Fareeha ex Parte Proof Redacted

IN THE COURT OF XXXth FAMILY JUDGE AT KARACHI

EAST

Family Suit No. [REDACTED]/2024

[REDACTED]

Daughter of [REDACTED]

Muslim, adult, R/o

H.no [REDACTED] Block # 13-B,

Muhalla, Allah Wala Town [REDACTED], Korangi [REDACTED],

Karachi. ……………..……………………….. Plaintiff

Master [REDACTED]

S/o [REDACTED]

Baby [REDACTED]

D/o [REDACTED]……………………Minor(s)

VERSUS

[REDACTED]

S/o [REDACTED],

Muslim, adult, R/o

H.no [REDACTED], Street No. [REDACTED],

Block # 32-A, Mohalla [REDACTED]

Korangi [REDACTED],

Karachi…………………………...………….. Defendant

EX PARTE PROOF ON BEHALF OF PLAINTIFF

The plaintiff above named respectfully submits as under:

That I say that the plaintiff and the defendant entered into a bond of marriage dated on [DATE REDACTED] according to Muslim rites and Shariat. The dower amount was fixed at 50,000/= (Rupees Fifty thousand only), which is still outstanding against the defendant.

That I say that two issues were born out of this wedlock i.e.

That I say that soon after the marriage the behaviour of the defendant became very harsh and cruel towards the plaintiff. The plaintiff was also a victim of verbal abuse and mental torture.

That I say that the plaintiff tried her level best to save the marriage bond but she failed to do so, due to the uncooperative behaviour of the defendant.

That I say that it is pertinent to mention here that the plaintiff filed the Habeas Corpus before in the Hon’ble Court [COURT REDACTED] Karachi East H.C.P No. [REDACTED]/2025, the application was allowed and an order dated [DATE REDACTED], in which handed over the custody of both minors to the plaintiff in an open court, since the [DATE REDACTED] the minors have been living with the plaintiff.

That I say that it is pertinent to mention here that the defendant had been negligent towards the plaintiff and the minors regarding the maintenance and when the plaintiff confronted the defendant on it then the defendant mistreated and used foul language with the plaintiff.

That I say that the defendant has badly failed to perform his marital duties and obligations with the plaintiff as well as parental obligation towards the minor.

That the I say that the defe