Plaint Dissolution of Marriage

LEGAL DRAFTING- I
QUIZ: DRAFT A SUIT FOR DISSOLUTION OF MARRIAGE
SUBMITTED BY: AMINA AAMER (49942)

DATE: 06/05/2021
HAZARA UNIVERSITY LAW DEPARTMENT
In the Court of Senior Civil Judge Family Court, Multan

Family Suit No. 19 of 2020
Ayesha Omer D/o. Omer Sheikh , Caste Sheikh , resident of House No. 18,
Model Town, Multan. (Plaintiff)
Versus
Hassan Ameer S/o. Fakhar Ameer, Caste Arian, residence of House No. 14, Street
No. 19, Johar Town Multan. (Defendant)
Suit For Dissolution Of Marriage on the basis of Cruelty and Non Maintenance.
Respectfully Sheweth:-
1. That the names and addresses of the parties have been given in the heading of the
plaint completely and correctly for effecting service upon the parties.
2. That the plaintiff was married to the defendant in accordance with the tenets of
Islam on 1st January, 2020, in presence of two witnesses and in consideration of
dower amounting to Rs. 50,000/-, a copy of Nikkah Nama is enclosed. After the said
marriage was solemnized the plaintiff went to defendant house Johar Town, Multan
to live with him over there to perform her conjugal rights.
3. That out of this wedlock no child was born.
4. That soon after the marriage the attitude of the defendant and his family members
turned hostile, inhumane and insulting towards the plaintiff. Besides inflicting mental
torture on the plaintiff, they became habitual of ridiculing her parents and other
relations. The defendant even did not hesitate to abuse her and to torture her
physically without any reason which made her life miserable. Nevertheless, the
plaintiff tried her level best to reconcile the matter for the sake of her matrimonial
life, but there has been no positive change in the behavior of her husband and his
family members.
5. That after a few months of the marriage, the situation went bad to worst the
defendant started quarrelling with the plaintiff on petty matters of domestic life and
eventually on 3rd June, 2020 he severely beat the plaintiff with a stick and inflicted
serious injuries leading to multiple fractures in hand and leg of the plaintiff and
turned her out of doors. Since then the plaintiff has been living up with her parents
in Model Town, Lahore.
6. That from the date of her expulsion from her husband’s house, the plaintiff and her
relative have been approaching the defendant requesting him to take the plaintiff,
but the defendant or his family members have not made any effort for settlement of
the matter.
7. That the defendant never had a job or any business and has badly failed and
neglected to provide for the maintenance and to perform his marital obligations for
the period stated herein above.
8. That the harsh and cruel behavior of the defendant has created hatred between the
two spouses and it is no longer possible to continue this hateful union.
9. That plaintiff seeks dissolution of marriage under The Dissolution of Muslim

Marriages Act, 1939 on the grounds of cruelty, physical and mental torture and non-
provision of maintenance.
10. That the cause of action firstly arose against the defendant on the day when the
defendant left the plaintiff to her parent’s house where she is still living, secondly
when he refused to provide her maintenance and subsequently few days ago when
the defendant declined to announce her divorce.
11. That the cause of action accrued within the territorial jurisdiction of this honorable
Court and the plaintiff is residing with her parents in Multan, as such, this honorable
Court has jurisdiction to adjudicate upon the matter.
12. That the appropriate Court fee has been affixed on the plaint
Prayer: In the light of the above mentioned circumstances, it is most humbly prayed that
this honorable Court may graciously be pleased to pass a decree of dissolution of marriage
in favor of the plaintiff against the defendant. Any other relief, which this honorable Court
may deem just and proper including the cost throughout, may also be awarded.
Date: 1st July, 2020 Ayesha Omer (Plaintiff)
through
Amina Aamer (Advocate)
Verification: Verified on oath today the 1st May ,2020 at Multan. The contents of the above
paragraphs are true and correct to the best of my knowledge and nothing has been
concealed.
Ayesha Omer (Signature of Plaintiff)
Date: 1st July, 2020

Plaint Dissolution of Marriage

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LEGAL DRAFTING- I

QUIZ: DRAFT A SUIT FOR DISSOLUTION OF MARRIAGE

SUBMITTED BY: AMINA AAMER (49942)

In the Court of Senior Civil Judge Family Court, Multan

3. That out of this wedlock no child was born.

9. That plaintiff seeks dissolution of marriage under The Dissolution of Muslim

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