Tayyab Rabbani S/o Tanveer Rabbani R/o Amanat Manzil House No --, Street no --,Mohalla Peer Makki Bazar
May it please Your Honour:
1. That the plaintiff was married to the defendant according to
Muslim Rights about 5 years ago and Sharai Dower was
fixed which was paid by the plaintiff.
2. That the plaintiff and defendant were living happily and were
performing martial obligation with each other when about 6 months ago the
relative of the defendant came in the house of the plaintiff and requested that
a marriage ceremony is going to be solemnized and the presence of the defendant
3. That the plaintiff agreed and the defendant went with her
relative and took with her cash of 30,000/- and Gold Ornaments 3 Tolas along with precious cloth and promised that she will
come back with in some days.
4. That as per promised the plaintiff approached defendant in the
house of her parents but the defendant postponed the matter by one way or other
at the instigation of her family and brothers.
5. That the plaintiff again approached the defendantís parents house in order to join the defendant but the
defendant totally refused to join the plaintiff at the instigation of her
6. That the plaintiff has a great love and affection and cannot
live in this world alone hence this suit.
7. That the cause of action arose in favour
of the plaintiff and against the defendant when the defendant refused to join
the plaintiff and the cause of action is still continuing.
8. That the plaintiff is residing at
9. That the requisite court fee of Rs.15 has been affixed on the plaint.
Hence it is prayed that the decree for restitution of conjugal rights may kindly be passed in favour of plaintiff. Any other relief which this
Mudaber Hussain Qureshi
Advocate High Court.
Verified on Oath at