IN THE COURT OF SENIOR CIVIL JUDGE /
JUDGE FAMILY COURT (WEST), ISLAMABAD
Noureen Jam D/o Jam Niaz Ahmad Daragh R/o 1301-
First floor street No.31-E Sector I-10/4, Islamabad.
.…Plaintiff
Vs
Yasir Iqbal S/o Muhammad Nawaz R/o Kehkashan,
street No.2, New North Gulgasht Colony, Multan.
… Defendant
SUIT FOR DISSOLUTION OF MARRIAGE, RECOVERY
OF DOWER, DOWRY ARTICLES AND MAINTENANCE
Respectfully Sheweth:
1. That the plaintiff was married with the defendant
according to Muslim rites on 02-02-2014. The
Nikah was performed at Faisal Mosque Islamabad.
Whereas Rukhsati was postponed and has not yet
taken place. (Copy of Nikkah Nama is annexed as
Annexure ‘A’).
2. That a house of 4 Marla situated at Multan, land
measuring 16 Kanal in Mouza Beat Kaich south
Tehsil Jalalpur Pirwala, District Multan, 2 Tola Gold
Ornament and Rs:5000/- cash were fixed as dower
consideration.
3. That out of the above said dower the defendant
paid 2 Tola Gold ornament and also transferred
land measuring 16 kanal in village Inayatpur Tehsil
Jalalpur Pirwala District Multan without delivery of
possession whereas remaining dower is still
unpaid.
4. That since the parties are native resident of
District Multan thus the parents of the plaintiff
prepared & purchased the dowery articles at
Multan and delivered to the defendant at his
above said residence as per list Annexure B, which
is in possession of the defendant and plaintiff is
entitled for its recovery.
5. That it was decided that the Rukhsati will took
place within Six months from the date of marriage
thus the dowery articles were handed over but the
defendant side delayed the Rukhsati on deferent
pretexts and till to date they are not willing to
bring the plaintiff to the matrimonial abode.
6. That parents of the plaintiff have tried their level
best to persuade the defendant and his parents for
Rukhsati but the defendant has not yet made any
promise for the same. Due to non Rukhsati, the
entire responsibility of which lies upon the
defendant, the prime matrimonial life of the
plaintiff has been ruined which is cruelty by
conduct. The plaintiff is facing this cruelty for more
than three and a half years coupled with the fact
that defendant has not paid a single penny to the
plaintiff on account of maintenance. The
defendant is under an obligation to maintain the
plaintiff as she is his legally wedded wife but the
defendant has failed to pay the maintenance since
date of marriage till to date.
7. That the defendant is neither habilitating the
plaintiff nor paying the maintenance, rather she
has been subjected to worst cruelty by the
defendant.
8. That the plaintiff is entitled for dissolution of
marriage on the basis of non payment of
maintenance and cruelty. The plaintiff also entitled
for decree for recovery of dower comprising of a
house of 4 Marla situated at Multan, possession of
land measuring 16 Kanal in Inayatpur Mouza Beat
Kaich south Tehsil Jalalpur Pirwala, District Multan,
and Rs:5000/- cash, and maintenance @
Rs.30,000/- p.m. from the date of marriage till to
date and future and dowry articles as per list
Annexure ‘B’.
9. That the defendant is under an obligation to pay
the dower to the plaintiff and also to maintain her.
He is also illegally occupying the dowry articles.
The defendant has got no right to keep linger on
the Rukhsati and to ruin the life of the plaintiff but
he is not willing to discharge his obligations and
all requests and reminders made to the defendant
have borne no fruit, hence this suit.
10. That cause of action accrued to the plaintiff lastly
yesterday, it continue, the suit is thus within time.
11. That plaintiff is residing at Islamabad hence this
Honourable court has got jurisdiction to entertain
the suit, try the same and grant relief claimed.
12. That Plaintiff
the
Through CH. ABDUL
REHMAN BAJWA
Advocate High
Court
appropriate court fee has been affixed on the
plaint.
It is therefore respectfully prayed that this
Honourable Court may very graciously be pleased to
pass following decrees:
a. A decree for dissolution of marriage on the basis
of non-payment of maintenance and cruelty.
b. A decree for recovery of dower comprising of a
house of 4 Marla situated at Multan, possession
of land measuring 16 Kanal in Inayatpur Mouza
Beat Kaich south Tehsil Jalalpur Pirwala, District
Multan, and Rs:5000/- cash.
c. A decree for recovery of dowry articles as per
list Annexure ‘B’.
d. A decree for recovery of maintenance of plaintiff
@ Rs.30,000/- per month, from the date of
marriage and on the same rate of future
maintenance.
Any other relief which this Honourable court may deem
fit and proper may also be awarded.
Verification
Verified on S.A that contents of para No.1 to 8 of plaint
are true and correct to the best of my knowledge and
belief and rest of the paras are believe to be correct as
per information furnished.
Plaintiff
