Before the family judge Buner

Mst. Foziat bibi w/o Suliman etc

Versus

Suliman s/o Abdul Manan

That the defendant had filed the above title case before this honorable court against the present
defendant for,,

For dissolution of marriage etc

Suite for recovery of dowler etc

_________________

Respectfully Sheweth,

Preliminary objections

1. That the suit in the present form is bad for miss-joinder and non-joinder.
2. That the suit of the plaintiff is bad in its present form and thus, is liable to be dismissed.
3. That the plaintiff has no documentary or orally proof to the extent of fixation of dower for her as
alleged in her plaint.
4. That the plaintiff has left the house of the defendant with her father out of her free well and
dconsent and having settled at the house of her parents without any legal justification and
despite of a number of jargas from the defendant for settlement in his house as his lawfully with
sedded wife and having denied his conjugal rights without any proof of cruelty and matter
treatment, is not entitled to any rate of maintenance in any way neither for herself and nor for
the minor mentioned above.
5. That, the plaintiff No.1 has no proof regarding snatching an amount of 300,000/- from her
during her stay at the house of the defendant as the defendant himself cannot even think about
such chief act on his part.
6. That, the plaintiff No.1 has not brought any dowery articles to the house of the defendant and
that the dowery articles so for in the house of the defendant were arranged for by father of the
defendant and that too for the marriage of elder brother of the defendant the late first husband
of plaintiff No.1.
7. That, the plaintiff No.1 has not annexed any medical prescription with her plaint to prove
expenses spent by her so for borne by her as well as in connection of treatment of the minors.
Thus the allegation to the extent of recovery of rupees one lac is fake and bogus.
8. That, list of the dowery articles in annexed with the plaint is fake and its alleged market value
rupees 95,000/- is also fake and bogus.
9. That the defendant loves plaintiff No.1 very much as her as his love fully well advised and
wished together settled in house at any cost. Therefore, written stated for the defendant may
kindly be considered as suit for restitution of conjugal rights on behalf of the defendants.
FACTUAL OBJECTIONS
1. That, Para No.1 of the plaint of the plaintiffs is taken as true and correct.
2. That, Para No.2 of the plaint is correct only to the extent of two daughters of the plaintiff
No.1 from her late husband Sarbiland, However the plaintiff No.1 has no proof to the extent
of fixation of five Tolas as dower or its snatching from the plaintiff No.1 by the defendant
anywhere at any time and even no specification is available within Para No.2 to the extent
of fixation of dower as 5 Tolas either in gold, silver or in any other metals.
3. That, Para No.3 of the plaint is taken as incorrect as plaintiff No.1 has no documentary or
orally proof with her to the extent of fixation of dower for her as 3 Tolas of gold during her
Nikah with the defendant rather the dower of the plaintiff No.1 was fixed as rupees 500/- in
presence of witness at the time of Nikah with plaintiff.
4. That, Para No.4 of the plaint is incorrect is no bridle gifts with any dowery articles were
given to the plaintiff No.1 by her parents as, She has no proof neither in the form of
purchase recites or any evidence regarding transportation or trick age of the Said dowery
articles from the house of her parents to the house of defendant, thus the list so for
appended with the plaint with its alleged market value is fake and bogus hence, denied.
5. That, Para No.5 of the plaintiff is incorrect as the defendant has neither any knowledge
regarding dispatch of any compensation amount by the Govt Saudi Arabia and nor has over
seen any amount of 3 lakh received by her ever, nor the defendant received the same from
plaintiff the instant Para is based on lies, self-made, denied.
6. That, Para No.6 of the plaint is taken as incorrect as Nikah of the plaintiff No.1 with that of
the defendant was solemnized with the defendant at the cost of fixation of dower as rupees
500/- and no dower as three Tolas of gold was fixed as dower in presence of witness in
Majlis of that very Nikah.
7. That, Para No.7 of the plaintiff is incorrect and as against the same the attitude of plaintiff
No.1 was not well towards the plaintiff defendant and was exclusive of complete
awarsement against the defendant and even no question for the defendant was their arise
to give the plaintiff No.1 even with sly look or to call her with bad names, denied.
8. That, Para No.8 of the plaint is incorrect as the defendant has never beaten the plaintiff
No.1 and nor has she has any proof regarding any beat down by the defendant or any other
physical assault as her person or any threats for dire consequences like murder to her
denied.
9. That, Para No.9 of the plaint is only correct to the extent of Mst Lalina being daughter of the
defendant, rest of the Para is incorrect proof less hence denied.
10. That, Para No.10 is the plaint is incorrect, as the plaintiff No.1 had left the house of the
defendant quite much happily along with her father in canteen for refreshment purpose and
was wet ousted by the defendant neither through beating nor through physical assault.
11. That, Para No.11 is incorrect and proof less therefore the paintiff No.1 no way is intitled for
any decree desolation of marriage with the defendant as the defendant loves her very much
 and ready to resettled her as his legal weeded wife at any cast and thus written statement
of the defendant may kindly by taken as suit for restitution of conjugle rights
12. 12. That, Para No.12 of the plaint is incorrect as the plaintiff No.1 has no proof to the extent
of fixation of dower as 5 Tolas or 3 Tolas gold for any of the Nikah, and that the plaintiff No.1
is not entitled to get any decree for it, as the detail consw has already given in above
13. That, Para No.13 off the plaint is incorrect as no dowery was given to plaintiff No.1 for her
marriage with the defendant and it being proof less for plaintiff No.1. She no way is entitled
for any decree and recovery of it hence denied.
14. That, Para No.14 of the plaint is incorrect as plaintiff No.1 has left house of the defendant
with her own freewell alongside her father and having kept at the house of her parent
without any reason and without any proof of cruelty and despite the fact od Jargas from the
defendant for her resettlement at the house of the defendant and having plenty denied
performing conjugal right of the defendant, No way is entitled for maintenance allowance
with any rate for any period and a court decree fo3 the same.
15. That, Para No.15 of the plaint is incorrect as no Jirgas were sent for any dialogues to the
defendant by the plaintiff No.1 while it was the defendant who sent Jirgas behind Plaintiff.
16. That, Para No.16 is not pertain to the defendant however, the relevant court fee is not
affined with the suit nor this honorable court has the jurisdiction to entertain the suit in
hand.
Affidavit
Solemnly affirm that all contents my written statement are correct to the best of my
knowledge and belief and nothing is kept concealed.