SUIT FOR DISSOLUTION OF MARRIAGE

 

SUIT FOR DISSOLUTION OF MARRIAGE 

The suit for dissolution of marriage is filed under family law by women (wife) against her husband due to circumstances when parties feel that relation between them is at a stage that it’s better to end this relation.

suit for dissolution of marriage

Family courts entertain the plaint and decide it by adopting the procedure given in the family law.

Plaint consist of check list ant all relevant document that support the version of the plaintiff.

Check List:

S.No	Document	Yes	No
1	Complete name, father’s name,addres, phone number of the parties
2.	Copies of all document and plaint equal the number of defendant + Two additional set of copies
3	All necessary document along with copies for defendant
4	Copy of Nikkah nama , copies of national identity card, copy of license of the counsel of plaintiff

Download Suit for Dissolution of Marriage

SUIT FOR DISSOLUTION OF MARRIAGE:

 

 IN THE COURT OF SENIOR CIVIL/FAMILY JUDGE LAHORE.

 

 

AB… (Write name of plaintiff here) daughter of   xyz (write plaintiffs father name), Resident of 2145/A,St.,No.1 jannat town Lahore (write complete address of the plaintiff).                                                                                                                                                                              Plaintiff                                         

            Versus

Cd…….. (Write name of defendant here) son of (write name of defendant father here) Resident of ……. Park, Street No.3… Lahore. (Write complete address of the defendant).                                                                                             

            Defendant

SUIT FOR DISSOLUTION OF MARRIAGE

            (On the Basis of Khula)

Respectfully Sheweth: -

1. That the plaintiff was married to the defendant in                                accordance with Muslim rites on 13th May, 2018. A copy of the         Nikkah Nama is enclosed with. Reasonable dowry articles were         given by the parents of plaintiff at the time of   marriage.

2. That out of this wedlock no child was born.

3. That the relation between the spouses remained cordial             only few days in the beginning of the marriage and after         that defendant started quarrelling with the plaintiff on very      common house hold matters.

4. That the attitude of the defendant and his family was                 very cruel, harsh, arrogant and unreasonable towards the         plaintiff, he ignored his obligation and let the plaintiff              mercilessly.

5.That despite the physical and mental torture given to                the plaintiff by the defendant, the plaintiff tried her level         best to reconcile the matter for the sake of her matrimonial      life but the behavior of the defendant became more harsh         and more cruel. On 06^thJun 2020,the defendant kicked out     the plaintiff from his house wearing apparels only after             giving severe torture to the plaintiff since then the plaintiff     is residing on the above mentioned address without being         maintained by the defendant.

6.That the defendant habitually assaulted the plaintiff and            made her life miserable by cruelty of act and conduct as she     was unable to fulfill the illegal and immoral demands of the     defendant.

8.That the defendant has never maintained the plaintiff and         they are making their both ends meet by the help of parents      of plaintiff.

9. That due to the attitude of the defendant the plaintiff has got     fixed aversion in her mind against the defendant and it is         now impossible for the plaintiff to live with the defendant     as his legally wedded wife , as such the plaintiff seeks            dissolution of her marriage on the ground of  *KHULLA *.

10. That the cause of action has arisen in favour of the                   plaintiff and against the defendant firstly at the time                of solemnization of marriage between the plaintiff  and             the defendant, secondly on 06^th June, 2020 when the             plaintiff was ultimately kicked out by the defendant                  from his house, hence the cause of action is still continue.

11. That the plaintiff is now residing at Lahore, so this                 honorable court has got the entire jurisdiction to                     adjudicate upon the matter.

12. That the appropriate court fee has been affixed on  the               plaint for the satisfaction of the court.

PRAYER:

In the light of the above mentioned facts and                      circumstances, it is most respectfully prayed that               the titled suit may very kindly be decreed in                      favour of the plaintiff and against the defendant on            the  following terms:

A decree for dissolution of marriage may kindly be           passed in favour of the plaintiff and against the                   defendant with costs.

Any other relief, which this honorable court deems             fit and proper, in the circumstances of the case,                 should also be awarded in favour of the plaintiff.

                                                                 Plaintiff

                                                                 Through:

                                                                 Imran Ali Satti

                                                                 Advocate High Court,

                                                                13-Fane Road, Lahore

Verification:-Verified on oath today the 30th Day of September, 2020 that the contents of the above paras are true and correct to the best of my knowledge and nothing is concealed.

Plaintiff