DISSOLUTION OF MARRIAGE ON THE GROUND OF OPTION OF PUBERTY
PLAINT
IN THE FAMILY COURT, LAHORE
_________________ D/O ___________________ R/O ______________________________________
District_____________________________
Plaintiff
VERSUS
__________________ S/O___________________ R/O ______________________________________
District____________________________
Defendant
SUIT FOR DISSOLUTION OF MARRIAGE ON THE GROUND OF OPTION OF PUBERTY
It is respectfully submitted as under,
1. That the plaintiff was married with the defendant at ____________________ on 8th day of February, 2004 when she was 13 years of age, according to Muslim rites, and on a sum of Rs 25,000/ having been fixed as prompt dower. A copy of Nikah-Nama showing the age of plaintiff is attached with this suit.
2. That the plaintiff was married to the defendant on the strong desire of her uncle and at that time, she was not able to refuse her maternal uncle who was the guardian of the plaintiff and used to bear all the expenses of the plaintiff.
3. That the plaintiff has attained the age of 16 years and is less than 18 years and is persona majora (major) under her personal law i.e, Mohammedan Law.
4. That the plaintiff had never gone to the house of the defendant since marriage and now in exercise of her right of option of puberty, she repudiates the said marriage and this fact of repudiation has been communicated to the defendant and defendant is not willing to accept the same, hence this suit.
5. That the cause of action arose firstly on 8th day of February 2004 when the plaintiff was married to the defendant being minor and secondly and finally when the plaintiff repudiated (disown) the marriage and the defendant refused to accept the same.
6. That the plaintiff and defendant reside and were married at ________________and the marriage was repudiated by the plaintiff in________________, therefore Family Court of ________________ has the jurisdiction to decree this suit.
7. That since it is a family suit, therefore, a court fee ticket of Rs 15/- is affixed on this plaint.
In view of the above, it is humbly prayed as under,
=> PRAYERS:
I. This suit may kindly be decreed in favour of the plaintiff and against the defendant by dissolving this marriage in exercise of option of puberty by the plaintiff.
II. Any other relief deemed possible by this honorable court may also be granted.
Plaintiff
THROUGH COUNSEL,
_________________________________
_________________________________
=>VERIFICATION:
Verified on oath at Lahore on this 14th day of May 2007 that the contents of paras 1-4 are true to the best of my knowledge & those of rest of paragraphs are correct to the best of my information & belief.
Plaintiff
IN THE FAMILY COURT, LAHORE
In re: _____________________________ VERSUS __________________________________
(SUIT FOR DISSOLUTION OF MARRIAGE ON THE GROUND OF OPTION OF PUBERTY)
PARAWISE COMMENTS (WRITTEN STATEMENT) ON BEHALF OF DEFENDANT:
It is respectfully submitted as under,
1. Admitted
2. Not concerned
3. Admitted.
4. Admitted: The plaintiff has right to exercise the option of puberty if she desires so, therefore the defendant has no objection if this Court dissolves this marriage.
5. Legal
6. Legal
7. Legal
View of the above prayed as under,
=> PRAYERS:
I. This suit may kindly be decreed according to the law.
II. Any other relief deemed possible by this honorable court may also be granted.
Defendant
THROUGH COUNSEL,
_________________________________
_________________________________
_________________________________
=>VERIFICATION:
Verification on oath at ____________________ on this 26th day of June 2007 that the contents of this reply are true and correct to the best of my knowledge and belief.
0 comments:
Post a Comment