IN THE COURT OF Ist FAMILY JUDGE KARACHI

(SOUTH)
Family Suit No. /2012
Maria Habib d/o Chaudhry Habib Rizvi,
Muslim, Adult, r/o House No 305R
sector 2D Nizami Road Jacob Line Near
Numaish Chorangi Karachi.
………………………………………………………………………PLAINTIFF
Shahid Akram Khan s/o Bashir Akram Khan,
Muslim, Adult, r/o House No. A-316 punjab
club haq manzil kharadar karachi
……………………………………………………………………DEFENDANT
SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF
KHULA
The Plaintiff abovenamed humbly submits as follows:
1. That the Nikah of the Plaintiff and the Defendant was
solemnised at Karachi on 10/03/2012 in accordance with
Sunni Muslim Personal Law on a dower amount of Rs. 5,
000/- (Rupees Five thousand Only). It is pertinent to mention
here that the Plaintiff brought a cash amount of Rs. 500,
000/- (Rs. Five Hundred Thousand Only) as dowry.

(Photo copy of the Nikahnama is annexed herewith and marked as

annexure “P-1”)

2. That the Defendant is a jobless person and is also whiling

away his time in anti-social activities in as much as does not
bear good moral character.

3. That, pursuant to the marriage, it came to the knowledge of

the Plaintiff that the Defendant is both an alcoholic and drug

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 addict. It is submitted that the Defendant, on a regular basis,
comes home late in the night in an intoxicated state.

4. It is submitted that the Defendant is involved in gambling and

he frequently invites his friends over to play cards and
consume alcohol and smoke drugs.

5. It is also submitted that the Defendant makes use of

unparliamentary languages with every one including the
Plaintiff.

6. That the Defendant has time and again been requested by

the Defendant as well as her parents to amend his habits but
to avail.

7. That, on 05/05/2012, the Plaintiff learned that the Defendant

had stolen the entire amount which the Plaintiff had brought
as dowry and wasted it all on alcohol.

8. It is submitted that given the facts narrated hereinabove, the

Plaintiff is unable to co-exist with the Defendant within the
limits settled by the Shariah, inasmuch as hatred has
developed in the heart of the Plaintiff, and, she is, hence,
seeking dissolution of her marriage with the Defendant in
exercise of her right of Khula, hence, this suit.

9. That the cause of action accrued in favour of the Plaintiff for

the facts and reasons disclosed hereinabove. The Plaintiff
resides within the limits of P.S. ______________________,
which falls within the territorial jurisdiction of this Hon’ble
Court. Proper court fee has been affixed herewith.

PRAYER

It is, therefore, in the interest of equity, justice and good

conscience, prayed that this Hon’ble Court may be pleased to
pass a Judgment and Decree as follows:

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 a. Dissolve the marriage between the Plaintiff and the
Defendant by way of Khula.
b. Grant any other, better, further and/or equitable relief
that this Hon’ble Court deems fit, proper and necessary given
the prevalent facts and circumstances in the instant case.
c. Costs of the suit may be awarded.
Karachi
Dated: 25/05/2012

PLAINTIFF

ADVOCATE FOR THE PLAINTIFF

VERIFICATION
I, Maria Habib d/o Chaudhry Habib Rizvi, Muslim, Adult, r/o
House No. 11, Block-II, Green Belt, P. E. C. H. S., Karachi,
holding CNIC No. 45426- 5129562-6, do hereby on solemn oath
and affirmation submit that whatever is stated above is true
and correct to the best of my knowledge and belief.

DEPONENT
Identified by me.

ADVOCATE
Solemnly affirmed before me on this 25th day of May, 2012 by
the deponent above named, who is identified to me by Ms.
Maria Ahmed, Advocate, who is personally known to me.

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COMMISSIONER FOR TAKING AFFIDAVITS

Document(s) filed: Annexure ‘P-1’

Document(s) relied upon Annexure ‘P-1’and all other documents that are
necessary and relevant to the subject matter.

Address for service.

Address for the As mentioned in the Title

Plaintiff’s counsel: As mentioned in the Vakalatnama

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