Sample Khula Rubab

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

FAMILY SUIT NO._____/2022

[PLAINTIFF NAME]

D/o [FATHER NAME] Muslim,

Adult R/o House No. 63/3/G, Sector 18-C,

[AREA REDACTED]

Karachi………………………………………………....PLAINTIFF

V E R S U S

[DEFENDANT NAME]

S/o [DEFENDANT FATHER NAME] Muslim, adult,

R/o House No. 10, Sector 89, 5G,

[AREA REDACTED]

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

S.NO:

DESCRIPTION

ANNEXURE

PAGES

1.

Memo of Plaint along with

Verification

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1-

2.

Photocopy of Nikkahnama

“A”

3.

Photocopy of the utility bill

“A1”

4.

Court fee

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----

5.

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

FAMILY SUIT NO._____/2022

Mst. Rubab Roshan

D/o [FATHER NAME] Muslim,

Adult R/o House No. 63/3/G, Sector 18-C,

[AREA REDACTED]

Karachi………………………………………………....PLAINTIFF

V E R S U S

[DEFENDANT NAME]

S/o [DEFENDANT FATHER NAME] Muslim, adult,

R/o House No. 10, Sector 89, 5G,

[AREA REDACTED]

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

SUIT FOR DISSOLATION OF MARRIAGE BY WAY OF KHULA UNDER SECTION 14, MUSLIM FAMILY LAW ORDINANCE 1961

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

 That the plaintiff and defendant entered into a bond of marriage dated: 16-08-2019 according to Muslim rites and Shariat. The dower amount was fixed at Rs. One hundered thousand rupees only which is still outstanding against the defendant.

(Copy of Nikkahnama is filed herewith as annexure A)

That the marriage between the Plaintiff and the Defendant was an arranged one and the Defendant left for UAE after marriage. The initial few days of the marriage passed smoothly. However, thereafter the Defendant's attitude towards the Plaintiff became indifferent and with the passage of time his behavior worsened which gave rise to serious irreconcilable differences between the parties and this made the life of the Plaintiff miserable.

That The Defendant started putting unreasonable restrictions on Plaintiff just to annoy her and mentally torture her, including attempting to prevent her from attending her cousin’s wedding and other family events. He would not even allow her to go out without first