HOW TO WRITE SUIT FOR RECOVERY OF DOWER MONEY

SUIT FOR RECOVERY OF DOWER MONEY

IN THE COURT OF FAMILY JUDGE LAHORE

Name --------------------          Daughter/O ----------------------------                  R/O--------------------------------
District-------------------------------------------------------------------------------------------------------------

Plaintiff.

Vs

Name ------------------------         S/O -------------------------                 R/O--------------------------------
District---------------------------------------------------------------------------------------------------------------

Defendant.

Suit for Recovery of Dower Money

Rs.50,000

1.      That the plaintiff was married to the Defendant on 1^st Sep, 2001 In consideration of prompt dower of (Rs. 50,000/-) according to the Muslim rites. A copy of Nikah Nama is attached to this suit.

2.      That after the marriage plaintiff and defendant lived a happy life but thereafter the defendant went cruel towards plaintiff and turned her out of doors.

3.      That since the plaintiff has been making repeated demands for the payment of her prompt doer i.e. Rs. 50,000/- which was fixed at the time of the marriage but defendant had flatly refused to pay money and demands. Hence this suit.

4.      That the cause of action arose against the defendant firstly on 15-09-2001 when the plaintiff was married with defendant and secondly when the defendant turned out the plaintiff of doors and lastly and finally on 18^th August, 2003 when the defendant flatly refused to pay the dower money to the plaintiff.

5.      That the marriage was performed at Samanabad and both the plaintiff and defendant reside in Samanabad Lahore, therefore civil Courts of Lahore have the jurisdiction to decree this suit.

6.      That the valuation of the suit for the purposes of Court fee and jurisdiction is Rs. 50,000/- therefore, Court fee tickets of Rs. 15/- is affixed on the plaint, which is prescribed Court fee to be affixed with this suit

In view of the above it is respectfully prayed as under.

PRAYERS

1.      A decree for a sum of Rs. 50,000/- may kindly be passed in favor of the plaintiff of the plaintiff and against the defendant.

2.      Cost of this suit may also be awarded to the plaintiff.

3.      Any other relief deemed possible by this Honorable Court may also be granted.

Plaintiff.

Through Counsel,

VERIFICATION:
Verified on Oath at Lahore on this abc day of Aug 2003 that the paras 1 to 3 are correct and remaining paras 4 to 6 are true according to my belief and knowledge.

Plaintiff.