IN THE COURT OF FAMILY JUDGE HYDERABAD
Family Suit No. Of 2024
Mst Hafsa W/O Sibtain Khatri Adult Muslim
R/O House No: B/32 Muhalla Sahafi Colony
Hyderabad City, District Hyderabad Plaintiff.
Versus
Sibtain Khatri S/O Abdul Hafeez Adult Muslim
R/O House No: B/32 Muhalla Sahafi Colony
Hyderabad City, District Hyderabad Defendant.
SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF
KHULA
The plaintiff above named respectfully submits as under:-
1. That the plaintiff was married with the defendant on dated
10-02-2018, according to principles of Islam against Haq
Maher of Rs.5000/- which has been paid to the plaintiff.(the
copy of nikahnama is annexed here)
2. That the defendant is mentally ill person and involved in ill
activities and he has leveled plaintiff with false charges
without any proof.
3. Wedlock plaintiff was blessed with one child namely
Muhammad Araham aged about 3 years who is residing with
the plaintiff.
4. That the defendant also failed to provide proper
maintenance to the Plaintiff and did not provide proper
requirements of daily life and medical treatment to her.
5. That being an eastern lady, the Plaintiff tolerated the
situation and circumstances, with the hope that the
defendant will mend himself in future but all hopes went in
vain.
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6. That the Defendant failed to give love and affection to the
Plaintiff even always kept the Plaintiff in mental and physical
torture, always mal treated and agony and forcefully ousted
her from house on dated 05/12/2020 without knowledge and
intimation and since he is not in contact to the Plaintiff .
7. That the defendant numbers of time has physically tortured
to plaintiff and plaintiff complained to his elders but all went
in vain.
8. That the cause of action accrued to the Plaintiff for filing the
present suit when the Defendant started maltreating the
Plaintiff and remained failed to provide maintenance to her
then ousted the Plaintiff from house without knowledge and
intimation and the same cause of action continues arose
day to day till today.
9. That because of the above facts and circumstances the
Plaintiff had developed severe hatred in her mind and heart
against the defendant and now it has become impossible for
her to pass future life with the defendant as her wife and
she will prefers to die rather to live with the defendant within
the limits prescribed by the almighty Allah the Plaintiff
therefore claims to dissolve of her marriage by way of Khula
and she is prepared to forego her dower amount in lieu of
Khula. Hence this suit.
10. That the plaintiff is residing within the jurisdiction of this
Honourable Court, hence this Honourable Court is competent
to adjudicate upon the matter.
11. That the required court fee of Rs.15/- is affixed on the plaint.
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12. The plaintiff, therefore, prays for Judgment and Decree as
under:-
PRAYER
a) That this Honourable Court may be pleased to
dissolve the marriage of Plaintiff with the defendant
or in alternative the marriage of the Plaintiff be
dissolved by way of Khulla.
b) Costs of the suit be awarded to the plaintiff;
c) Any other relief.
Hyderabad,
Dated. .07.2024 PLAINTIFF
VERIFICATION
I, Mst: Mst Hafsa W/O Sibtain Khatri Adult Muslim R/O House No:
B/37 Muhalla Sahafi Colony Hyderabad City, District Hyderabad, do
hereby verify on oath that whatever stated above is true and correct
to the best of my knowledge and belief.
Deponent.
I know the deponent.
Advocate
Affirmed on oath before me on this___day of JULY 2024 by the
deponent who has been identified by Mr. NAEEM BALOCH
Advocate, who is known to me.
Commissioner for taking affidavit
Documents filed.
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IN The COURT Of CIVIL JUDGE And FAMILY JUDGE- IX
HYDERABAD.
Family Suit No. of 2024
Mst: Fahmida . . . . . . . . . . . . . . . . . . . . . . . . . . . Plaintiff.
Vs
Abdul Hakeem. . . . . . . . . . . . . . . . . . . .Defendant.
AFFIDAVIT
I, Mst Hafsa W/O Sibtain Khatri Adult Muslim R/O House No:
B/37 Muhalla Sahafi Colony Hyderabad City, District Hyderabad do
hereby solemn affirmation as under:-
01. That I am the plaintiff in the above suit and as such am well
conversant with the matter.
02. That the accompanying affidavit has been drafted under my
instructions.
03. That nikahnama is in the custody of defendant which I
cannot produce before this Honourable Court.
04. That nikahnama may be produced by the defendant in his
reply.
05. That for the sake of brevity the contents of affidavit may be
treated as part and parcel of record.
Whatever stated above is true and correct to the best of
my knowledge and belief.
HYDERABAD
Dated - 07 -2024 Deponent.
The deponent is identified by me to the commissioner for
taking affidavit.
Advocate
The deponent is identified by Mr. NAEEM BALOCH Advocate who
is personally known to me.
Commissioner for taking affidavit.
Contents of this affidavit truly and audibly read over to the
deponent above named in his mother tongue who appears to have
understood the same and put his signature in my presence.
Commissioner for taking affidavit
