Suit for Declaration
IN THE COURT OF THE DISTRICT JUDGE, LAHORE
...
Muhammad Ali, aged 35 years, son of Abdul Rehman, resident of
House No. 123, Gulshan-e-Iqbal, Lahore. .... PLAINTIFF
Versus
Zainab Bibi, aged 30 years, daughter of Aslam Khan, resident of
House No. 456, Model Town, Lahore. ...... DEFENDANT
Suit for Declaration
Statement of Claim
1) That the Plaintiff and the Defendant entered into a verbal
agreement of marriage on 10th January 2023.
2) That pursuant to the said agreement, the parties exchanged gifts
and made preparations for the marriage.
3) That the Defendant, without any lawful cause or justification,
refused to marry the Plaintiff on 15th March 2023.
4) That the refusal of the Defendant to marry the Plaintiff has
caused immense mental and emotional distress to the Plaintiff.
5) That the Defendant's conduct is against the principles of good
conscience and amounts to a breach of promise.
6) That the Plaintiff has suffered irreparable loss and damage due to
the Defendant's unjustified refusal.
7) That the defendant is residing in Lahore and verbal agreement
also took place place in Lahore. Therefore, This court has the
jurisdiction to try the suit.
8) That proper court fees of Rs 3000 has been affixed on the plaint.
Prayer
WHEREFORE, the Plaintiff most respectfully prays that this Hon'ble
Court may be pleased to:
(a) Pass a decree declaring that the agreement of marriage between
the Plaintiff and the Defendant is valid and binding.
(b) Pass a decree declaring that the Defendant is liable to marry the
Plaintiff.
(c) Pass a decree directing the Defendant to compensate the Plaintiff
for the losses and damages suffered by him due to her breach of
promise.
(d) Pass such other and further orders as this Hon'ble Court may
deem fit and proper in the circumstances of the case.
Verification
Verified on oath and declared that para 1-6 are true and correct to
the best of my knowledge and para 7-8 are true to the best of my
belief.
Muhammad Ali
Through
Hassan Mehmood
25-05-2024
Written Statement
IN THE COURT OF THE DISTRICT JUDGE, Lahore
Zainab Bibi, aged 30 years, daughter of Aslam Khan, resident of
House No. 456, Model Town, Lahore. ...... PLAINTIFF
Versus
Muhammad Ali, aged 35 years, son of Abdul Rehman, resident of
House No. 123, Gulshan-e-Iqbal, Lahore. .... Defendant
Suit for Declaration
Written Statement
1) The Defendant, Zainab Bibi, hereby submits this Written
Statement in reply to the Plaint filed by the Plaintiff, Muhammad Ali.
2) The Defendant denies all the allegations made in the Plaint as
false, frivolous, and baseless.
3) The Defendant submits that no valid agreement of marriage ever
existed between the parties.
4) The Defendant submits that the alleged "exchange of gifts" were
mere social courtesies and do not constitute a valid marriage
contract.
5) The Defendant submits that the Plaintiff has no valid proof to
prove the existence of any legally enforceable agreement of
marriage.
6) The Defendant submits that the Plaintiff's claim for specific
performance of a marriage contract is not maintainable in law.
7) The Defendant submits that the Plaintiff's claim for damages is
misconceived and without any legal foundation.
8) The Defendant submits that the Plaintiff has not suffered any loss
or damage due to any act or omission on the part of the Defendant.
9) The Defendant submits that the Plaintiff's suit is devoid of any
merit and deserves to be dismissed with costs.
Prayer
WHEREFORE, the Defendant most respectfully prays that this
Hon'ble Court may be pleased to:
(a) Dismiss the Plaintiff's suit with costs.
(b) Pass such other and further orders as this Hon'ble Court may
deem fit and proper in the circumstances of the case.
Verification
Verified on oath and declared to be true and correct to the best of
my knowledge and belief.
Zainab Bibi
Through
Adv. Huzaifa Nonari
25th July 2023
