IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF JUDGE FAMILY COURT, LAHORE

­­­­­­­______ Daughter of _______, Resident of ______, Lahore.

Plaintiff

V E R S U S

______ Son _______ Resident __________________
 

Defendant

SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULLA

Respectfully Sheweth:-

1. That the plaintiff was married with the defendant on 2.07.20 in accordance with Muslim Law against Rs. ____/- as prompt dower, which was paid.

2. That with the passage of time the attitude and behavior of the defendant became cruel and harsh. The plaintiff was also a victim of domestic violence and mental torture.

3. That Since the marriage took place, the defendant has not provided adequate maintenance to the plaintiff.

4. 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.

5. That elders of the families tried for reconciliation; however, all their efforts have failed. The defendant has flatly refused to mend his ways.

6. That in January 2022 the defendant after severe beating deserted the plaintiff from his house in three wearing apparels.

7. That the life of the plaintiff severely impacted by the defendant's cruel conduct. Now plaintiff has developed hatred in her mind against the defendant and she cannot live with the defendant within prescribed limits of ALMIGHTY ALLAH.

8. That the plaintiff’s approached the defendant and requested him to divorce the plaintiff but defendant flatly refused. Hence, this suit.

9. 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 when defendant flatly refused to divorce the plaintiff, which is still continuing.

10. That the plaintiff is residing in Lahore, therefore, this Honourable court has got the jurisdiction to adjudicate upon the matter.

11. That the requisite court fee 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.

Any other relief which this Honourable Court deems fit may also be awarded.

 Plaintiff

through

_____________________
Advocate High Court

VERIFICATION

Verified on oath at Lahore this __ day of jul 2024 that the contents of paras No. 1 to 10 are correct to the best of my knowledge and belief.                                                                                 Plaintiff