IN 

THE COURT OF VTH FAMILY JUDGE
  KARACHI WEST
F.S. No. /2022

Jibran Ansari s/o

Naeem Uddin Ansari, Muslim, Adult,
Resident of House No. LS-4Sector 1/C,
Mohallah Banaras Nagar, Orangi Town,
Karachi. ……..……APPLICANT

Versus
Mst. Asifa D/o
Syed Akhbar, Muslim, Adult,
Resident of House No.546, sector 1-B
Orangi Town,
Karachi. ……….RESPONDENT

SUIT FOR RESTITUTION OF CONJUGAL

RIGHTS

                      The Plaintiff, abovenamed, submits as under: -

1. That the petitioner was married with respondent on 26-01-2016, in

accordance with Muslims laws Ordinance 1961, on consideration of
Dower amount to the tune of Rs.25,525/- it is averred that the
Nikahnama was executed and duly registered in, Orangi Town, within
jurisdiction of Orangi Town, Police Station, District Karachi West.

(Photocopy of Marriage Registration Certificate is attached

herewith and marked as annexure A/1).

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2. That, after nikah rukhsati taken place and the applicant brought the
respondent to his house and they remained as husband and wife and from
this marriage Two issues namely Noor Fatima and M.Usman took birth
, who is in custody of the respondent.

(Photocopy of Birth Registration Certificate is attached herewith

and marked as annexure B/1).

3. That the Plaintiff performed all conjugal obligations accordingly

but it is submitted that the Plaintiff’s behavior towards the
Defendant and his parents was very harsh, abusive, inflicted
mental torture & agony and she tried her level best to make a
miserable-life of the Plaintiff and his other family members, on
instigation of her mother. Inspite of all these practices the Plaintiff
& the other family member tolerated & loved her, maintained
properly and provided her every thing of necessity. since from the
month of June 2022 she left the house of the Plaintiff with Cell
Phone , which worth of Rs. Fifty thousand along with precious
Bridals clothes on pretext of a wedding in her relatives’ house but
she did not come back besides of all efforts of the Plaintiff, family
members and well-wishers but all in vain.

4. That inspite of facts and circumstances mentioned supra the

Plaintiff loves her very much & wants she must join him, perform
conjugal rights and live together within limits prescribed by al-
Mighty Allah.

5. That cause of action accrued to the Plaintiff when she left the
house of the Plaintiff without any reason but entirely on instigation
of her mother.

6. That after rukhsati the Plaintiff and the Defendant resided together
as husband and wife in house of the Plaintiff which is situated
within limits of P.S Orangi Town, which is within jurisdiction of this
Hon’ble Court.

7. That the prescribed court fees stamps has affixed as the suit is
valued in accordance with the provision of Family Court Act.

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       P R A Y E R

    It is, therefore, prayed that this Hon’ble Court may be pleased to
pass judgment and decree against the Defendant and in favour of the
Plaintiff as follows: -

a)          To direct the Defendant to join the Plaintiff as a faithful

wife and live together within limits prescribed by Al-Mighty ALLAH.

b)                Any other relief, which this Hon’ble court deems fit

and proper in the facts and circumstances, mentioned supra because
the Defendant loves her very much.

c)                 Costs of the Suit.

Karachi.
Dated: - ___/12/2022.
PLAINTIFF

Advocate For Plaintiff

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 VERIFICATION

                                   I, Jibran Ansari s/o Naeem Uddin Ansari, Muslim, Adult,

Resident of House No. LS-4Sector 1/C, Mohallah Banaras Nagar, Orangi
Town,
Karachi, do hereby verify and state on oath that whatever stated
above is true correct to the best my knowledge and belief.

Karachi    
Dated: /12/2022.                                                                
Deponent/Plaintiff.

The deponent identified by me

Muhammad Azam Khan

(ADVOCATE)
Solemnly affirmed on oath before me at Karachi on this __ th day of
_______ 2022, by the deponent abovenamed who is identified by
Mr. Muhammad Azam Khan, Advocate whom I know personally.
                                                            The contents of the Plaint have
been read over and explained to the Deponent in Urdu too and he/she
seems to be understood the same and set his/her signature/thumb
impression.

COMMISSIONER FOR TAKING AFFIDAVITS

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