In the Court of Senior Civil Judge with powers of Judge Family Court, 

Lahore

1.      Mst. Faiza Khan D/o. Adbul Rehim, Caste Rajput, resident of 13 – Bund Road,
Lahore.

2.      Imran Khan S/o. Sattar Khan, Caste Rajput, resident of 98 – Bund Road, Lahore.

Minor through Mst. Faiza Khan, Plaintiff No. 1 as next friend      (Plaintiffs)

Versus

Sattar Khan S/o. Muhammad Ahmad, Caste Rajput, resident of 40 – Jail
Road, Lahore.                                                                                               (Defendant)

Suit for the recovery of Maintenance Allowance

Respectfully Sheweth:---

1.            That plaintiff no. 1 was married to the defendant at Lahore on March 07, 1996, in
accordance with Muslim Rites. The marriage was duly registered under the Muslim
Family Laws Ordinance, 1961. Out of this wedlock plaintiff no. 2 was born on June 07,
1997.

2.            That plaintiff no. 2 is a minor and is suing through plaintiff no. 1 who is his real mother
and has got no adverse interest against the minor plaintiff.

3.            That some time after the marriage, the relation between the parties became strained.
However, plaintiff no. 1 tolerated obnoxious (offensive) treatment meted out to plaintiff
no. 1 at the hands of the defendant, so that their family life may have smooth sailing. The
defendant did not care for that and continued his obnoxious treatment towards the
plaintiff and eventually turned out the plaintiff from his house where after the plaintiff
has been living with the parents of plaintiff no. 1.

4.            That the defendant has completely neglected plaintiffs and has completely failed to pay
any maintenance allowance to them.

The defendant has no other liability except the liability of maintaining the plaintiffs. The
defendant is an Engineer and his presently working as an executive engineer in the
Irrigation Department of the Government of the Punjab and he is drawing salary Rs.
25,000/- per month.

5.            That plaintiff no. 1 is M. A. English and belongs to respectable family of Lahore enjoying
very high social status. She claims a sum of Rs. 10,000/- per month as her maintenance
allowance. Plaintiff no. 2 claims a sum of Rs. 5,000/- per month as his maintenance
allowance.

6.            That the defendant was requested to pay the maintenance allowance to the plaintiff at the
aforesaid rates but he was flatly refused to pay the same. Hence this suit.
7.            That the cause of action arose in favour of the plaintiff against the defendant as this
refusal to pay the maintenance to the plaintiffs.

8.            That the parties reside at Lahore therefore, the family Court at Lahore have jurisdiction to
try the present suit.

9.            That the prescribed Court fee of Rs. 15/- has been paid.

It is, therefore, most respectfully prayed that a decree for the past as well as future maintenance
at the aforesaid rate may kindly be passed in favour of the plaintiffs against the defendant with
cost.
 
  Plaintiff
Through  
  Counsel

Verification: Verified on oath at Lahore on this 1 st day of February 1999, that the contents of
paragraphs no. 1 to 6 of the plaint are true to the best of my knowledge and those of paragraph
no. 7 to 9 are believed to be correct on information received therefrom.

Plaintiff