PLAINT

IN THE FAMILY COURT, LAHORE

Hina Jillani D/O Akram Jillani R/O House # 51, Street No.3, Nisar Colony, Lahore Cantt,
District Lahore.

…..Plaintiff

VERSUS

Abdul Rehman S/O Muhammad Haider Shabbir R/O House # 81, Block-D, Wapda Town,
District Lahore.

…..Defendant

SUIT FOR DISSOLUTION OF MARRIAGE

Respectfully Sheweth:

1. That the plaintiff was married with the defendant on 26th January 2013 at Lahore and Nikah
was solemnized and registered according to Muslim rites before witnesses and other family
members, in consideration of dower amount of Rs. 2,00,000/- which is still unpaid. A copy
of marriage certificate is attached as Annexure A.
2. That after marriage, relations between the spouses did not ever remain in a harmonious
married life from the very inception and then the defendant started to inflict mental &
physical torture and mal-treated the Applicant.
3. That the plaintiff has been residing at her parent’s home situated at Nisar Colony since 23rd
February, 2017 and no maintenance was ever paid by respondent to applicant till then.
4. That from the date of expulsion from her husband’s home, the relatives of plaintiff had
been approaching the defendant requesting him to either take the plaintiff back to his house
and give her maintenance or dissolve the marriage by giving divorce but to no avail.
5. That the defendant had contracted a second marriage on 17th December, 2018 without
plaintiff’s permission in contravention to the provisions of Muslim Family Laws
Ordinance, 1961 and then plainly refused to divorce the plaintiff or to take her back or to
provide her maintenance.
 6. That the cause of action firstly arose on 23rd February, 2017 when after severely torturing
the plaintiff, defendant turned her out of doors and defendant was left with no option except
to start residing at her parent’s home since then and secondly on 17th December, 2018 when
defendant contracted second marriage.
7. That the plaintiff and defendant reside at Lahore and the cause of action arose at Lahore,
therefore the Family Court is entitled to decree this suit.
8. That since it is a family suit, therefore Court fee Rs. 15/- have been affixed on this plaint.

PRAYER

In circumstance narrated above, it is humbly prayed to this Honorable Court that:-

1. A decree of dissolution of marriage may kindly be passed in favour of the plaintiff and
against the defendant.
2. Heavy costs may also be awarded to the plaintiff.
3. Any other relief by this Honorable Court may deemed possible also be granted.

Plaintiff

Through Counsel:

Ammara Afzaal Siddiqui

Advocate High Court

Lahore, District Lahore.

VERIFICATION:

Verified on oath at Lahore on this 24th day of July 2019, that the contents of paras 1 to 4
are true to the best of my knowledge and those of paras 5 to 8 are correct the best of my information
and belief.

Plaintiff