IN THE COURT OF AT KARARACHI 

  
Family Suit No.      of 2023

1. Mst. Madina Naz D/O Muhammad Pervaiz Shahzada,

Muslim, Adult, Holding CNIC No. 42000-8961603-5, Resident of House
No. B-99, National Stadium Housing Society, K.D officers Society,
Karachi.

2. Maryam Hussain Lakhani D/O Muhammad Hussain Lakhani (Minor)

through her mother Mst. Madina Naz D/O Muhammad Pervaiz
Shahzada, plaintiff No-01
…………………………………………………………………….Plaintiffs     

VERSUS

Muhammad Hussain Lakhani S/O Muhammad Amin Lakhani,

Muslim, Adult, Holding CNIC No. 42301-2605990-1, Resident of House
No. 10/8-A,
Hussaini Housing Society, South
Karachi……………………………………………………….....Defendant

SUIT FOR RECOVERY OF DOWRY ARTICLES AND

MAINTENANCE

             The Plaintiffs above-named beg to submit as under:

1. That the plaintiff was married with the defendant abovenamed on 09-01-2022
in Karachi in accordance with Islamic Shariat (Hanafi) law for consideration of
haq mahr in sum of Rupees One Lac (100000/-).
Photocopy of the Nikahnama is enclosed as Annexure "A".

2. That the plaintiff No-01 continued to live with the defendant after the
solemnization of marriage as a submissive, faithful wife and performed her
matrimonial duties and obligations.

3. That during the wedlock one baby girl namely Maryam Hussain Lakhani
(Plaintiff No-02) was born on 06-10-2022.

4.  That the defendant, consequent upon wedding, kept the plaintiff no-01
properly only for one year. Thereafter, the defendant's behavior towards the
plaintiff changed gradually. He became critic and used to create dispute on
petty domestic matters. He became very harsh and hit the plaintiff with fist on
several occasions. His attitude became sub human and barbaric. One bad
morning in 2023, he along with his family members beat/assaulted the plaintiff
No-01 mercilessly and tuned her out from the house in three plain clothes the
victim having left with no-option took refuge/shelter at the parent's house.

5. That later on the defendant moved a false application to SHO PS New Town
Police Lines against plaintiff no 1 alleging therein the plaintiff no 1 of
 committing theft of his Turkish passport, Turkish visa and Turkish residence
permit and also of harassing the defendant.
Photocopy of the application is enclosed as Annexure "A-1".

6. That the defendant divorced the plaintiff no 01 on date 06-07-2023 through

WhatsApp but the same was registered in back date i.e., 23-06-2023.
Photocopy of the whatsapp screen shot and divorce deed are is enclosed as
Annexure "A-2 & A-3" respectively.

7. That the defendant and his family approached the plaintiff 01 through
WhatsApp even after pronouncement of divorce threatening her of grave
consequences and outraging her modesty which the plaintiff no 01 reported to
SHO PS New Town by making an application dated 07-07-2023.
Photocopy of the application is annexed herewith as “Annexure A-4”

8. That the plaitiff no 1 was given gold ornaments and other dowry articles and
costly items by parents of worth crores which remain with the defendant till
date who is not willing to hand over to the plaintiff no 01, the same was also
mentioned in the application mentioned in the above paragraph, i.e., 07.

9. That since then, the plaintiff 01 has been living with her parents along with her
minor child plaintiff no-02, and the defendant has failed to provide
maintenance to plaintiff no 01 and 02.

10. That the plaintiff No-01 extended her demand of return of dowry articles from
the defendant which consists golden ornaments, dowry articles and other costly
items. The value of entire dowry articles amounts to Rupees two crore
approximately.
A list of dowry articles is enclosed herewith as Annexure " ".

11. The defendant turned a deaf ear, occupied all dowry articles, gold ornaments
and other costly items and refused to return in spite of repeated requests and
emphatic demands.

12.  That the defendant is a successful builder and developer whose monthly
emoluments are Rs. 1500000/-(Rupees Fifteen Lac) approximately.

10.   That in this era of high price spiral, high rate of inflation pressurized
economy, the plaintiff No 01 along with plaintiff no-02 is dependent on her
parents and thus has become a burden on them. She is passing a miserable life and
her sufferings and agony know no bounds.

11.    That since the date of divorce the husband/defendant, the hardhearted

defendant did not pay a single penny to poor plaintiff no-01 and 02 as maintenance
whereas he is an affluent, well to do and capable to support them financially. His
personal economy is very set as his monthly income is Rs.1500000/-.

12.  That the plaintiff is basically a housewife confined to household affairs and no

means for self-support. Henceforth, she puts forward her undermentioned claim of
maintenance allowance as admissible under the Muslim Family Ordinance of
1962.
i)    A consolidated amount of Rs.250000/-(Rupees two lac and fifty thousand
only) for plaintiff 01 and 02 as past maintenance allowance/stipend for the last two
months till date.
ii)    A monthly maintenance allowance of Rs.100000/=(Rupees one lac) for
plaintiff no-01 till the observation of iddat period.
iii) A monthly maintenance allowance of Rs.100000/=(Rupees one lac) for
plaintiff no-02 till her marriage.

13.  That the defendant is legally bound to provide maintenance cover to the
plaintiff regularly and punctually.

15. That the cause of action arose to the plaintiff for filing the present Family Suit
at Karachi, on or about , when she was forcibly sent back to her parents'
house by the defendant and thereafter he denied/failed to provide her
maintenance.

16. That proper court fee has been affixed herewith.

17. That the plaintiff resides within the local limits of P.S. which is
within the jurisdiction of this Hon'ble court.

PRAYER

                 It is respectfully prayed that this Hon'ble court may be pleased to pass
judgement and decree in favour of plaintiffs no -01 and 02 against the defendant :

i) A consolidated amount of Rs.250000/-(Rupees two lac and fifty thousand

only) for plaintiff 01 and 02 as past maintenance allowance/stipend for the
last two months till date with specific institution/direction to pay promptly.

ii) A monthly maintenance allowance of Rs.100000/=(Rupees one lac) for

plaintiff no-01 till the observation of her iddat period which appears to be
just and cogent in view of the circumstances of the case.

iii) A monthly maintenance allowance of Rs.100000/=(Rupees one lac) for

plaintiff no-02 onwards till her marriage.

iv) Return of entire dowry articles, golden ornaments, a vehicle and other
costly items including but not limited to home appliances to plaintiff no-1
which amount to Rs two crore approximately.

v) Cost of the suit by virtue of poverty of plaintiff.

vi) Any other relief/relieves which this Hon'ble court may deem fit and proper
in the circumstances of the case may also be granted.
 Advocate for the
plaintiffs

Karachi.
Dated: