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IN THE COURT OF FAMILY AND CIVIL JUDGE SUKKUR

Family Suit No. 216 of 2011

Mst. Nasreen D/o Muhammad Ramzan by caste Shaikh,


Muslim, Adult R/o Waspur Muhalla Royal Road
Old Sukkur..Plaintiff.

V E R S U S

Hidayatullah S/o Sher Muhammad by caste Shaikh,


Muslim, Adult R/o Near Local Board Sukkur
..Defendant

Cross Examination on the Deposition of Gulzar Ahmed S/o


Muhammad Jaffer by caste Shaikh.

Dated:09-06-2012
Recalled and Reaffirmed on oath
Cross to Mr. Ishrat Qayoom Advocate for Defendant

On 18-04-2010 the marriage of both the


parties was solemnized, I had attended this marriage, I
know witness of this Nikah namely Mehan Ali and
Mohammad Malook. They are relatives Mst. Nasreen is my
real nice. At the time of Nikha the Haq Mahar was fixed
gold ornaments worth of Rs.50,000/-. It is correct to
say that it is mentioned in the nikhanama the Haq Mahar
Rs.50,000/- in shape of gold ornaments has been paid to
plaintiff, actual it has not been paid. The defendant
is also my relative. It is correct to say that at the
time of Nikha the parents of plaintiff did not raise
objection about the Haq Mahar in shape of 3 Tola gold
ornaments. It has correct to say that my counsel had
read over the contains of affidavit-in-evidence. The
plaintiff left the house of defendant on 1st week of
April, 2011, it is correct to suggest that she passed
happy life with her husband for about 7/8 Month. I do
not know weither weather she left the house of
defendant with her brother. It is incorrect to suggest
that she took all the gold ornaments alongwith her
brother. I can not say that she left the house of
defendant she was pregnant or not. It is incorrect to
suggest that there is one issue from the defendant I do
not know that the parents of plaintiff made miscarriage
of pregnancy. The parents of plaintiff gave the dowery
articles in my presence. It is fact that the
list/receipt of dowery articles was prepared at the
time of marriage. It is correct to say that no
signature is present on the list of dowery articles nor
was obtained at the time of marriage when the dowery
articles were given to the plaintiff. The parents has
arranged room including furniture and fix him, the
parents of plaintiff had given the following articles.
(1) T.V (2) Bed Set (3) Gold Finger Ring. Half tola
gold set, Jooser Machine, Water Set. 25 pairs of
clothes. It is incorrect to say that I have not produce
the list of dowery articles and the receipt alongwith
my affidavit-in-evidence. It is incorrect to say that
the parents of plaintiff did not gave any dowery
articles. The defendant has a private Job. I can not
say that the defendant has a private Job at the time of
Marriage the Salary of defendant was 10,000/- I do not
know weither the plaintiff and defendant lived a happy
life. She did not complaint to me when she was at the
house of defendant. It is correct to say that we had
gone to the house of defendant to emmicable settlement
the dispute but failed to set any passitive response by
the defendant side. Thereafter she file the suit-for-
dissolution of marriage. It is correct to say that the
plaintiff filed the present suit at the mistance of her
parents. It is incorrect to suggest that I have come
before this court for evidence due at the instance of
the parents of plaintiff it is incorrect to suggest
that I am deposing false and this case is managed and
false.
NO RE
SRO And AC
Sd/-09-06-2012
Family Judge Sukkur
IN THE COURT OF FAMILY AND CIVIL JUDGE SUKKUR
Family Suit No. 216 of 2011

Mst. Nasreen D/o Muhammad Ramzan by caste Shaikh,


Muslim, Adult R/o Waspur Muhalla Royal Road
Old Sukkur..Plaintiff.

V E R S U S

Hidayatullah S/o Sher Muhammad by caste Shaikh,


Muslim, Adult R/o Near Local Board Sukkur
..Defendant

Cross Examination on the Deposition of Mst. Nasreen D/o


Muhammad Ramzan by caste Shaikh.

Dated:09-06-2012
Recalled and Reaffirmed on oath
Cross to Mr. Ishrat Qayoom Advocate for Defendant

My marriage was solemnized with


Hidayatullah on 18-03-2010. It is fact that the
defendant Hidayatullah is my relative. At the time of
Nikha there were to witness Mohammad Mehar and Malook
who attended the Nikha. It is correct to suggest that
the witness Mohamamd was not present in my Nikha. It
is fact that the witness Abdul Ghani was present in my
nikha. It is fact that the Haq Mahar was fixed of
Rs.50000/- in shap of gold ornaments. It is incorrect
to suggest that the defendant did not pay the Haq Mahar
in shap of gold ornaments. It is incorrect to suggest
that it is mention in my nikhanama that in Colum No.13
which is not correct. It is correct to suggest that I
was readover my affidavit in evidence by my counsel. It
is correct to suggest that relevant documents is
attached with my affidavit in evidence. It is incorrect
to suggest that I left the House of Hidayatullah on 26-
05-2011 with my own consent. It is incorrect to suggest
that I took Rs.20000/- from the house of defendant
alongwith 3 tola gold ornaments. It is incorrect to
suggest that when I left the house of defendant when I
was pregnant. It is incorrect to suggest atht I have
deliver any issue from Hidayatullah in para No.4 it is
mention that there is one issue to me from defendant.
It is correct to say that I see the list of dowery
articles. I prepared the list of dowery articles my
self. I prepared the said list at the time of filling
of the suit. It is fact that this marriage, with
defendant was solemnized with consent of my elders. It
is incorrect to suggest that of the time of my rukhsati
nothing was given to me as dowery articles by me
pirates. My parents gave some dowery articles are as
under (1) T.V (2) washing Machine (3) Bed Room set
(4)pedestal fen (5) chopper Machine (6) Iran (7) Tea
set (8) Dinner Set (8)Cutrely Set (9) crockery Set
e.t.c. It is correct to suggest that no purchase
receipt has been produce with my affidavit in evidence.
It is incorrect to suggest that my parents wants to get
my second marriage therefore, I have prayed for
dissolution of marriage before this court. It is
correct to say that after the marriage, I passed happy
life with my husband for 06/07 months. I left the house
of defendant about 05 months from my marriage. It is
incorrect to suggest that I left the house alongwith my
brother, but the defendant kick out from his house. On
07-04-2011, the defendant shut out from his house. I
left the house of defendant I was not pregnant. It is
incorrect to say that my parents get mis.carge of my
pregnancy. It is correct to say that the amount of Haq
Mahar 5000/- was not paid. It is incorrect say that I
left the house with my own accord therefore I am not
entitled for maintenance. It is incorrect to say that
the cash amount Rs.20000/- and three (3) tola gold
ornaments and 50,000/- are in my possession. It is
incorrect to suggest that the dowery articles are not
ling in custody of defendant and nor he kicked me from
his house. It is incorrect to say that all the receipt
of dowery articles are false and fabricated. I can not
say that my prayer is false.
NO RE
SRO And AC
Sd/-09-06-2012
Family Judge Sukkur
IN THE COURT OF FAMILY AND CIVIL JUDGE SUKKUR
Family Suit No. 216 of 2011

Mst. Nasreen D/o Muhammad Ramzan by caste Shaikh,


Muslim, Adult R/o Waspur Muhalla Royal Road
Old Sukkur..Plaintiff.

V E R S U S

Hidayatullah S/o Sher Muhammad by caste Shaikh,


Muslim, Adult R/o Near Local Board Sukkur
..Defendant

Cross Examination on the Deposition of Ghulam Nabi son


of Sher Muhammad by caste Shaikh.

Dated:25-09-2013
Recalled and Reaffirmed on oath
Cross to Mr. Shabir Ahmed Khoso Advocate for Plaintiff

I am educated up to 8th class. It is fact


that my house and my brother house is joint property.
My brother is serving in a private Job. It is fact that
the affidavit in evidence is written in English
language as well as it has been written under my
instructions. It is fact that the written statement was
read over to me by the counsel of defendant. It is fact
that in the affidavit in evidence / written statement,
it is not mentioned that the defendant stated that my
all the witness are aware about the fact of his case.
It is fact that I am not witness of this marriage. It
is fact that the gold ornament amounting Rs.50000/- is
not mention in my affidavit in evidence, which were
given by my brother to the plaintiff but I voluntarily
say that the amount of Haq Mahar was already paid by
the defendant to the plaintiff. It is fact that it is
not mention in affidavit in evidence the Haq Mahar was
paid in may presence. It is fact that I have not
produced any regarding proof of both parties/agreement
about the dowery articles. It is fact that we have not
denied about the genuineness of bills, and dowery
articles given by the plaintiff with his memo of
plaint. It is fact that the plaintiff Nasreen was
instigated about talak by her parents. It is fact that
I did not visit the house of the parents of plaintiff.
It is fact that the parent of plaintiff used to say
that the plaintiff may take amount from the defendant.
It is fact that the defendant has mentioned in Para
No.09 of Written statement which are genuine. It is
incorrect to suggest that the defendant did not Exhibit
the bills of gold ornaments, silver ornaments with the
memo of written statement. It is fact that the
defendant did not Exhibit the medical certificate in
support of his version, about the pregnancy of two
months of the plaintiff. It is incorrect to suggest
that the defendant drove the plaintiff out from his
house in plain three cloths. It is fact that the
defendant always paid the maintenance amount to the
plaintiff when he drove the plaintiff out from his
house. It is correct to suggest that the defendant has
produced no proof for payment of maintenance of
plaintiff with memo of written statement and affidavit
in evidence. It is incorrect that in this case the
defendant is Hidayatullah and I am not the defendant.
It is incorrect to suggest that I am deposing falsely.
I know very will that the defendant is duty bound to
pay the maintenance to his wife. It is incorrect to
suggest that the prayer clause of plaint of plaintiff
is not true. It is incorrect to suggest that I have
deposed on the instance of my brother.

NO RE
SRO And AC
Sd/-25-09-2013
Family Judge Sukkur
IN THE COURT OF FAMILY AND CIVIL JUDGE SUKKUR
Family Suit No. 216 of 2011

Mst. Nasreen D/o Muhammad Ramzan by caste Shaikh,


Muslim, Adult R/o Waspur Muhalla Royal Road
Old Sukkur..Plaintiff.

V E R S U S

Hidayatullah S/o Sher Muhammad by caste Shaikh,


Muslim, Adult R/o Near Local Board Sukkur
..Defendant

Cross Examination on the Deposition of Dilsad son of


Sher Muhammad by caste Shaikh.

Dated:08-10-2013
Recalled and Reaffirmed on oath
Cross to Mr. Ghulam Shabir Advocate for Plaintiff

I am educated up to (v) class. I am Tailor


Master. It is fact that the affidavit in evidence
written by the advocate on my instruction. I known the
written statement. It is fact that in my affidavit in
evidence is also mention in Para No.1 which is also
correct. It is fact that I am witness of this Nikha. It
is correct to suggest that at the time of marriage the
Haq Mahar was fixed in shape of gold armaments viz:
earrings and neckless worth of Rs.50000/-. It is fact
that the gold ornaments were given to the plaintiff
worth of Rs.50,000/-. It is correct to suggest that
defendant driven out the plaintiff from his house. I
was not present at the house of defendant. It is fact
that I have not produce any documentary proof which may
show that the parents of plaintiff are poor. It is
correct to say that the list of dowery articles is not
correct except other receipt. The defendant marriage
was solemnized about 2 years back I do not know the
exact date of marriage. The defendant driven out the
plaintiff from his house at about 2 years. It is
incorrect to suggest that the defendant did not
misbehaved with his wife, on every petty matters. It is
fact that I used to leave my house at about 10.00 A.M
and returned back my house at 9.00 P.M. It is correct
to say that I do not know about in this matter/case. It
is incorrect to say that the value of gold ornaments is
not worth of Rs.200000/-. It is correct to say that I
have already produce the receipt of the silver
ornaments. It is correct to say that I have produced
the proof viz: ultrasound report and another medical
report, regarding pregnancy to the plaintiff. I know
one Gulzar.
Note. Cross reserved for want of time.
NO RE
SRO And AC
Sd/-08-10-2013
Family Judge Sukkur

CERTIFIED TO BE TRUE COPY

FAMILY JUDGE AND CIVIL JUDGE SUKKUR


Certified copy applied for on: 03-12-2013.
Cost Estimated for on: 03-12-2013.
Cost Deposited for on: 03-12-2013.
Stamps supplied for on: 03-12-2013.
Copy made ready on: 04-12-2013
Copy certified on: 04-12-2013
Copy Delivered on : 04-12-2013

Coping fee Rs. 10-40.


Comparing fee. Rs. 01-20.
Total fee. Rs 11-60.

Typed by :
Compared by:
Read by:
Record Keeper
Family court and civil court Sukkur

IN THE COURT OF FAMILY AND CIVIL JUDGE SUKKUR


Family Suit No. 216 of 2011
[
Mst. Nasreen D/o Muhammad Ramzan by caste Shaikh,
Muslim, Adult R/o Waspur Muhalla Royal Road
Old Sukkur..Plaintiff.
V E R S U S
Hidayatullah S/o Sher Muhammad by caste Shaikh,
Muslim, Adult R/o Near Local Board Sukkur
..Defendant
Cross Examination on the Deposition of Hidauatullah Son
of Sher Muhammad by caste Shaikh.
Dated:13-05-2013
Recalled and Reaffirmed on oath
Cross to Mr. Shabir Ahmed Khoso Advocate for Plaintiff
It is fact that I have not produced any
documents with my written statement. It is correct to
suggest that the receipt of gold ornaments is not false
and fabricated produce by me in my affidavit in
evidence. It is fact that the receipt of gold ornaments
worth of Rs.50000/- is not mentioned in my written. I
voluntarily say that its mention total amount of gold
ornaments. It is fact that the reconciliation was held
between spouses. It is not a fact that I admitted the
amount of Haq Mahar which was not paid to the plaintiff
before this court. It is correct to suggest that I did
not produced gold samith as my witness. It is correct
that I did not produce any proof that the parents of
the plaintiff are very poor. I have pass intermediate.
It is correct that I have mention in my written
statement and affidavit in evidence about receipt of
gold ornaments. I was read over all the contents the
Written statement and affidavit in evidence. I do not
know in which paras the same receipt of gold ornaments
are false and fabricated. It is correct to suggest that
at the time of marriage no any dowery articles were
given by the parents of plaintiff. It is fact that the
dowery articles were not given to the plaintiff by her
parents which are not lying in my possession. It is
correct that the plaintiff took a way 20000/- cash
alongwith the gold ornaments where she left my house.
It is correct to suggest that the receipt of gold
ornaments does not shows amount of Rs.200000/- it is
correct to suggest that no any proof has been produced
in respect that the plaintiff left the house of
defendant on 26-05-2011. It is fact that when she was
pregnant where the plaintiff left the house of
defendant. It is correct that I have not produced any
proof in respect of her pregnancy. It is correct that I
have mention in my written statement that she was
pregnant of 2 months when she left the house, on 18-09-
2011, I filed suit. It is fact that the plaintiff left
the house of defendant on 26-05-2011, and suit was
filed 18-09-2011, the period of 4 months. It is correct
that the period of six month the child can not born. It
is incorrect to suggest that after six months of this
marriage the behavior to wards the plaintiff was worst.
It is incorrect to suggest that at the time of meeting
the smail of intoxicants from the mouth of defendant
was coming. I am not in habit of any intoxication. It
is incorrect to suggest that Nekmards of our community
alongwith the parents of the plaintiff come to me for
amicable settlements between us. It is correct to
suggest that the allegation of second marriage of
plaintiff is correct there is no any proof in support
of this allegation. It is incorrect to suggest that I
drove the plaintiff out from my house within three
cloths. When she left the house with her own accord. It
is correct to suggest that I did not maintain the
plaintiff when she left the house with her own accord.
It is correct to suggest that I did not bound my self
to pay Rs.3000/- P.M to the plaintiff. It is incorrect
to suggest that the plaintiff is entitled to gate
khulla. It is incorrect to say that I am bound to
return the dowery articles the plaintiff which were
lying in my custody. It is incorrect to say that I am
deposing falsely in order to usurb dower articles.
NO RE
SRO And AC
Sd/-13-05-2013
Family Judge Sukkur

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