Before the court of Civil Judge Family Court Charsadda

Mst. Laila Rooh

VERSUS

Asif Khan

Subject: Written statements on behalf of defendant Asif Khan

Respected Sheweth,

Preliminary Objections:

i. The Plaintiff has got no cause of action.

ii. Suit of the plaintiff is not maintainable in the present form

iii. Suit of the plaintiff has been based upon mala-fide and false materials.

iv. Suit of the plaintiff is suffering for mis-joinder and non-joinder of necessary
persons as defendants, is un-tenable and liable to dismissal with heavy cost.

v. Suit of the plaintiff has been based upon surmises and conjectures.

vi. That the plaintiff through her father has been paid a huge amount of 2 lacs for
purchase of dowery articles.

vii. That the annexed documents are the result of forgery and fabrications for
which the plaintiff may be proceeded before the competent forum after the
lodging of criminal case.

Factual Objections:

1. That para No 1 needs no reply due to need of evidence at proper stage.

2. That para No 2, subject to evidence needs proper scrutiny of documents hence is

hereby un-rebuttable.
 3. That para No 3 is totally incorrect it has been drawn against the actual facts hence,
hereby denied.

4. That para No 4 has also been drawn incorrectly hence refused totally.

5. That the para numbered as 4 regarding the look-after of the family members of
defendants is also totally incorrect because the plaintiff for so many times having
mis-placed the valuable articles from the defendant house was properly reported
before her parents in time.

6. That para No.5 on the subject has incorrectly been drawn hence, denied.

7. That plaintiff soon after the Eid-ulu-Adha has taken away huge amount form the
house of the defendant and has been living since then in her parental house.

8. That para No 7 in the context of maintenance allowance is incorrect because, the

plaintiff without any legal cause has been sitting in her parental house as a result
of which she is not entitled for any relief of maintenance etc.

9. That the plaintiff has got no entitlement for the claimed relief of dower,
maintenance etc. hence denied in toto.

10. That for the purchase of dowery articles, clothes and food etc. of her family the
defendant has paid an amount of 2 lacs, to the father of the plaintiff, before the
Rukhsati, the plaintiff hence, is not entitled to any set of relief claimed on the
subject of dowery articles.

11. That paras regarding cause of action, court fee are legal clauses, although she has
got no cause of action.

It is, therefore, most humbly prayed for dismissal of the suit with heavy cost against the
plaintiff.

Through,

Jan Muhammad Khan Utmanzai

Advocate High Court,
Peshawar.

&

Muhammad Iqbal Khan Mohmand

Advocate High Court,
Peshawar.
:Verification
It is hereby verified that the contents of this Plaint are correct to the best of my belief
.and knowledge
DEPONENT