Sample Khula Hiba

IN THE COURT OF CIVIL & FAMILY JUDGE (CENTRAL) KARACHI

FAMILY SUIT NO._____/2022

[PLAINTIFF NAME] & ANOTER ………………………………………………. PLAINITFF(s)

V E R S U S

[DEFENDANT NAME] ……………………………..……………………………. DEFENDANT

S.NO:

DESCRIPTION

ANNEXURE

PAGES

1.

Plaint

2.

Affidavit in support of plaint

3.

Photocopy of Nikkahnama

4.

Medical report and receipts of medical report

5.

List of dowry articles

6.

Receipts of dowry articles

7.

list of gold ornaments

8.

Receipts of gold ornaments

9.

Application u/s 17 A

10.

Affidavit in support of Application u/s 17 A

11.

Vakalatnama

ADVOCATE

IN THE COURT OF CIVIL & FAMILY JUDGE (CENTRAL) KARACHI

FAMILY SUIT NO._____/2022

Mst. [PLAINTIFF NAME]

D/o [FATHER NAME] Muslim, adult,

R/o Plot No. R-874-3rd Floor 3-B

Block-15 [AREA REDACTED]

Karachi.

MUHAMMAD AFNAAN

S/0 [DEFENDANT NAME] Muslim, minor,

R/o Plot No. R-874-3rd Floor 3-B

Block-15 [AREA REDACTED]

Karachi……………………………………………………. PLAINITFF

V E R S U S

[DEFENDANT NAME]

S/o [DEFENDANT FATHER NAME] Muslim,

Adult, R/o Journalist Society, House No.69-A,

Block 4 A, [AREA REDACTED]

Karachi.………………………………..……………… DEFENDANT

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULA AND MAINTENANCE AND RECOVERY OF DOWRY ARTICLES

The Plaintiff above named respectfully begs to submit as under:-

 That the plaintiff and defendant entered into a bond of marriage dated: 22-12-2019 according to Muslim rites and Shariat. The dower amount was fixed at Rs. fifty one thousand only which is still outstanding against the defendant.

(Copy of Nikkahnama is filed herewith as annexure “A”).

That the plaintiff also brought with her sets of gold jewellery and basic household items including the furniture and electronic appliances as the dowry articles from her parents house which are still lying with the defendant.

(List of the dowry articles and gold ornaments marked as annexure )

That one issue was born out of this wedlock i.e.

[MINOR NAME]

Age: 2 years

Son

That soon after the marriage the behaviour of the defendant became very harsh and cruel towards the plaintiff. The plaintiff was also a victim