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Suit For Dissolution of Marriage

This is a court document filed by a woman seeking dissolution of her marriage through khula. She lists the mistreatment and lack of maintenance by her husband as reasons for seeking divorce. She is also asking the court to order her husband to return dowry items worth Rs. 1,790,000 that were given at the time of marriage but were not returned when she left the marital home.

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33 views4 pages

Suit For Dissolution of Marriage

This is a court document filed by a woman seeking dissolution of her marriage through khula. She lists the mistreatment and lack of maintenance by her husband as reasons for seeking divorce. She is also asking the court to order her husband to return dowry items worth Rs. 1,790,000 that were given at the time of marriage but were not returned when she left the marital home.

Uploaded by

trendingteam04
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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IN THE COURT OF X FAMILY JUDGE DISTRICT EAST KARACHI

Suit no 420/2024

Mst hira .w/O sarfaraz Khan,


Muslim, adult
resident of house no 5 lakhani plaza … … … … … … . Plaintiff

Versus
Sarfaraz Khan s/o waheed Khan,
Muslim, adult
resident of Gul plaza sadar Karachi … … … … … .. Defendant

Suit for dissolution of marriage by way of khula, return of dowry articles and
maintenance of minors
Facts
1. It is respectful submitted that the applicant is respectable citizen of Pakistan

2. That the Plaintiff was married with the Defendant on 14-12-2022 in


accordance with Muslim Family Laws in consideration of dower amount of
Rs. 200,000/- which is still outstanding against the Defendant.

3. That after marriage, the Plaintiff lived with the Defendant as his wife and
performed matrimonial obligations of her part and the behavior of
the Defendant towards the Plaintiff remained cordial for a few months;
thereafter, the Defendant started picking quarrels with the Plaintiff on one
or the other pretext without any rhyme or reason. Furthermore, the
Defendant failed to provide maintenance regarding even the basic
necessities of life. The Plaintiff tolerated the misbehavior / maltreatment of
the Defendant to save the marital tie.
4. That the Defendant on 21-12-2023 expelled the Plaintiff from his house and
forcibly restrained the Plaintiff from even taking her own belongings with
her. In particular, the Defendant did not allow the Plaintiff to take gold
ornaments and other dowry articles worth Rs1790000/- given by the
parents of the Plaintiff to her. Since the date of expulsion, the Plaintiff
along with the minor is residing at the given address and all the
maintenance and expenses of the Plaintiff and minor are being borne by the
parents and brothers of the Plaintiff.

5. That at the time of marriage ceremony the Plaintiff was given dowry articles
including gold ornaments valued at Rs. 1790000/- by her parents
which are lying with the Defendant at his house and at the time of her
expulsion, the Plaintiff was not allowed to take single item / article out of the
same.
(A list of the dowry articles is attached herewith as Annexure A).

6. That the Defendant even during the period of living together


failed to maintain the Plaintiff and minor and the Plaintiff had to obtain
money from her parents/brothers to meet the expenses of her basic
necessities And medical expenses of the minor. It is pertinent to mention
here that the Plaintiff was not even allowed to meet or visit the house of her
close relatives. The life of the Plaintiff was made miserable by the
Defendant and his family members.

7. That due to the maltreatment, misconduct, harsh / cruel attitude, lack of


maintenance and misbehavior of defendant, the Plaintiff has developed such
a hatred against the Defendant that it has become impossible for the Plaintiff
to reside with the Defendant as his wife within the limits prescribed by
ALMIGHTY ALLAH and the Plaintiff seeks dissolution of her marriage on
the basis of KHULA and is ready to forego her right of dower and
maintenance.
8. That the Plaintiff asked the Defendant to dissolve the marriage and to give
divorce to the Plaintiff in writing and to return all the dowry articles
including gold ornaments as prelist attached as Annexure A but the
Defendant refused to do so, hence this suit.
9. That the cause of action accrued to the Plaintiff firstly on 21-12-2023 when
the Plaintiff was turned out of the Defendant’s house along with minor and
was deprived of all the said dowry articles and gold ornaments as per list
attached and lastly one month ago when the Defendant flatly refused to give
divorce in writing and to return the said dowry articles and gold ornaments;
the cause of action is continuing.
10.That the Defendant is residing at the given address in Karachi and the
marriage of the Plaintiff was also solemnized here in Karachi , hence this
Honorable Court has got jurisdiction to entertain the suit and adjudicate
upon the matter.

It is, therefore, respectfully prayed that the suit of the Plaintiff may very
kindly be decreed infavour of the Plaintiff and against the Defendant as
follows:-

a. For dissolution of marriage on the basis of “Khula”.


b. For Giving maintenance and medical expenses of the minor
c. For the recovery of dowry articles as per list attached as Annexure A or in
the alternative, the Defendant be ordered to pay the price of the same
amounting to Rs. 1790000/-.
d. Costs: Any other relief which this Honorable Court deems fit and proper
may also granted to the Plaintiff.

Plaintiff

Annexure A
List of dowry articles
Dowry articles Price
Gold 300000
Mehran car (used) 500000
Double bed 100000
Bedding and 20000
Mattress
AC 150000
Refrigerator 50000
Washing machine 45000
Owen 50000
Wardrobe 30000
Dressing table 20000
LCD 45000
Blanket 10000
Utensils and 30000
kitchenware
Curtain 10000
3 Sofa set 80000
Dinning table and 150000
chairs
Designer clothes 200000

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