaintiff.
IN THE COURT OF FAMILY JUDGE, DADU.
Family Suit No: of 2016
Mst:Tahira Panhwar-----------------------------------------------------Plaintiff.
Versus
Ali Mohammad
Shaikh------------------------------------------------Defendant
AFFIDAVIT
I,
Mst: Tahira daughter of Ghulam Shabir, By caste Panhwar, wife of Ali Muhammad,
Muslim, Adult, Resident of Housing Society Daro Dadu Town, Taluka &
District Dadu, do hereby state on oath as under:-
1. That
I am plaintiff in the above matter and know the facts very well.
2. That
I contracted marriage with defendant took place about 3 months back according
to Muhammadan law.
3. That
the averments of the suit may be treated as part and parcel of this affidavit.
4. That
whatever is stated above is true and correct to the best of my knowledge and
belief.
Deponent.
I know the deponent.
Advocate
Dadu.
IN THE COURT OF FAMILY JUDGE DADU.
Family Suit No:
of 2016
Mst: Tahira
naz----------------------------------------------------------Plaintiff.
Versus
Ali
Mohammad--------------------------------------------------------Defendant
LIST
OF DOWERY ARTICLES
1: Almirah amounting to Rs: 8000/:
2: Big Iron Box
amounting to Rs: 5000/:
3: Padestal fan amounting to Rs: 3000/:
4: Two Cots amounting to Rs:
4000/:
5: Utensels amounting to Rs:
30,000/:
6: 20 Rillies amounting to Rs: 15000/:
Total:
65000/:
Dadu.
Dated: Advocate
For the Plaintiff.
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