SUIT FOR DISSOLUTION OF MARRIAGE
1. Dissolution of the Muslim Marriages, Act, 1939
2. W.P family Courts Act, 1964 as amended by Family Courts Amendment Ordinance 2002
Court Fee:
Court fee to be paid on any plaint filed before a family court shall be Rs. 15 for any kind of suit (Section 19)
Plaint or appeal in family cases, court fee of Rs. 15 is paid
Limitation:
No limitation is required, Section 23 of the limitation Act can be taken into consideration and therefore, such a suit is never barred.
DRAFT FOR SUIT IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF JUDGE FAMILY COURT, LAHORE
Mst. Parveen Akhtar
Daughter of Tufail Rana
Resident of House no. 87, Blokc-H, Model Town, Lahore, Pakistan.
Plaintiff
VERSUS
Javed Mina
Son of Ishtiaq Ahmed
Resident of House no. 34, Blokc-B, Muhafiz Town, Lahore, Pakistan.
Defendant
SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULLA
Respectfully Sheweth:-
- That the plaintiff was married with the defendant on 04.12.2015 in accordance with Muslim Law against dower of Rs. 935,000/- which was paid on spot and the nikah was registered with the concerned union council.
- That the behaviour, conduct of the defendant was cordial only for few years with the plaintiff, afterwards the defendant started beating and quarreling with the plaintiff on petty household matters, which the plaintiff beard only in order to intact her marriage.
- That in January 2016 the defendant after severe beating kicked out the plaintiff from his house in three wearing apparels and the plaintiff take shelter in her uncle's house where she is presently residing
- That the life of the plaintiff became miserable by defendant's cruel conduct.
- That now plaintiff has developed hatred in her mind against the defendant and she cannot live with the defendant within prescribed limits of ALMIGHTY ALLAH.
- That the plaintiff seeks dissolution of marriage on the ground of Khulla.
- That respectables of the plaintiff's family approached the defendant and requested him to divorce the plaintiff but defendant flatly refused them. Hence, this suit.
- That the cause of action accrued in favour of the plaintiff against the defendant firstly, when marriage was solemnized, secondly, when defendant tortured the plaintiff and kicked out the plaintiff from his house and lastly, a day before filing of this suit when defendant flatly refused to divorce the plaintiff, which is still continuing.
- That the plaintiff is residing in Lahore, therefore, this Honourable court has got the jurisdiction to adjudicate upon the matter.
- That the requisite court fee of Rs. 15/-has been affixed on the plaint.
PRAYER
- Under above narrated circumstances, it is, therefore, most respectfully prayed that a decree for dissolution of marriage on the basis of "Khulla" may very kindly be passed in favour of the plaintiff and against the defendant.
- Costs of the suit may also be awarded.
- Any other relief which this Honourable Court deems fit may also be awarded.
VERIFICATION
Verified on oath at Lahore this day of April 2016 that the contents of paras No. 1 to 10 are correct to the best of my knowledge and remaining paras No. 8 to 10 are true to the best of my belief.