IN THE COURT OF SENIOR CIVIL JUDGE WITH POWERS OF

JUDGE FAMILY COURT, LAHORE.

MST. SOBIA BIBI Wife of Muhammad Salim Daughter of Nazir

Ahmed, Resident of Jafri Tibba, Begum Kot, Shahdara,
Lahore.
Plaintif
VERSUS

Muhammad Salim Son of Muhammad Munir, Resident of

House No. 169/N Gazali Road, Samanabad, Lahore.

Defendant

SUIT FOR DISSOLUTION OF MARRIAGE

May it please your honour.

1. that the plaintif seeks the kind indulgence of this

Honourable Court through this plaint by way of
passing a decree for dissolution of marriage in favour
of the plaintif against the defendant on the basis of
“KHULA” in the supreme interest of justice and
equity.
2. that the marriage of the plaintif was solemnized with
the defendant on 04.09.2013 according the Muslims
Rites and Nikanama was duly registered in the union
council concerned, an amount of Rs. 5,00,000/- was
fixed as dower amount which was paid on the
demand of the plaintif. It is pertinent to mention
here that 1 daughter and one son were born out of
 above said wedlock who are residing with the
plaintif. It is very essential to narrate here that the
original Nikahnama was taken into custody of the
defendant and no copy is given to the plaintif so far.
3. That the relations between the spouses remained
unpleasant form the very beginning of the marriage
but the plaintif always tolerated such occasions for
the sake of respect and honour of her parents and
thereafter for the sake of betterment of the future of
the minors.
4. that the plaintif was being mentally and physically
tortured by the defendant and his parents throughout
the period of above said wedlock on house hold petty
matters without any justification just to tease the
plaintif and to cause her mental torture but the
plaintif always ignored such situation and entered
into reconciliation due to the interference of the
elders and the respectable of family as well as
locality.
5. That almost 2 months ago, the plaintif was again
tortured by the defendant and her parents and
turned out from the house in three apparels and
since then the plaintif is residing at the above
mentioned address with her parents.
6. That the defendant is man of bad character and due
to his rough and rude attitude, a great hatred has
been developed in the mind of the plaintif so in
these circumstances, the plaintif prefer die than
reconciliation with the defendant.
7. That the plaintif approached the defendant to give
divorce but he is not ready to listen the request of
the plaintif hence this plaint.
8. That the cause of action firstly arose almost 2
months ago when the defendant lastly turned out the
plaintif from his house and secondly almost a couple
of days ago when the defendant refused to give
divorce to the plaintif which still in a row.
9. That both the parties of the suit are residing in
Lahore, marriage was solemnized in Lahore, hence
this Honourable court has got the jurisdiction to
adjudicate upon the matter.
10. That the prescribed court fee has been affixed on the
plaint.

It is therefore most respectfully prayed that

the suit for dissolution of marriage may kindly be

decreed in favour of the plaintiff against the

defendant on the basis of “khula” in the interest

of justice and equity.

Any other relief which this Honourable Court

may deems fit and proper may also be awarded in

this regard.

Plaintif
Through

M.ASIM SHEHZAD
Advocate High court
Hassan Plaza, 2- Mozang Road, Lahore.

VERIFICATION
Verified on oath at Lahore this 30 day of July, 2019 that
the contents of para No. 1 to 8 of the plaint are true and
correct to the best of my knowledge and belief whereas
remaining para No. 9 to 11 are correct to the best of my
information.
Plaintif.
 IN THE COURT OF SENIOR CIVIL JUDGE WITH POWERS OF
JUDGE FAMILY COURT, LAHORE.

In Re:- Mst. Sobia Bibi VS Muhammad Salim

(SUIT FOR DISSOLUTION OF MARRIAGE)

APPLICATION UNDER ORDER 39 RULE 1 & 2 OF CPC FOR

GRANT OF INTERIM RELIEF.
May it please your honour:-
1. That the petitioner has filed the above titled suit in
this Honourable Court in which no date of hearing
has been fixed so far.
2. That the contents of the plaint may kindly be read as
an integral part of this plaint.
3. That the petitioner has a very good prima facie and
arguable case in his favour and there is every
likelihood of the success.
4. That the balance of convenience also lies in favour of
the petitioner.
5. That the defendant is going to a broad in the very
next week and he must liable to be restrained to
travel from Pakistan during the pendency of the
above said case.
6. That if the interim relief is not granted, the petitioner
shall sufer an irreparable loss and injury.

It is therefore most respectfully prayed that the

respondent may kindly be restrained to leave Pakistan in any
manner whatsoever till the final decision of main suit.

Petitioner

Through
M.ASIM SHEHZAD
Advocate High court
Hassan Plaza, 2- Mozang Road, Lahore.
 IN THE COURT OF SENIOR CIVIL JUDGE WITH POWERS OF
JUDGE FAMILY COURT, LAHORE.

In Re:- Mst. Sobia Bibi VS Muhammad Salim

(APPLICATION UNDER ORDER 39 RULE 1 & 2 OF CPC

FORGRANT OF INTERIM RELIEF.)
Affidavit of Mst. Sobia Bibi Wife of Muhammad Salim
Daughter of Nazir Ahmed, Resident of Jafri Tibba, Begum Kot,
Shahdara, Lahore.
I the above deponent do hereby solemnly affirm and
declare as under :-

1. That the petitioner has filed the above titled suit in

this Honourable Court in which no date of hearing
has been fixed so far.
2. That the contents of the plaint may kindly be read as
an integral part of this plaint.
3. That the petitioner has a very good prima facie and
arguable case in his favour and there is every
likelihood of the success.
4. That the balance of convenience also lies in favour of
the petitioner.
5. That the defendant is going to a broad in the very
next week and he must liable to be restrained to
travel from Pakistan during the pendency of the
above said case.
6. That if the interim relief is not granted, the petitioner
shall sufer an irreparable loss and injury.

Deponent
VERIFICATION
Verified on oath at Lahore this 2nd day of August, 2019,
that the contents of above affidavit are true and correct to
the best of my knowledge and belief and there is nothing
concealed there from.

Deponent