SUIT FOR DISSOLUTION OF MARRIAGE

IN THE COURT OF SENIOR CIVIL JUDGE WITH

 THE POWER JUDGE FAMILY COURT, DADU

Mst. ABC d/o D.M Cast           , R/o    , Tehsil & District,      

…PETITIONER

Vs.

Mr.      S/O                   R/o     District,           .

…RESPONDENT

SUIT FOR DISSOLUTION OF MARRIAGE

Respectfully Sheweth:

1)      That the petitioner was married with the respondent three years back according to the principle of Muslim Law, at                        where the petitioner along with her parents resided.

2)      That a dower of Rs. 2 lacs was fixed. The Nikahnama was accordingly registered with Union Council                         .

3)      That Rukhsati took place on the same day where the marriage was sermonized, dowry articles amounting at Rs. 10 lacs were given by the parents of the petitioner as Jahaiz which was received by the respondent and presently are lying with the respondent at his residence.

4)      That a true list of the dowry articles duly attested is placed at Annexure-A. Attested copy of Nikahnama is also placed at Annexure-B, with may be read as integral part of this petitioner.

5)      That a son was born to the petitioner from this wedlock who is two years old and presently residing with the petitioner and is being looked after and maintained by the petitioner.

6)      That relationship between the spouses remained cordial for few months where after relations become restrained. The respondent become cruel and callous and often use to beat the petitioner sometimes with iron rod.

7)      The reasons of the bitterness created between the spouses was the first marriage of the respondent. As matter of fact with respondent was already a married person having two children, the first wife of the respondent was living at another District, which fact was concealed from the petitioner and her relations.

8)      That the due to this facts the petitioner has developed a fixed hatred and aversion against the respondent, who has made life of the petitioner miserable.

9)      That the petitioner seeks dissolution of marriage on the basis of khula and is ready to forgo her right of over the dower money amounting to Rs. 2 lacs.

10)  That cause of action accrued in favour of the petitioner and against the respondent on     when the marriage it also accrued a few months ago when the respondent become callous and cruel and gave severe beating to the petitioner.

11)  That the parties reside at Dadu where marriage to place. The petitioner presently reside with her present at Dadu as such this honourable Court has jurisdiction to hear and adjudicate upon the matter.

12)  That a court fees of Rs. 15,000/- is affixed according to law.

Prayer

It is respectfully prayed that this honorable court is pleased to accept this petition and grant decree of dissolution of marriage on the basis of Khula as provided in law.

Any relief which this honourable court may deem fit is further prayed.

PETITIONER

Through

Counsel

Verification:

Verified on oath at Dadu the 10^th of September, 2010 that the contents of Para No. 1-9 are true to the best of my knowledge and that of Paras No.10-12 to thebest of my information.

PETITIONER