Sample Suit For Khula

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

FAMILY SUIT NO.____/2024

[PLAINTIFF NAME]

W/o: [DEFENDANT NAME]

Muslim, adult, R/o H.no C-44

Mohalla Ishaqabad, Sir Shah

Suleiman Road [AREA REDACTED] Block-1

Karachi ……………………………………….. PLAINTIFF

V E R S U S

[DEFENDANT NAME]

S/o [DEFENDANT FATHER NAME]

Muslim, adult, R/o Flat no.604

Al Rehman Palace 6th floor Shah Wali Road

Mohalla Khada, [AREA REDACTED]

Karachi ...…………………………..………. DEFENDANT

SUIT FOR DISSOLUTION 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: 13-09-1996 according to Muslim rites and Shariat. The dower amount was fixed at the rate of Rs. 501/- only which is still outstanding against the defendant.

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

That the plaintiff also brought with her basic household items including the furniture as the dowry articles from her parents’ house.

That three issues were born out of this wedlock i.e.

[CHILD 1 NAME]

Age: 27 Years

Male

[CHILD 2 NAME]

Age: 25 years

Male

[CHILD 3 NAME]

Age: 17 years

Female

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. The plaintiff tried her level best to save this marriage bond but she failed to do so, due to the uncooperative behaviour of the defendant.

That it is pertinent to mention here that the defendant is a drug addict and is also habitual of gambling as a result of which the plaintiff and her children has suffered from great financial loss.

That it is further pertinent to mention here that the defendant forcefully sold out the gold ornaments belonging to the plaintiff due to his addiction of gambling.

That it is pertinent to mention here that the two children namely: [CHILD 2 NAME] (Son) and Fatima Javed (Daughter) are deaf and dumb by birth and that the defendant never looked after the medical expenses of the children nor took any responsibility