7 7 Famil Suit Waseem Nazia Abid

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IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF FAMILY JUDGE LAHORE 1. 2. 3. 4. 5. Mst. Nazia D/O Bagha Mst. Naseem Abid (Minor) Umair Abid (Minor) Abdulla Abid (Minor) Zain Ali Abid (Minor) Daughter and Sons Abid Ali Plaintiff No. 2, 5 are minors hence it through plaintiff No. 1. All Awami Colony Qanchi Amar Sidhu, Tehsil Model Town, District Lahore. Plaintiffs VERSUS Abid Ali S/O Muhammad Sharif R/O St. No. 4, Awami Colony Qanchi Amar Sidhu, Tehsil Model Town, District Lahore Defendan
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  IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERSOF FAMILY JUDGE LAHORE 1.Mst. Nazia D/O Bagha2.Mst. Naseem Abid (Minor)3.Umair Abid (Minor)4.Abdulla Abid (Minor)5.Zain Ali Abid (Minor)Daughter and Sons Abid AliPlaintiff No. 2, 5 are minors hence it through plaintiff No. 1.All Awami Colony Qanchi Amar Sidhu, Tehsil Model Town,District Lahore.PlaintiffsVERSUSAbid Ali S/O Muhammad Sharif R/O St. No. 4, Awami Colony QanchiAmar Sidhu, Tehsil Model Town, District LahoreDefendant1-SUIT FOR DISSOLUTION OF MARRIAGE,2-SUIT FOR MAINTENANCE ALLOWANCE 3- SUIT FOR RECOVERY OF DOWRY ARTICLES & GOLD ORNAMENTS 3 TOLAS, TOTAL Rs. 2,80,000/- Respectfully Sheweth.1.That the address at the parties is correct for the effectivecorrespondence of summons/notices.2.That the Plaintiff No. 1 was married with the defendantaccording to Muslim Rites about 11 years ago and God blessed her Four children who are alive namely (1) Mst.   Naseem Abid aged 9 years, (2) Umair Abid aged 7 years, (3)Abdulla Abid aged 6 years (4) Zain Ali Abid aged 2-1/2 yearswhose are in the custody of the plaintiff No.1. (Mother).3.That in the starts of the marriage relation between spousesremained cordial but thereafter behavior to wards the plaintiff became cruel as the defendant used to torture the plaintiff on petty matters.4.That the plaintiff has developed hated towards thedefendant due to his cruel attitude.5.That the defendant has not provide any maintenance to the plaintiff No. 1 after the married and the plaintiff isworking in deferent houses and earn for her self and her children.6.That the defendant is a criminal minded person and the plaintiff cannot live within the limits of Quran & Sunnah.7.That about six months ago back the defendant tortured the plaintiffs quite badly and kicked out the plaintiff includingminor in three wearing cloths out of his house. The plaintiff No. 1 with her children came to on a rent house.8.That the plaintiff No.1 with her minors since from about 6months living with her children and the bearing allexpenses of her self and her children.9.That the Plaintiffs parents gave precious dowry articles,gifts and 3 Tolas gold ornaments at the time of marriage  valuing Rs. 4,90,000/- which were moved to defendant’shouse along with Plaintiff and dowry articles are still inthe custody defendant. The Nikah Nama of the plaintiff isin the possession of defendant.10.That the Plaintiff No. 1 repeatedly demanded her dowryarticles, gold ornaments and dower article which wasgiven to the defendant’s at the time of marriage becausenow it is difficult to live as a wife with the defendant infuture but the defendant has always been linger on matter  by lame excuses and the matter is still unresolved.11.That the cause of action firstly arose in the favour of thePlaintiff No.1 and against the defendant at the time of marriage and secondly when the defendant kicked out the plaintiff No. 1 with her child minor in three cloths out of his house about three years ago.12.That the plaintiffs are residing at Lahore so thisHonourable court has full powers of jurisdiction to try thesuit.13.That the court fee has been paid according to law. PRAYER  Under the circumstances enumerated above, it is, mosthumbly prayed that a (i) a degree of desolation of marriage infavour of the plaintiff against the defendant may very kindly be passed, (ii) a degree of maintenance in favour of the plaintiffs  against the defendant valuing 2,52,000/- and continue till thematurity of minors may also be passed, (iii) a degree of recovery dowry articles valuing Rs. 4,90,000/- may also be passed in favour of plaintiffs against the defendant.Any other relief which this Honourable Court deems fitmay also be awarded.PlaintiffsThrough Counsel Mian Mehmood AhmedAdvocate High Court42-43Model Town Courts,Lahore.Verification. Verified on Oath at Lahore on this day of 9 th July 2012, that the para No. 1 to 10 is correct according to best of my knowledge and belief and therest of paras are correct according to my knowledge.Plaintiffs
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