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

1. 2. 3. 4. 5.

Mst. Nazia D/O Bagha Mst. Naseem Abid (Minor) Umair Abid (Minor) Abdulla Abid (Minor) Zain Ali Abid (Minor) Daughter and Sons Abid Ali Plaintiff No. 2, 5 are minors hence it through plaintiff No. 1. All Awami Colony Qanchi Amar Sidhu, Tehsil Model Town, District Lahore. Plaintiffs VERSUS

Abid Ali S/O Muhammad Sharif R/O St. No. 4, Awami Colony Qanchi Amar Sidhu, Tehsil Model Town, District Lahore Defendant 1- SUIT FOR DISSOLUTION OF MARRIAGE, 2- SUIT FOR MAINTENANCE ALLOWANCE 3- SUIT FOR RECOVERY OF DOWRY ARTICLES & GOLD
ORNAMENTS 3 TOLAS, TOTAL Rs. 2,80,000/-

Respectfully Sheweth.

1.

That the address at the parties is correct for the effective correspondence of summons/notices.

2.

That the Plaintiff No. 1 was married with the defendant according to Muslim Rites about 11 years ago and God blessed her Four children who are alive namely (1) Mst.

Naseem Abid aged 9 years, (2) Umair Abid aged 7 years, (3) Abdulla Abid aged 6 years (4) Zain Ali Abid aged 2-1/2 years whose are in the custody of the plaintiff No.1. (Mother). 3. That in the starts of the marriage relation between spouses remained cordial but thereafter behavior to wards the plaintiff became cruel as the defendant used to torture the plaintiff on petty matters. 4. That the plaintiff has developed hated towards the defendant due to his cruel attitude. 5. That the defendant has not provide any maintenance to the plaintiff No. 1 after the married and the plaintiff is working in deferent houses and earn for her self and her children. 6. That the defendant is a criminal minded person and the plaintiff cannot live within the limits of Quran & Sunnah. 7. That about six months ago back the defendant tortured the plaintiffs quite badly and kicked out the plaintiff including minor in three wearing cloths out of his house. The plaintiff No. 1 with her children came to on a rent house. 8. That the plaintiff No.1 with her minors since from about 6 months living with her children and the bearing all expenses of her self and her children. 9. That the Plaintiffs parents gave precious dowry articles, gifts and 3 Tolas gold ornaments at the time of marriage

valuing Rs. 4,90,000/- which were moved to defendants house along with Plaintiff and dowry articles are still in the custody defendant. The Nikah Nama of the plaintiff is in the possession of defendant. 10. That the Plaintiff No. 1 repeatedly demanded her dowry articles, gold ornaments and dower article which was given to the defendants at the time of marriage because now it is difficult to live as a wife with the defendant in future but the defendant has always been linger on matter by lame excuses and the matter is still unresolved. 11. That the cause of action firstly arose in the favour of the Plaintiff No.1 and against the defendant at the time of marriage and secondly when the defendant kicked out the plaintiff No. 1 with her child minor in three cloths out of his house about three years ago. 12. That the plaintiffs are residing at Lahore so this Honourable court has full powers of jurisdiction to try the suit. 13. That the court fee has been paid according to law.

PRAYER Under the circumstances enumerated above, it is, most humbly prayed that a (i) a degree of desolation of marriage in favour of the plaintiff against the defendant may very kindly be passed, (ii) a degree of maintenance in favour of the plaintiffs

against the defendant valuing 2,52,000/- and continue till the maturity of minors may also be passed, (iii) a degree of recovery dowry articles valuing Rs. 4,90,000/- may also be passed in favour of plaintiffs against the defendant. Any other relief which this Honourable Court deems fit may also be awarded. Plaintiffs Through Counsel

Mian Mehmood Ahmed Advocate High Court 42-43Model Town Courts, Lahore. Verification. Verified on Oath at Lahore on this day of 9 th July 2012, that the para No. 1 to 10 is correct according to best of my knowledge and belief and the rest of paras are correct according to my knowledge.

Plaintiffs

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

Mst. Nadia etc

VERSUS

Abid Ali

SUIT FOR DISSOLUTION OF MARRIAGE, AFFIDAVIT OF: Mst. Nazia D/O Bagha resident of Awami Colony Qanchi Amar Sidhu, Tehsil Model Town, District Lahore`

I, the above named deponent do here by solemnly affirm and declare that the contents of accompanying petition and affidavit are correct to the best of my knowledge and belief and nothing has concealed in it. DEPONENT VERIFICATION. Verified on oath at Lahore on this 9th July, of 2012 that the contents of the above affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed.

DEPONENT

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

Mst. Nadia etc

VERSUS

Abid Ali

SUIT FOR DISSOLUTION OF MARRIAGE,

LIST OF WITNESSES
1. plaintiffs herself

2.

3.

Plaintiffs Through Counsel

Mian Mehmood Ahmed Advocate High Court 42-43Model Town Courts, Lahore.