Before the Senior Civil Judge/Family Judge Kohat.

Mst sima d/o Ashraf Khan wife of Aftab Gul Residence of Jerma distt Kohat. Plaintiff VS Aftab Gul S/O Abdul Kareem R/O Kohat city ... defendant A) Suit for the recovery of Dower Rs 10 Lac in cash, 5 marla constructed house bearing 70 Sector K.1 Phase 3 HayatAbad against the defendant./ B) Sut foor the recovery of maintenance amount @ Rs 10000/- per month against the defendant and Rs 3000/- each for the plaintiff no 2 to 5 pr month from 1st December 2010 till the final disposal of the case and onward for plaintiff No 2 till his age of majority and for that plaintiff No 3 to 5 till their marriages. C) Suit for the dissolution of marriage on the basis of cruelty. Cause of action accrued to the plaintiffs since 1st of December 2010 when the plaintiffs expelled by the defendant from his house in the territorial jurisdiction of this Honorable court at kohat Respectfully Sheweth, 1) that the plaintiff marriage was solemnized with the defendant on 25th march 1995 according to the injunction of Islam and at the time of Nikah/Marriage Rs 10 lac cash and 5 marla constructed house bearing No 70 sector K.1 Phase 3 Hayatabad was fixed as dower, However at the time of Nikah, a Nikah Nama was also executed which was signed by the spouses in the presence of witnesses as well as Nikah Khawan/Nikah Registrar (Copy of the Nikah Nama is attached). 2) that at the time of marriage/Rukhsati, a hug quantity of dowry article were shifted by the parents of the plaintiff which were shifted on the same day to the house of defendant and still are lying in his house ( Copy of detailed list along with prices/receipts are attached). 3) That after the Rukhsti/Marriage, the plaintiff started residence with the defendant and perform her legal obligation with the defendant due to which plaintiff No 2 to 5 have born. 4) that after the marriage a few month later the attitude of the defendant was cordial but thereafter the attitude of the defendant became harsh and started beating giving

abuse and mental torture on one pretext or the other but the plaintiff being a Muslim wife beard the said situation. 5) No complaint was made by the plaintiff to anyone against the harsh attitude of the defendant and the defendant has also became a drug addict and has refused to perform maintenance of the plaintiff rather started demand to arrange money from anywhere and refused to work. On the refusal of the plaintiff, the defendant always has beaten the plaintiff severely and twice the plaintiff received injuries including the right leg bone fracture. The plaintiff continues her treatment from the competent doctors due to which she borne Rs 50000/- (Copy of the medical report and X-rays are attached). 6) That on 1st of De 2010, the defendant severely beaten the plaintiff for the demand of money to purchase drug and when the plaintiff refused to do so then the defendant forcibly expelled the plaintiff from his house in the wearing clothes/empty hands and since then the plaintiff is residing in the house of her parents. However, at that time the plaintiff has lodge report in police station Jerma Kohat for beating and expulsion against the defendant.(Copy of the naqal mud report is attached). That since then the defendant has not approached to the plaintiff to take her in his house or to make payments of maintenance to the plaintiff. However, the parents of the plaintiff have sent several Jerga s to patch up the matter with the defendant but the defendant has always refused to keep the plaintiff a his wedded wife, hence the present suit against t he defendant. 7) that the value for the purpose of jurisdiction and Court fee have already been mentioned in the heading of the suit and this Honorable court has the jurisdiction to entertain the instant suit. It is therefore humbly prayed that on the acceptance of this suit a decree which is prayed for in the heading of the suit in favour of the plaintiff and against the defendant. Any other relief which deem fit in the eyes of law may also be granted in favour of plaintiff and against the defendant date Through Shafi Ahmad Verified that all the contents of the above suit are true and correct to the best of my knowledge and belief and nothing bas been concealed from this Honourable court. Deponent Plaintiff