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.
16. 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

Download Word Doc