Draft of Suit For Dissolution of Marriage on the Basis

of Khula

IN THE COURT OF SENIOR CIVIL JUDGE, FAMILY JUDGE, (WEST)

ISLAMABAD

Family Suit No:______/2016

Wife ABC D/o def, R/o House No: 000, Street No:000, Sector: 000, Islamabad

……………….Plaintiff

VERSUS

Husband ghi S/o Jkl R/o House No: 00, Street No:00, Sector 00, Islamabad

……………Defendant

SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULA

Respectfully Sheweth:

1. That the plaintiff and defendant entered into a bond of marriage in the
year 1998 according to Muslim rites and Shariah. The dower amount was
fixed @ Rs. fifty thousand only which is still outstanding against the
defendant.
2. That after the marriage the attitude of the defendant became very harsh
and cruel towards the plaintiff. The defendant also concealed the fact
that he is already married. He also had to daughters from his previous
marriage.
3. That with the passage of time the attitude and behavior of the
defendant became cruel and harsh. The plaintiff was also a victim of
domestic violence and mental torture. The plaintiff tried her level best to
save this marriage bond but she failed to do so, due to the
uncooperative behavior of the defendant.
 4. That it is also pertinent to mention here that the defendant has badly
failed to provide maintenance to the plaintiff in the past eighteen years.
The defendant never had a job or business throughout his life. The
defendant sold the jewelry from time to time and he used to force the
plaintiff to bring money from her family. The defendant took all her
savings and her share in the property of her father.
5. That the plaintiff left with no choice and started working for herself. For
the last eighteen years, the plaintiff is earning in order to live a happy
married life. The defendant never provided even a single penny on
account of maintenance rather plaintiff used to pay the rent of the
house, groceries, boarding, lodging, and expenditures of the defendant.
6. That on the 20th of December, the defendant has beaten the plaintiff
inhumanly and turned her out of his house in the middle of the night.
The plaintiff called the brother of the defendant who immediately came
and rescued the plaintiff. The brother of the defendant stayed there till
morning in order to save the plaintiff. The Very next morning plaintiff’s
brother and sister came to take her in their home.
7. That defendant has badly failed to perform his marital duties and
obligations with the plaintiff and the defendant did not provide any
maintenance to the plaintiff.
8. That plaintiff has now developed a strong hatred in her heart against the
defendant and she cannot live with him as a wife within the limits
prescribed by the Allah almighty.
9. That plaintiff seeks dissolution of marriage on the ground of non-
provision of maintenance, cruelty, mental torture, and on the basis of
khula, for which she is ready to forego her dower.
10.That the cause of action accrued to the plaintiff firstly when the
defendant turned the plaintiff out of his house and secondly a week ago
when he refused to maintain her and also refused to have any contact
with her.
11.That the cause of action accrued to the plaintiff at Islamabad. The
parties are also the resident of Islamabad, hence this court has
jurisdiction to try and entertain the present suit.
12.That the appropriate court fee has been affixed on the plaint.
PRAYER:
It is most respectfully prayed that the decree for dissolution of marriage on
the basis of khula may kindly be passed in favor of the plaintiff against the
defendant.

Any other relief this honorable court deems fit and proper may also be
awarded.

Plaintiff

Through

Counsel

VERIFICATION:

Valid on oath at Islamabad on this day___ of December 2016, that the contents
of the plaint are true and correct to the best of my knowledge and nothing
has been concealed from this honorable court.

Plaintiff

CERTIFICATE:

Certified that this is the first case filed by the plaintiff on this subject and no
other case is pending before any other court, High Court or Supreme Court

Plaintiff