SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA SAMPLE



IN THE COURT OF Ist FAMILY JUDGE KARACHI (SOUTH) 
Family Suit No. /2012 
Maria Habib d/o Chaudhry Habib Rizvi, Muslim, Adult, r/o House No. 11, Block-II, Green Belt, P. E. C. H. S., Karachi. ----------------------- PLAINTIFF 
v. 
Shahid Akram Khan s/o Bashir Akram Khan, Muslim, Adult, House No. C/F/28, Shah Faisal Colony No. 2, Karachi. --------------------- DEFENDANT 

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA 

The Plaintiff abovenamed humbly submits as follows: 
1. That the Nikah of the Plaintiff and the Defendant was solemnised at Karachi on 10/03/2012 in accordance with Sunni Muslim Personal Law on a dower amount of Rs. 5, 000/- (Rupees Five thousand Only). It is pertinent to mention here that the Plaintiff brought a cash amount of Rs. 500, 000/- (Rs. Five Hundred Thousand Only) as dowry. (Photo copy of the Nikahnama is annexed herewith and marked as annexure “P-1”) 

2. That the Defendant is a jobless person and is also whiling away his time in anti-social activities in as much as does not bear good moral character. 

3. That, pursuant to the marriage, it came to the knowledge of the Plaintiff that the Defendant is both an alcoholic and a drug addict. It is submitted that the Defendant, on a regular basis, comes home late in the night in an intoxicated state.

4. It is submitted that the Defendant is involved in gambling and he frequently invites his friends over to play cards and consume alcohol and smoke drugs. 

5. It is also submitted that the Defendant makes use of unparliamentary languages with every one including the Plaintiff. 

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA 

6. That the Defendant has time and again been requested by the Defendant as well as her parents to amend his habits but to avail. 

7. That, on 05/05/2012, the Plaintiff learned that the Defendant had stolen the entire amount which the Plaintiff had brought as dowry and wasted it all on alcohol. 

8. It is submitted that given the facts narrated hereinabove, the Plaintiff is unable to co-exist with the Defendant within the limits settled by the Shariah, inasmuch as hatred has developed in the heart of the Plaintiff, and, she is, hence, seeking dissolution of her marriage with the Defendant in exercise of her right of Khula, hence, this suit. 

9. That the cause of action accrued in favour of the Plaintiff for the facts and reasons disclosed hereinabove. The Plaintiff resides within the limits of P.S. ______________________, which falls within the territorial jurisdiction of this Hon’ble Court. Proper court fee has been affixed herewith. 

PRAYER 


It is, therefore, in the interest of equity, justice and good conscience, prayed that this Hon’ble Court may be pleased to pass a Judgment and Decree as follows: 

a. Dissolve the marriage between the Plaintiff and the Defendant by way of Khula. 

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA 

b. Grant any other, better, further and/or equitable relief that this Hon’ble Court deems fit, proper and necessary given the prevalent facts and circumstances in the instant case. 

c. Costs of the suit may be awarded. 

Karachi                                                                      PLAINTIFF

Dated: 25/05/2012                                     ADVOCATE FOR THE PLAINTIFF

VERIFICATION 

I, Maria Habib d/o Chaudhry Habib Rizvi, Muslim, Adult, r/o House No. 11, Block-II, Green Belt, P. E. C. H. S., Karachi, holding CNIC No. 45426- 5129562-6, do hereby on solemn oath and affirmation submit that whatever is stated above is true and correct to the best of my knowledge and belief. 
DEPONENT 

                                                                Identified by me. 
                                                                   

                                                                 ADVOCATE 

Document(s) filed: Annexure ‘P-1’ 
Document(s) relied upon: Annexure ‘P-1’and all other documents that are necessary and relevant to the subject matter. 
Address for service: As mentioned in the Title. 
Address for the Plaintiff’s counsel: As mentioned in the Vakalatnama 
Drafted by me
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