Format for Legal Notice to Wife for Restitution of Conjugal

Rights
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To

Mst. XYZ,

Daughter of ABC,

R/o ___________________,

Sub:-               LEGAL NOTICE

I hereby informed you that Mr. JA son of BA resident of H. No. __, St No. _, near ____,
Allama Iqbal Colony, ______, Rawalpindi has engaged me as his counsel to send you
legal notice in a family matter and after placing all the relevant documents /record
before me, has requested to serve you with the following legal notice:

 
1.

That my client was married to you according to Islamic Rights. The dower
amount was fixed Rs. 1 million, out of which half was paid to you, no dowry
articles were given to you by your parents. During the matrimonial life, no issue
was born.

2.

That during the subsistence of the marriage, your behavior towards my client was
not well and you on the instigation of your father are making hurdles also making
troubles in your matrimonial life with my client. Your father often asked you to
collect money from my client and give it to him but when my client denies the
same, you left the house of my client many times. My client tried to reconcile with
the elders of Brother and repeatedly took you to his house.

3.

That after the marriage of the parties hereto you proved yourself as an
undaunted lady, selfish, wayward/ arrogant, and a woman of willfulness.
However, my client tried his level best for the betterment of the material abode
 and also to manage with you and in this regard left no stone unturned. But in
return not even a single step is taken by you for the betterment of the situation.
You intentionally by your conduct and behavior made the life of my client
miserable, however, my client bothered all this for the sake of material abode, for
the honor of his family, and also for the honor of the family of you but it was you
who always proved yourself as NASHIZA from your conduct and behavior. My
client himself and through the elders of both the families emphasized you and
asked you to become loyal, obedient, and a good lady but all in vain. Rather you
demanded a huge amount and other valuables gifts from my client on the
instigation of your father.

4.

That it is worth mentioning to state here that my client belongs to a respectable

family. You and your parents contracted the marriage with my client with the
intention to grab extraordinary benefits from my client and in this regard during
the matrimonial lifetime and again asked and pressurized my client to give huge
amounts

5.

but on the refusal and straightaway denial, they came to the conclusion that their
illegal and unlawful desires and also their wishes for grabbing money and other
valuables can never be achieved.
6.

That it is also pertinent to mention that my client provided all the necessities of
life to you according to his means and status but unfortunately found you as one
who has no respect for your husband and also has no belief in family life. In spite
of living with my client in his house you on the instigation of your father’s time
and again left the house of my client without the permission and knowledge of my
client as well as without any cogent reason.

7.

That at the time of marriage, my client on demand of the parents of you has
managed and given gold ornaments and also gave a luxurious reception. But
when you and your parents came to the conclusion that their illegal and unlawful
desires cannot be fulfilled, you left the house of my client in the last month i.e.
May 2008 without the permission, knowledge of my client in his absence along
with valuables while my client was not in the home. When my client came to his
house, he came to know that you are not at the home. He inquired on the
telephone about your absence, you told me that you will come back. You while
leaving the house of my client took the gold ornaments weighing 8 Tolas and
also cash amount of Rs. 70,000/- and also valuable articles.

8.
 That it is only your father who poked his nose in the matrimonial life of you and
my client and instigate you to pressurize my client to fulfill their illegal desires.

9.

That you took the valuables on the instigation of your father and my client
reserves his right to initiate criminal as well as civil proceedings against you and
her father.

10.

That my client has love and affection with you and he wants to live in a happy
family.

11.

That my client sent you many Jirgas for reconciliation but you on the instigation
of your father denied to reconcile. The members of the Jirga are ready to record
their evidence which my client has sent them to your house for compromise but
you again on the instigation of your father demanded a huge amount for
compromise. My client is a poor man, he could not fulfill your desires because of
 which you denied performing your matrimonial obligations. My client is a young
man, who is living a miserable life without his wife.

12.

That my client has paid the maintenance allowance to you throughout his
matrimonial life.

13.

That my client still has love and affection with you and he wants to live a happy
life with you and is ready to reconcile.

14.

That it is an obligatory duty upon you both legally and morally that you should live
with your husband and perform the matrimonial obligation.

15.
 That despite the number of reservations, my client tried his level best by himself
and through Jirgas to solve this matter to save his matrimonial life and to provide
love and affection to you but all the efforts made by my client remain futile due to
your adverse and negative attitude.

Through this legal notice in a family matter, I hereby instruct you in your own interest to
rejoin my client and perform your matrimonial obligations, for which he has the legal
right and also rejoin my client in his house within 14 days otherwise my client has given
me clear instructions to institute a suit for restitution of conjugal rights in the competent
court of law, at your risk and costs. My client also asked me to inform you that if you do
not perform your matrimonial obligations and do not reconcile, he will have a right to
remarry after due process.

Through

Name of Council

Advocate High Court