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IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE SUKKUR

Family Suit No. 25/2012

Mst. Shamim Akahter Soomro

S/o Fazul-Ur-Rehman Soomro
House No. B 3250 Muhalla
Take Chan Street Frear Road Sukkur---------------------------Plaintiff.
VERSUS
Muhammad Lal Bux Balouch
S/o Wali Muhammad Donki
R/o Near Telephone Exchange
Ghandahni Fatak Sukkur Next
Address Barket Dantal Service
Near Kiran Bakary Gharibabad Sukkur----------------------Defendant.

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF KHULLA

The plaintiff above named respectfully submit as under:-

1. That the plaintiff is Muslim, Adult, aged about 29 years, residing

at the address mentioned above within territorial jurisdiction of this
Honorable court.

2. That on 22-09-2010 the Nikah of the plaintiff was solemnized in

the Mosque the name of Moti Masjid with the defendant without
consent of the plaintiff parents. The plaintiff execute the Nikah with the
defendant without the permission of her parents in the base of FREE
WILL AFFIDAVIT Dated:-12-09-2010.

3. The Plaintiff Nikah was execute before Nikah Khuwa Moti

Masjid Dated :- 22-09-2010 with he defendant due to many promise
and securities gave by the defendant to plaintiff that I will be agree t her
parents for the Rukhsati and at the time of Registration of the Nikah
and amount of Rs. One Tola Gold was Haq Maher, but the same was
not paid to the plaintiff by the defendant.

4. After the execute of Nikah I was back to y parents house only

for 2 hours of the same days and I am waiting for complete the
promise by defendant who will be satisfied of my parents.

5. That the plaintiff still waiting for the Rukhsati by the defendant
in the house of her parents.
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6. That after Nikah, it has come to knowledge of the plaintiff that

the defendant is Government Jobless person and used to take
intoxicant and having character and spend all the time with his bad
character friends.

7. That the after the Nikah the plaintiff comes to knowledge

through reliable resources the defendant already married Holder and
he has five children and his wife are living with the caption address.

8. That the plaintiff being lady of gentle nature and also educated
and she was pass the inter and also passed the C I T certificate holder
of Computer courses for the spend of best life.

9. That after the Nikah defendant no any response or contact to

her parents for the further proceeding because the defendant was
already married Holder.

10. That the plaintiff. Contact to the defendant for the clarification
of the news of married Holder Person. The defendant excepted that I
am already married Holder and he said my first wife is alive I am loving
very much for my 1st wife.

11. That the plaintiff request to the defendant you may divorce to
me but defendant refused to give the divorce to the plaintiff and he
suggest/ advise to her that your parents must be provided a House
with house Hold articles then I will be spend the life as per Muhammad
an Law.

12. That the plaintiff no any alternator file the present suit before
this honorable court because the defendant fraudly, Misuided to the
plaintiff for the arrange of Nikah with the plaintiff.

13. That the defendant used to start the blackmailing to the plaintiff
and her parents and also information who want to make the KARI to
the plaintiff.

14. That the defendant melafidy and command of work he has

possession of the affidavit and Nikha Nama. Many times requested by
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the plaintiff to give the Nikha Nama but he refused to the plaintiff, for
the black mailing in future,

15. That under these circumstances, the plaintiff developed hatred

her mind against the defendant and it is quit difficult for he to live with
the defendant as his wife under the limits prescribed by ALMIGHTY
ALLAH. Then to give her company with be defendant as his wife.

16. That the plaintiff ready t leave the all benefits and other relief
which is the mention of the Nikha Nama if this honorable court pass the
order judgment and decree in the favor of plaintiff with this suit for
desolation of marriage on ground of Khulla.

17. That cause of action has been accrued to the plaintiff to file the
present suit, when her Nikha was perfumed without her consent by her
parents and leaving false allegation if the plaintiff would not accept the
defendant as a husband. Secondly the defendant jobless man and he
has already married person. Thirdly the defendant used to drugs and
using to bad character society and same is continued till today within
the territorial jurisdiction of this honorable court.

18. That therefore, the plaintiff finding no other patent, prompt and
efficacious remedy approached this Honorable court by way of filing
this suit.

19. That no suit is this respect has been filed prior to this.

20. That the plaintiff, therefore, respectfully prays as under:-

PRAYE R

A. That this Honorable court may be pleased to passed the

judgment and decree in favor of the plaintiff and dissolve
the marriage of the plaintiff by way of Khulla.

B. To grant any other relief, which deems fit and proper

under the circumstances of the case.

C. To award the cost of the suit.

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D. Court deems fit and proper under the circumstance of

the case.
Sd/-
Plaintiff
NIC. 45504-6455763-6

VERIFICATION

I Mst. Shamim Akahter Soomro S/o Fazul-Ur-Rehman

Soomro House No. B-3250 Muhalla take chand street Frear Road
Sukkur caste, Soomro do hereby verify on oath with photo snap
that that the contents of the suit was read over to me in, which is
my mother tongue and I admit it correct and signed on the plaint
by admitting its contents as true and correct to the best of my
knowledge and belief.

Verified and signed at Sukkur on this 6th day of

February, 2012.

Identified by me. Sd/-

Sd/- Deponent.
Advocate NIC. 45504-6455763-6

LIST OF DOCUMENT:-
1. Will be produced after the receiving.

DOCUMANTS RELIED UPON:-

Any other document, which rebut the case of the
defendant and proved the case of the plaintiff.

ADDRESS FOR SERVIE OF PLAINTIFF:-

Same is mentioned in the title of memo of plaint.
Sukkur.
Dated:-06-02-2012
Sd/-
Advocate for the plaintiff