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