Sue for Maintenance & Dowry-Article Recovery

In the Court of Senior Civil Judge with the

Powers of Family Court, Pattoki.
Name of Plaintiff D/o Plaintiff Father Name, caste Jutt,Resident of (City Name), Tehsil
(Pattoki), Dist (Kasur)
                                                                                                                                           
________Plaintiff
                                                                     Versus
Name of Defendant S/o Father Name, Resident of MallanwalaChak No: 34, Tehsil Pattoki
District Kasur                                                              
_______Defendant   
Sue for Maintenance Allowance and the recovery of Rs: 650,000/= as dowry
Articles/Money.
The Plaintiff submits as under:--
1. That the plaintiff was married to the defendant on 11th of November, 2008 according to
the Muslim rite and thus registered under Muslim Family Law Ordinance. The copy of
Original testimonial document is attached with the plaint.
 That after the marriage plaintiff & defendant reside together amicably where plaintiff
raised three daughters & two sons; who are under the kind custody of plaintiff now.
 That initially the relations between plaintiff & defendant remain cordial but, thereafter
the defendant started quarrelling on petty household matters and eventually one year from
now defendant severely beat the plaintiff and turned her out of the house with
humiliation. Since then the plaintiff has been putting up with her parents along with her
daughters and sons bearing their expenses out of her personal earning; securing through
huge effort and struggle. Defendant pays no attention for the children day to day
expenses, necessary to lead a respectful life even with minimum status level of the
society.
 That since defendant expulsion from the house plaintiff and her relatives have been
making repeated demands for the dower money and personal belongings & dowry
Articles amounting up to 650,000/= as per the list attached and, furthermore, there is a
high probability that defendant might alienate or sell the plaintiff Articles & other
belongings without any legal authority, as defendant is absolutely not willing to return the
belonging, instead rejected our legitimate demand exclusively one week from now.
Hence the present sue
 That  defendant has Supervisor job in the factory and have enough earning that he can
pay Rs:5000/Child but, not paying a penny since the plaintiff residing with her parents
 That the marriage was performed at Tehsil Pattoki so the honorable Court is competent to
hear the present sue.
 That proper court fee of Rs: 15 has been affixed on the plaint.
Prayer
  It is therefore, respectfully prayed that decree for recovery of dowry Articles be passed or
likewise a sum of Rs: 650,000 be passed in favor of plaintiff and against defendant with
additional sue cost as, honorable court understand best fit for.
It is also prayed to pass a decree of Rs: 5000/child total of Rs: 25000/M in favor of plaintiff and
against the defendant
Any other relief that honorable court may deems fit
Name of Plaintiff, plaintiff
Through
  Malik Slamat Adv
VERIFICATION
Verified on oath at Pattoki this 15th day of October, 2020 that the contents of the paras 1 to 3 are
true to my knowledge and those of rest are to my information & belief.
                                                                                            Name of Plaintiff, Plaintiff