IN THE COURT OF FAMILY JUDGE, NARA.
Family Suit No. /2025
Mst kalsoom D/o Niyaz Hussain Bycaste Mirjat , adult,
Muslim, R/o village ghulam Abbass mirjat Taluka Nara
District Khairpur
------------ PLAINTIFF
V E R S U S
Allah Bachayo son of Ghulam Hussain Bycaste Mirjat , adult,
Muslim, R/o village khet near Qaim khan Bhanbhro Taluka
Nara District Khairpur
------------ DEFENDANT
SUIT FOR DISSOLUTION OF MARRIAGE ON THE GROUND OF KHULLA
That the plaintiff named above beg to submits as
under;-
1/- That prior to this no suit filed like nature before
this Honorable court.
2/- That the plaintiff was performed her NIKAKAH/marriage
with defendant about two years back at village, no
consideration was received by the plaintiff in lieu
of hand of plaintiff at the time of marriage. The
Rukhsati of the plaintiff took place at the same date
of Nikah no any issue has been born to the plaintiff.
3/- That at the time of nikah haq mahar was fixed two
thousands rupees 2000 same was not paid by the
defendant till today.
5/- That about 06 months back defendant came in other
colors, started maltreated to plaintiff on every day
fight with me defendant is jobless, man of no
character and use intoxicant but despite of that the
plaintiff being respectable lady has not been to
leave his house.
6/- That plaintiff has requesting to defendant to mend
his way but paid no heed, rather has been maltreating
her like animal without any cogent reason, lastly
defendant having given a several beaten to the
plaintiff drove her out from his house and plain
three cloths wherefrom the plaintiff came to her
parental house where continuously maintained to
plaintiff by her parents.
7/- That the parents of plaintiff was approached to the
defendant through noteable person of the area to get
back as well as to maintain to plaintiff properly but
defendant has clearly refused.
8/- That since the time of being driven out, neither the
defendant has never paid any single ruppee to the
plaintiff for maintenance during hard days, defendant
has not turn to see the face of the plaintiff.
8/- That the cause of action has accrued to plaintiff for
filling the present suit firstly when defendant
started when defendant came in other colours to the
plaintiff and maltreated to her without
justification, secondly it accrued she kicked out
from the house of defendant at about 06 months in
plain 3 cloths, when the defendant failed to provide
maintenance thereafter, till yet plaintiff
continuously residing with her parents thirdly
accrued when defendant clearly refused to pay
maintenance to the plantiff .
10/- That due to previor and current circumstances, the
plaintiff developed deep hatred against the
defendant, so she wants dissolution of marriage on
the ground of “KHULLA” and so also other grounds.
11/- That for the purpose of court fee Rs.15 is affixed
herewith.
12/- That the Plaintiff, therefore, prayed for judgment
and decree as under;-
P R A Y E R S
i. That this Honourable Court may graciously be
pleased to dissolve the marriage of plaintiff
with the defendant on the ground of “KHULLA”.
ii. To award the cost of this suit.
iii. Any other relief, as deemed fit and proper.
Dated: 29.01.2025 P L A I N T I F F
VERIFICATION
Mst kalsoom D/o Niyaz Hussain Bycaste Mirjat , adult,
Muslim, R/o village ghulam Abbass mirjat Taluka Nara
District Khairpur hereby verify on solemn affirmation that
whatever stated above is true and correct to the best of my
knowledge and belief.
Verified and signed this 29th day of janurary 2025 at Nara.
D E P O N E N T
I know the deponent
Advocate
DOCUMENTS FILED: NIL.
Nikah nama
DOCUMENTS RELIED UPON
Any document in rebuttal
Dated. 29.01.2025. Advocate for plaintiff.
IN THE COURT OF FAMILY JUDGE, NARA
Family Suit No. /2025
Mst Kalsoom ------------ PLAINTIFF
V E R S U S
Allah bachayo ------------ DEFENDANT
LIST OF WITNESSES
1 Plaintiff She is plaintiff and will
support her plaint.
2 he is _________ of plaintif
and will support the
version of plaintiff.
Dated: 29.01.2025 ADVOCATE FOR PLAINTIFF
IN THE COURT OF FAMILY JUDGE, NARA
Family Suit No. /2025
Mst: kalsoom ------------ PLAINTIFF
V E R S U S
Allah bachayo ---------------------- DEFENDANT
A F F I D A V I T
I Mst kalsoom D/o Niyaz Hussain Bycaste Mirjat , adult,
Muslim, R/o village ghulam Abbass mirjat Taluka Nara
District Khairpur do hereby state on Oath as under;-
1/- That I am Plaintiff in the above matter, thus well
conversant with the facts.
2/- That the plaintiff was performed her NIKAKAH/marriage
with defendant about two years back at village, no
consideration was received by the plaintiff in lieu
of hand of plaintiff at the time of marriage. The
Rukhsati of the plaintiff took place at the same date
of Nikah no any issue has been born to the plaintiff
3/-That my Nikah was recited with the defendant about 3
years back but the said Nikhanama is lying with the
defendant therefore, I am unable to produce the same
before this Honorable Court in the above family suit.
4/- That this affidavit is drafted after my instruction
and the contents were read over to me.
5/- That for the sake of brevity, the contents of this
affidavit are treated as part and parcel of
accompanying application.
Whatever, stated above is true and correct to the
best of my knowledge and belief.
Verified this the 29th day of janurary, 2025, at
nara.
DEPONENT
I know the deponent
Advocate
