E-Notice Registration Form for Law Firms/ Individual Lawyers

Full Name MST. SAMINA

Husband Name Noor-ul-Hussain
Email Address ---
WhatsApp No. +92
Mobile No. +92
Messenger I.D ---
Plaintiff Address House No.801, Sector 48/F, Korangi No. 2 1/2,
Karachi
Law Firm Lawyer Sadam Hussain
Name/Lawyer Name
Law Firm Registration ADVO/18771/HC/KHI
No./ Lawyer enrollment
No.
Name of Respondent MUHAMMAD BABUL
CNIC of Respondent ---
Father Name of Muhammad Faqeer
Respondent
Address of Respondent House No. 2443, Sector 48/D, Kornagi No. 2 ½,
Karachi
Mobile No. +923083404012
Whatsapp No. +923083404012
Email I.D of Respondent ---
Messenger I.D of ---
Respondent
Any other Address ---

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1. This information is collected solely for the purpose of E-Notices by
electronic/digital means
2. You must be registered with the proper and correct information shown in the
registration form to receive the E-Notices.
3. Court will issue each E-Notice to you via given digital/electronic modes as
per the details provided in the registration form.
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No. Mobile No. etc you will need to resubmit the registration form with the
permission of the concerned court.
5. If applicants and respondents are more than one please attach a separate
sheet with the registration form with their complete, correct, proper
particulars separately for the issuance of E-Notices to all the case parties.
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during court hours.

Signature & Stamp

 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL
S/o Muhammad Faqeer, Muslim, Adult,
R/o House No. 2443, Sector 48/D,
Kornagi No. 2 ½, Karachi ………………………… DEFENDANT

To,
The Defendants named above
Whereas, Plaintiff above named have instituted a Civil Suit
against you SUIT FOR DISSOLUTION OF MARRIAGE BY WAY
OF KHULLA. You are hereby summoned to appear in this court in
person or by a pleader duly instructed and able to answer all material
questions relating to the suit or who shall be accompanied by some person
able to answer all such questions. On the , day of
________________-2023 at 08:30 A.M. to answer the claim and you are
directed to produce on that day all the documents upon which you intend
to rely in support of your defence and to file your written statement on the
said date.
Given under my hand and seal of the court this on___, day of _____,
2023.

By, Order
 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA
W/o Noor-ul-Hussain, Muslim, Adult,
Currently R/o House No.801, Sector 48/F,
Korangi No. 2 1/2, Karachi …………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL
S/o Muhammad Faqeer, Muslim, Adult,
R/o House No. 2443, Sector 48/D,
Kornagi No. 2 ½, Karachi ………………………… DEFENDANT

SUIT FOR DISSOLUTION OF MARRIAGE BY WAY OF

KHULLA

The plaintiff above named respectfully submits before this Hon’ble

Court as under:

1. That, the plaintiff is a law-abiding citizen of the Islamic Republic of

Pakistan, currently residing at the above-mentioned address with her
parents, and possesses all fundamental rights as ordained by the
constitution of the Islamic Republic of Pakistan, it is pertinent to
mention here that Plaintiff belongs to a religious family.

2. That, the plaintiff entered into marriage/Nikah with Defendant in the

month of October 2018, Dower was Fixed Rs.50,000/-, the dower
amount still outstanding against the defendant, after Nikah/Marriage
Rukhsiti was took placed and the plaintiff & Defendant started their
married life at the above-mention address of the defendant.

3. That, after the marriage/Rukhsati, Plaintiff started residing with

Defendant, and marriage was duly consummated, whereupon out of said
wedlock one issue was born namely Ayan aged 3 years old, it is
pertinent to mention here, above minor has been residing with her
mother at above mention address.
4. That, after passing sometime of marriage, the attitude of Defendant
and his family became very harsh, cruel, and humiliating towards
Plaintiff, it is pertinent to mention here that the above Defendant did not
fulfill the substantial responsibilities, as neither he gave monthly
maintenance to Plaintiff nor he provided necessary thing such as clothes,
shoes, etc to the Plaintiff.

5. That, being Muslim and belonging to a religious family Plaintiff has

given all her efforts for making smooth and normal life but the ignorant
and aggressive attitude of Defendant all the efforts of Plaintiff went in
vain and Plaintiff remained to continued physically and mental
tortured by the Defendant on trifling issues.

6. That, it is pertinent to mention here, during the entire period of

marriage, all the livelihood expenses of the minor and Plaintiff were
borne by her mother of Plaintiff, it is pertinent to mention here, Plaintiff
has not received any maintenance amount/pocket money during the
entire period of wedlock, but being supportive wife Plaintiff performed
her part beyond her obligations & responsibilities.

7. That the defendant never maintained the plaintiff properly nor gave
any maintenance and whenever she demanded her maintenance and
dower amount was she subjected to torture.

8. That the defendant in the month of May 2021 sent the plaintiff to her
parent’s home since then she is living with her parents whereas the
defendant never contacted nor approached the plaintiff for her
maintenance and other necessitates.

9. That since the day of turn out, the plaintiff is residing with her
parents at the above-mentioned address, while the defendant still neither
reconciled the matter nor sent any single penny as her maintenance
being her husband, as laid down by the Almighty Allah.

10. That due to the maltreatment, misconduct, harsh/cruel attitude, non-

maintenance, and misbehavior of the defendant, Plaintiff
has developed such hatred against Defendant that it has become impossi
ble for Plaintiff to reside with Defendant as his wife within the limits
prescribed by ALMIGHTY ALLAH and Plaintiff seeks dissolution of
her marriage on the basis of KHULLA and for which ready to forego
her dower.
11. That the cause of action has arisen to the plaintiff against the
defendant when marriage was solemnized and thereon then when the
defendant fails to maintain the minor and the plaintiff and sent the
plaintiff to her parent’s home in the month of May 2021 and the same is
still continues till today.

12. That the plaintiff is residing at the above-mentioned address, within

the territorial limit of Police Station Zaman Town which is within the
jurisdiction of this honorable court.

13. That the proper court fee as prescribed under the law has been affixed
on the plaint.

PRAYER

It is, therefore, respectfully prayed that this honorable court may graciously
be pleased to pass a judgment and decree in favor of the plaintiff and against the
defendant as follows;

A. To dissolve the plaintiff’s nikah with the defendant by way of Khula, as

the plaintiff is ready to forgo her dower amount in lieu of Khula.

B. To grant the cost of the suit and any other relief[s] which this honorable
court under the facts and circumstances of the matter may deem fit and
proper.

Karachi, PLAINTIFF
Dated: 16-11-2023.

ADVOCATE FOR
PLAINTIFFS
(SADAM HUSSAIN)

VERIFICATION

I, MST. SAMINA W/o Noor-ul-Hussain, Muslim, Adult, Currently R/o House

No.801, Sector 48/F, Korangi No. 2 1/2, Karachi, do hereby verify that
whatever stated above is true and correct to the best of my knowledge.

Karachi, DEPONENT
Dated: 16-11-2023.
 Identified by me.

ADVOCATE FOR PLAINTIFF

(SADAM HUSSAIN)

On S.A before me, at Karachi, on this 16th day of November 2023 , the
deponent is identified by SADAM HUSSAIN who is personally known to me.

COMMISSIONER FOR TAKING AFFIDAVITS

Documents filed By : The Annexure ()

Documents relied upon : All Documents related to the Dispute.
Address of the Plaintiff’s : As per Vakalatnama
Advocate,

Drafted By me

(SADAM HUSSAIN)
 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL …………………………… DEFENDANT

PERMANENT ADDRESS OF PLAINTIFF FOR SERVICE

MST. SAMINA

W/o Noor-ul-Hussain, Muslim, Adult,

Currently R/o House No.801, Sector 48/F,

Korangi No. 2 1/2, Karachi

ADDRESS OF PLAINTIFF’S COUNSEL FOR SERVICE

ADVOCATE SADAM HUSSAIN

CHAMBER: Shop No.17, Karimiyah Qadriyah Masjid,
Sector 48/E, Korangi No. 2 ½, Karachi
CELL No:0334-3577956

East Karachi. ADVOCATE FOR PLAINTIFF

Dated:16-11-2023 (SADAM HUSSAIN)
 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL …………………………… DEFENDANT

AFFIDAVIT IN SUPPORT OF ADDRESS & CNIC

I MST. SAMINA W/o Noor-ul-Hussain, Muslim, Adult, Currently R/o

House No.801, Sector 48/F, Korangi No. 2 1/2, Karachi, do hereby state on
oath as under:-

1. That I am the Plaintiff in the matter as well as the deponent of this

affidavit, as such I am fully conversant with the facts stated herein.

2. That the accompanying affidavit in support of address & CNIC has

been drafted and filed under my specific instructions by my Counsel
and the contents whereof may be treated as part and parcel of this
affidavit for the sake of brevity.

3. That, I say that lived at my parent’s house at the above-mentioned

address, and my CNIC isn’t issued by the NADRA therefore, I
couldn’t produce my CNIC before this Hon’ble Court.

4. That I say that until and unless the accompanying application is

granted, I as well as the minor shall suffer irreparable loss and be
seriously prejudiced.

5. That whatever is stated above is true and correct to the best of my

knowledge and belief.

Dated; 16-11-2023 DEPONENT

 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL …………………………… DEFENDANT

LIST OF WITNESSES

1) Mst. Samina D/o Noor-ul-Hussain

(Plaintiff herself)

East Karachi. ADVOCATE FOR PLAINTIFF

Dated:16-11-2023 (SADAM HUSSAIN)
 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL …………………………… DEFENDANT

LIST OF DOCUMENTS

1.

2.

3.

East Karachi. ADVOCATE FOR PLAINTIFF

Dated:16-11-2023 (SADAM HUSSAIN)
 IN THE COURT OF XXIIITH FAMILY JUDGE,
EAST AT KARACHI
Family Suit No. of 2023

MST. SAMINA ………………………………….….…..PLAINTIFF

VERSUS
MUHAMMAD BABUL …………………………… DEFENDANT

I, Mst. Samina D/o Noor-ul-Hussain, the above-named Plaintiff do hereby

appoint and constitute, MR. SADAM HUSSAIN ADVOCATE & MR.
TAHIR MEHMOOD ADVOCATE in the above matter.

Represent, appear, and act for me/us, further my advocate (s) in the above matter,

I also authorize the said Advocates to compromise, withdraw and receive on

my/our behalf, and present our case on my/our behalf in the above matter and/ or refer
to the above matter to arbitration or to compromise or withdraw from the same.

I undertake to appear in the above matter before the Court, my Counsel shall
not be held responsible in the above matter in case the matter is dismissed/disposed
of /Ex-Parte due to my/our failure to appear/ attend the case.

I also undertake to pay his full professional fee before the conclusion of the
case, in case his full fee is not paid, the counsel can withdraw his Vakalatnama from
the above matter, and in case of a change of Advocate in the above-noted case, I shall
not be entitled to get back the paid professional fee.

I also undertake that in case I fail to pay the outstanding professional fee, my
Counsel has the right to file a case for payment of the due professional fee.

Date: ____________
Received by me on _____________ from___________

SIGNATURE

SADAM HUSSAIN TAHIR MEHMOOD

ADVOCATE HIGH COURT ADVOCATE HIGH COURT
Ledger No. ADVO-16865-SBC-KHI Ledger No.16865/HC
CELL NO. 0334-3577956 CELL NO. 0331-2200614

SAMREEN ZEHRA
ADVOCATE
Ledger No.
Address for services: Shop No.17, Karimiyah
Qadriyah Masjid, Sector 48/E, Korangi No. 2 ½,
Karachi