Tuesday, 12 February 2019
DISSOLUTION OF MARRIAGE
Q. Draft a plaint on behalf of Miss Hameeda for dissolution of her marriage on the ground of exercise of option of puberty. A. Draft a written statement to the above suit on behalf of the defendant. OR
Q. Draft a plaint in a suit for dissolution of marriage on behalf of Khalida against Salman her husband on the ground of cruelty, non-maintenance and Khula. A. Draft a written statement on behalf of the defendant for the above suit. OR
Q. Nasreen wishes to dissolve her marriage with Zafar on ground available to her under the Dissolution of Muslim Marriage Act, 1939 and Khula. Prepare a plaint for instituting in a Family Court.
A. Draft a para, wise reply, on behalf of Naureen's husband(defendant) in the above suit.
(PLAINT)
IN THE FAMILY COURT,______________________
_________________ D/O ___________________ R/O ______________________________________
District_____________________________
Plaintiff
VERSUS
__________________ S/O___________________ R/O ______________________________________
District____________________________
Defendant
SUIT FOR DISSOLUTION OF MARRIAGE
It is respectfully submitted as under,
1. That the plaintiff was married with the defendant at ___________________ on 8th day of February, 2002, according to Muslim rites and a sum of Rs 25000/-having been fixed as prompt dower. A copy of Nikah-nama is attached with this suit.
2. That for about four years the relations between the parties remained pleasant but thereafter the defendant started quarreling with the plaintiff on petty issues and he also started to beat the plaintiff and also has turned her out of doors.
3. That since then the plaintiff is residing with her parents at Chuburgi, Lahore.
4. That from the date of her expulsion from her husband’s house, the plaintiff and her relatives have been approaching the defendant requesting him to either take the plaintiff back to his house or to dissolve his marriage by giving divorce to the plaintiff but to no avail. Also the defendant has refused to provide maintenance for the plaintiff, hence this suit.
5. That the cause of action arose firstly on 28th December 2006, when the defendant turned out the plaintiff from his house and secondly and finally one week ago when the defendant flatly refused to give divorce to the plaintiff.
6. That the plaintiff and the defendant reside at_____________________ and the cause of action arose at___________________, therefore the Civil Court is entitled to decree this suit.
7. That since it is a family suit, therefore Court fee tickets of Rs15 have been affixed on this plaint.
In view of the above, it is humbly prayed as under,
=> PRAYERS:
I. A decree of dissolution of marriage may kindly be passed in favour of the plaintiff and against the defendant.
II. Heavy costs may also be awarded to the plaintiff.
III. Any other relief deemed possible by this honorable Court may also be granted.
Plaintiff
THROUGH COUNSEL,
_________________________________
_________________________________
_________________________________
=>VERIFICATION:
Verified on oath at _____________________ on this 30th day of January 2007, that the contents of paras 1 to 4 are true to the best of my knowledge and those of paras 5, 6 and 7 are correct to the best of my information and belief
Plaintiff
WRITTEN STATEMENT IN THE FAMILY COURT, LAHORE
In re: _________________________VERSUS________________________
(SUIT FOR DISSOLUTION OF MARRIAGE)
Written Reply on behalf of the Defendant
It is prayed as under,
ON MERITS:
1. Admitted.
2. Denied: The plaintiff never quarreled the plaintiff and never turned her out of his house. The plaintiff left the house of the plaintiff with her own will and without any force.
3. Not concerned.
4. Denied: The plaintiff and her relatives never approached the plaintiff for the solution of her problems, therefore there is no question of acceptance or denial of the proposal alleged to have been given to the defendant by the relatives of the plaintiff.
5. Legal
6. Legal
7. Legal
In view of the above, it is prayed as under,
=> PRAYERS:
I. This suit may kindly be dismissed.
II. Heavy costs may also be awarded to the defendant.
III. Any other relief deemed possible by this honorable court may also be granted.
Defendant
THROUGH COUNSEL,
_________________________________
_________________________________
_________________________________
=>VERIFICATION:
Verified on oath at __________________ on this 28th day of February 2007, that the contents of this written statement are true and correct to the best of my information and belief and nothing herein has been concealed from this Court.
Defendant
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