BEFORE THE JUDGE FAMILY COURT, RAWALPINDI

Mst. Hamna Ayaz wife of Sheikh Muhammad Ayaz resident of

House No. 4-A, Ghazi Road, Sadiqabad

.Plaintif
VERSUS

Sheikh Muhammad Ayaz son of Sheikh UmerIlyas Resident of

House No. 292, Street No. 18, Gulzar-e-Quaid, Rawalpindi

.Defendant

SUIT FOR DISSOLUTION OF MARRIAGE ON GROUNDS OF KHULA

AND RECOVEY OF DOWER AMOUNT

Respectfully Sheweth:

1. That the Plaintiff hails from a very renowned and noble family

and is a highly civilized lady. Plaintiff was married with

Defendant on 07-04-2014 at Rawalpindi in accordance with

Muslim Personal law of Shariah. Nikahnama was duly

registered with Nikkah Registrar at Union Council No. 34,

Bani, Rawalpindi. Out of this wedlock a daughter namely

Noor Fatima was born on 1st April 2015.

2. That dower was fixed as Rs. 50,000/- which is payable on

demand. No amount of dower has yet been paid and it is still

outstanding.

3. That soon after the marriage the behavior and conduct of

Defendant and his mother towards Plaintiff became cruel. He

 and her mother collectively used to keep her in continuous

mental and physical torture. He kept the plaintiff in wrongful

confinement and isolation and did not allow her to meet her

mother and other family members.

4. That on 6th day of May 2016 Defendant left the country and

went abroad probably to Canada, leaving plaintiff and her

daughter with his cruel mother. Despite the efforts, Plaintiff

is unable to trace Defendant and his address in abroad. She

is only aware of his last known address in Pakistan

mentioned above.

5. That mother of the Defendant tried to dispossess the Plaintiff

from her place of abode where she was living with her

husband whereupon Plaintiff was constrained to file suit for

permanent injunction and obtained stay order.

6. That now Defendants mother, taking the benefit of the

absence of Defendant from the country, and even against the

injunctive order issued by competent court, had forcibly

thrown Plaintiff and her about 18 months daughter out of the

marital home on 12-05-2016. Since then Plaintiff along with

her suckling baby is living with her parents. Defendant has

not contacted the Plaintiff through any mode.

7. That parents and respectable of the family intervened into the

matter and ultimately brother of Defendant executed an

 agreement dated 12-05-2016 whereby he gave articles of

dowry to Plaintiff and her parents. Only gold ornaments

weighing 2.75 tola which is still in the custody of Defendant

and his family member. Brother of Defendant took

responsibility to pay maintenance at the rate of Rs. 20,000/-

per month to the daughter of Plaintiff.

8. That in view of above said circumstances, Plaintiff has

developed acute hatred against the Defendant, therefore,

Plaintiff cannot live with defendant within the limits

prescribed by God hence she claims dissolution of marriage

on the ground of Khula. As per section 10 Plaintiff is ready to

forgo 25% of prompt dower. However, Defendant is under legal

obligation to pay the remaining amount of dower viz Rs.

37,500/-

9. That the cause of action is recurring one.

10. That prescribe court fee has been affixed on the plaint.

11. That cause of action accrued within the territorial

jurisdiction of this Honorable Court where also the marriage

took place and Plaintiff is also residing, hence this

Honourable Court has jurisdiction to entertain and try the

suit.
It is, therefore, respectfully prayed the decree for

dissolution of marriage on basis of Khula and recovery of

 75% of dower amount viz Rs. 37,500/- be passed in favor

of Plaintif as against the defendants with cost.

Plaintif

Through

MUHAMMAD ILYAS SHEIKH

ADVOCATE SUPREME COURT OF PAKISTAN

Verified on oath on this _____ day of _______, 2016 that the contents of the plaint are true
and correct to the best of knowledge and belief and nothing has been concealed or
withheld.

Plaintiff

Certificate:-
It is certified that no matter is pending adjudication between the same parties before any
court of law

Plaintiff