Civil Petition For Separation Under Section 10 22 And 23 of Christian Marriage 1869 And Recovery of Maintenance

IN THE COURT OF XXTH FAMILY JUDGE AT KARACHI EAST

Family Suit No. /2013

1) Mst. Sarafeen

D/o Babu Palous,

W/o Saul Badshah,

Christian, adult, resident of

House No.563, Korangi No.5 ½,

Karachi

2) Baby Escol, D.O.B. 26/09/2002

3) Baby Jamaima, D.O.B. 05/12/2006

4) Master Adrel, D.O.B. 22/07/2009

all minors, residing with their mother/

petitioner ….………….Petitioners

Versus

Mr. Saul Badshah

S/o Sadiq Badshah,

Christian, adult, resident of

Church of Pakistan, Manzoor Colony,

C/o Pastor Asif Ahmed, Karachi. ……………. Respondent

CIVIL PETITION FOR SEPARATION U/S. 10, 22, & 23 OF CHRISTIAN MARRIAGE 1869 AND RECOVERY OF MAINTENANCE

The petitioner above named most respectfully submits as under:

That the petitioner abovenamed was married with the respondent on 20/12/2001 at Korangi, Karachi according to Christian Law and the marriage was solemnized and co-habitation took place on the same day.

Marriage Certificate is in the custody of the respondent and there is no copy available with the petitioner.

That after marriage both the petitioner and respondent were lived together as husband and wife since long and out of that wedlock the children namely (1) Baby Escol, D.O.B. 26/09/2002, (2) Baby Jamaima, D.O.B. 05/12/2006 & (3) Master Adrel, D.O.B. 22/07/2009 were born, all are presently in custody and under care of their mother/petitioner.

That after passing many years, the true colour of the respondent transpires and behavior towards the petitioner become harsh and due to his behaviour and conduct has shown himself to be hot temper man.

That the respondent discharged his liabilities being a husband and petitioner herself beard all expenses but the respondent ignored the petitioner and also not taking care the children.

That the respondent did not take care/maintain the petitioner and respondent has no responsibility about the petitioner and regularly cruel with his wife / petitioner.

That the attitude of the respondent was not good towards the petitioner and he used to misbehave with the petitioner.

That there is no collusion or connivance between the petitioner and the respondent with respect to the subject