IN THE COURT OF SENIOR CIVIL JUDGE WITH POWERS OF JUDGE FAMILY COURT LAHORE.

 

 

 

 


Tayyab Rabbani S/o Tanveer Rabbani R/o Amanat Manzil House No --, Street no --,Mohalla Peer Makki Bazar Lahore. 

PLAINTIFF

VERSES

 

Saba Noreen D/o Muhammad Tauseef Ahmad R/o New Chaudhry Park Band Road Lahore.

DEFENDANT


SUIT FOR RESTITUTION OF CONJUGAL RIGHTS

 

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 is necessary.

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 family members.

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 Lahore cause of action arose at Lahore hence this jurisdiction to try upon the matter.

9.       That the requisite court fee of Rs.15 has been affixed on the plaint.

Prayer:
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 Honíble Court may deems fit and proper may also be awarded.

PLAINTIFF

Through :


Mudaber Hussain Qureshi
Advocate High Court.
Civil Courts Lahore


VERIFICATION:
Verified on Oath at Lahore this 30th day of October, 2015 that the contents of the Paras No. 1 to 9 are correct to the best of my knowledge and the contents of rest of the paras are true to the best of my belief. 

 

PLAINTIFF