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IN THE COURT OF SENIOR CIVIL JUDGE WITH

THE POWERS OF JUDGE FAMILY COURT AT


LAHORE.

FAMILY SUIT NO__________/2012


Abdul Sallam Bokhari son of Qamar-ud-Din resident of House
No. 348, Yasir Block, Nishter Colony Feroze Pur Road Lahore.
PLAINTIFF
VERSUS
Khadeeja Bokhari wife of Abdul Sallam Bokhari daughter of
Irfan Maqsood resident of House No. 70, Street No. 15,
Liaqatabad, Lahore.
DEFENDAN
T

SUIT

FOR RESTITUTION OF CONJUGAL


UNDER FAMILY COURTS ACT, 1964.

RIGHTS

Respectfully Submitted as under;


1. That the addresses of the parties as given above in the
head-note of this suit are true and correct for the purpose
of effective notices/summons upon them through the
process of this Honorable Court issued from time to time.

2. That the concise facts giving rise to file the suit are that
on 27-01-2006 the plaintiff was married with defendant
according to Muslim Rites and Shariah Mohammadi. Copy
of Nikah Nama is attached for the kind perusal of this
Honorable Court.
3. That the plaintiff and defendant are still husband and
wife inter-se. That the plaintiff and defendant lived
happily

and

amicably

after

the

marriage,

but

subsequently, in the month of September 2011, the


defendant went to the house of her parents on pretext to
attend wedding ceremony of some relative of her parents
alongwith entire gold ornaments and precious clothes
etc, but later on, she refused to come back in the house
of the plaintiff and to live with him and to perform her
matrimonial obligations towards plaintiff without any
justification and cogent reason.
4. That the plaintiff has effort many times to reconciliate
the matter on his part, but the defendant is not ready
and wiling to join him at any cost.
5. That the defendant has also filed a suit for Dissolution of
Marriage while raising frivolous allegations upon the
plaintiff. That the plaintiff is always ready to join her, but
she is reluctant to join the plaintiff without any cogent
reason.
6. That the plaintiff along with elders of the family, number
of times requested the defendant to live with him, but he

flatly refused to accede the genuine and legal request of


the plaintiff without any cause, hence this suit.
7. That the cause of action has firstly accrued to the
plaintiff and against the defendant in the month of
September 2011 and finally two weeks ago, when the
defendant flatly refused to reconciliate the plaintiff, and
the same is still continuing.
8. That the parties to the suit are the resident of Lahore, the
cause of action also accrued at Lahore, Nikah Nama is
also registered at Lahore, therefore, this Honorable Court
has got jurisdiction to entertain and adjudicate upon the
matter.
9. That the requisite court fee has been affixed on the
plaint.

PRAYER
It is, therefore, most respectfully prayed that a Decree of
Restitution of Conjugal Rights may very graciously be passed
in favour of the plaintiff and against the defendant directing
the defendant to join the plaintiff and to perform her
matrimonial obligations towards plaintiff.
Any other relief which this Honorable Court deems fit and
proper may also be awarded to the plaintiff.
THROUGH

PLAINTIFF

MOHAMMAD SHAHZAD MUSHTAQ


(Advocate High Court)
1 Floor, Arif Latif Building 13-Justice
M.R Kiyani (Fane) Road Lahore.
st

VERIFICATION:Verified on oath at Lahore this 18 th day of April 2012 that


the contents of the above plaint from Para 1 to 5 are true to
the best of my knowledge and those of 6 to 8 are true and
correct to the best of my knowledge and belief.

PLAINTIFF

IN THE COURT OF SENIOR CIVIL JUDGE WITH


THE POWERS OF JUDGE FAMILY COURT,
LAHORE.

IN RE:-

Abdul Sallam Bokhari

VS

Khadeeja

Bokhari
(SUIT FOR RESTITUTION OF CONJUGAL RIGHTS UNDER FAMILY COURTS ACT,
1964.)

SEHEDULE OF WITNESSES ON BEHALF OF THE


PLAITIFF.
1. Qari AbduL Khaliq son of Ghulam Murtaza resident of
563 Usama Block, Nishter Colony Lahore.
2. Abdul Ghaffar son of Qamar-ud-Din resident of Nishtar
Colony, Ferozepur Road, Lahore.
3. Atta Ullah son of Ghulam Murtaza resident of Garhi
Shahu Lahore.
4. Plaintiff himself.

ALL THE WITNESS WILL SUPPORT THE CONTENTS OF TH


PLAINT.
PLAINTIFF
THROUGH

MOHAMMAD SHAHZAD MUSHTAQ


(Advocate High Court)
1 Floor, Arif Latif Building 13-Justice
M.R Kiyani (Fane) Road Lahore.
st