How to write a suit for Dissolution of Marriage, Khula Lahore Pakistan

suit for Dissolution of Marriage, Khula

SUIT FOR DISSOLUTION OF MARRIAGE

IN THE FAMILY COURT,

Name-------------------------------------------------      D/o ---------------------------------------------------- 
R/o------------------------------------------------------------------------------------------------------------------
District-------------------------------------------------------------------------------------------------------------

Plaintiff

VS

Name-----------------------------------------------------------------------------------------------------------------

S/o--------------------------------------------
R/o--------------------------------------------
District---------------------------------------------------------------------------------------------------------------

Defendant.

That the plaintiff was married with the defendant at abc on 8th day of Feb,2002 according to Muslim rites and a sum of Rs: 50000/- having been fixed as prompt dower. A copy of Nikah nama is attached with this suit.

That for about four years the relations between the parties remained pleasant but thereafter the defendant started quarreling with the plaintiff on petty issues and he also started to beat the plaintiff and also has turned her out of doors.

That Since then the plaintiff is residing with her parents at chuburgi Lahore.

That from the date of her expulsion from her husbands house, the plaintiff and her relatives have been approaching the defendant requesting him to either take the plaintiff back to his house or to dissolve his marriage by giving divorce to the plaintiff but to no avail.also the defendant has refused to provide maintenance for the plaintiff. Hence this suit.

that the cause of action arose firstly on 28th December 2006, when the defendant turned out the plaintiff from his house and secondly and finally one week ago when the defendant flatly refused to give divorce to the plaintiff. 

That the plaintiff and the defendant reside at Chuburji and the cause of action arose at Lahore therefore the Civil Court is entitled to decree the suit.

That since it is a family suit, therefore Court fee tickets of Rs.15 have been affixed on the plaint.

Prayers.

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

Heavy costs may also be awarded to the plaintiff.

Any other relief deemed possible by this honorable Court my also be granted.

Plaintiff.

Through Counsel.

Verification.

Verified on oath at       on the 30th day of jan,2007, that the contents of paras 1 to 4 are true to the best of my knowledge and those of paras 5 to 6 and 7 are correct to the best of my information and belief.

plaintiff.