IN THE COURT OF SENIOR CIVIL JUDGE / JUDGE FAMILY
COURT LAHORE.
Muhammad Khalil S/o Muhammad Ali R/o House No 38, Street
no.33, Shama Street, Sultan Mahmood Road, Baghban Pura,
Lahore. PLAINTIFF
VERSES
Sadia Kanwal D/O Bahadar Sultan R/O Mohala Tiba Kila Khazana,
Shalimar Town, Lahore.
DEFENDANT
SUIT FOR RESTITUTION OF CONJUGAL RIGHTS
Respectfully Sheweth:
1. That the plaintiff was married to the defendant according to
Muslim Rights on 27/11/2016 and Sharai Dower was fixed
which was paid by the plaintiff. Copy of Nikhanama attached.
2. That out this wedlock one issue namely Afan Ali was born
out aged about 4 years who is alive and in the custody of
Defendant.
3. That the plaintiff and defendant were living happily and were
performing martial obligation with each other when about 2
years ago the relative of the defendant came in the house of
the plaintiff and requested that a marriage ceremony is going
to be solemnized and the presence of the defendant is
necessary.
3. That the plaintiff agreed and the defendant went with her
relative and took with her cash of 30,000/- and Gold
Ornaments 3 Tolas along with precious cloth and promised
that she will come back with in some days.
4. That as per promised the plaintiff approached defendant
in the house of her parents but the defendant postponed the
matter by one way or other at the instigation of her family. 4.
That the plaintiff went to his father-in-law’s house
at07/04/2022 to bring the defendant, a number of times, but
on one pretext or the other, she declined to come along with
the petitioner to his house.
5. That lastly the plaintiff went to the house of the defendant’s
father at 8 o’clock on 08/11/2024 and asked the defendant to
return with him, but she refused to come.
6. That the defendant deserted the plaintiff and has withdrawn
from his company without any reasonable or lawful excuse;
hence, the plaintiff is leading life of a bachelor.
7. That the plaintiff two weeks before with the elder of family
again approached the defendant’s parent’s house in order to
join the defendant but the defendant totally refused to join
the plaintiff at the instigation of her family members the
elders of plaintiff side asked the right of husband to live with
his wife basis on marriage relationship. Wife is required to
perform her part of the matrimonial obligations towards
husband but defendant straight refused.
8. That the plaintiff has a great love and affection and
cannot live in this world alone hence this suit.
9. That the cause of action arose in favour of the plaintiff and
against one weeks before the defendant when the defendant
refused to join the plaintiff and the cause of action is still
continuing.
10. That the plaintiff is residing at Lahore cause of action
arose at Lahore hence this jurisdiction to try upon the matter.
11. That the requisite court fee of Rs.15 has been affixed on
the plaint.
Prayer:
Hence it is prayed that the decree for restitution of conjugal rights may
kindly be passed in favor of plaintiff. Any other relief which
this Hon’ble Court may deems fit and proper may also be awarded.
PLAINTIFF
Through:
Muhammad Nadeem Yasin
Advocate High Court.
VERIFICATION:
Verified on Oath at Lahore this 04th day of January, 2025 that the
contents of the Paras No. 1 to 9 are correct to the best of my
knowledge and the contents of rest of the paras are true to the
best of my belief.
PLAINTIFF
