Sample Sundus Exparte Proof

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

FAMILY SUIT NO._____ /2023

[PLAINTIFF NAME]

D/o: [FATHER NAME]

Through her attorney: [ATTORNEY NAME]

D/0: [ATTORNEY FATHER NAME], Muslim, adult,

R/o Roofi Apartments, House No. F 20,

Block 13- D2, [AREA REDACTED]

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

V E R S U S

[DEFENDANT NAME]

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

R/o Roofi Apartments, House No. F 20,

Block 13- D2, [AREA REDACTED]

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

EX PARTE PROOF ON BEHALF OF THE PLAINTIFF

The plaintiff above named respectfully submits as under:

That I say that the plaintiff and defendant entered into a bond of marriage dated: 7-03-2011 according to Muslim rites and Shariat. The dower amount was fixed at Rs. ten thousand only which is still outstanding against the defendant.

That I say that the plaintiff also brought with her one set of gold jewellery and basic household items including the furniture as the dowry articles from her parents’ house.

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

[CHILD 1 NAME]

Age: 11 yrs 7 month

Son

[CHILD 2 NAME]

Age: 9 yrs 1 month

Son

[CHILD 3 NAME]

Age: 5 yrs 6 month

Daughter

[CHILD 4 NAME]

Age: 3 yrs 4 month

Son

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. 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 I say that it is pertinent to mention here that the defendant had been involved in having extramarital affairs to date 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 often speaks of explicit and immoral acts about other women to the plaintiff.

That I say that the defendant has badly failed to perform his marital duties and obligations with the plaintiff.

That I say that the plaintiff has now developed a strong hatred in her heart against the defendant and she cannot live with hi