family written statment

BEFORE CIVIL & FAMILY JUDGE NO II TANDO MUHAMMAD KHAN Family Suit No. of 2010RIZWANA……………………………………………………………………………PlaintiffVERSUS Muhammad IQBAL……………………….....………………………….…….Defendant WRITTEN STATEMENT The defendant above named respectfully begs to submit his written statement in the above matter as under:-1.That the contents of Para No.1 of the plaint are admitted.2.That the Contains of Para NO. 2 is admitted only to the extent that the HAQ MAHAR was settled as golden Ghoomak but it is denied that the same has not Paid to the Plaintiff, but the factual Position is that the same has Paid to the Plaintiff at the time of marriage, which is even admitted and shown in the nikahnama the Photo copy of the same is attached herewith as annexure “A” it is further stated that the Plaintiff is 3 months Pregnant when she voluntarily with out any force left the house of Defendant.3.That the Contains of Para NO 3 are false and Fabricated hence vehemently denied the actual Position is this the defendant is employee and working as a Helper in Hassan Construction Pvt limited Copy of the attendance is attached for kind Construction.4.That the Contains of Para NO 4 and 5 are false and Fabricated hence denied.5.That the Contains of Para NO 6 are devoid of truth hence denied and the Factual Position is this the Plaintiff with out getting Permission from the defendant and voluntarily left the house of defendant on the instigation of her Parents, because they want to get marriage with an other Person and at the time of leaving the house of defendant the Plaintiff not only taken the golden ornaments but also took cash amount of rupees 15000/=6.That the Contains of Para NO 7 are false & Fabricated hence denied .7.That the Contains of Para NO 8 are false Fabricated and denied, and no Cause of action has accrued to the Plaintiff for filling the Present Suit.8.That the Contains of Para 9 and 10 are legal hence no need to reply .9.That the Contains of Para NO 11 which is Prayer Clause it is stated in this regard that the Plaintiff doesn’t entitle for the Prayer which she Prayed from this honorable court . It is respectfully prayed that the plaintiff is not entitled for any relief(s) hence merits no consideration and is liable to be dismissed, which may accordingly be dismissed and special compensatory costs may be awarded to the defendant.a.The plaintiff be directed to live with the defendant as his legally wedded wife as per injunctions of Islam.b.Any other relief(s) which this Honourable Court deems fit, just and proper in favour of the defendant. defendant VERIFICATION I, Muhammad iqbal S/O Abdullah Muslim, adult, by caste Soomro, R/O Moosa Muhalla Mityari town, Taluka & District matyari, do hereby verify on oath this ___th of April, 2010 that whatever stated above is true and correct to the best of my knowledge and belief. DEPONENTTando Muhammad KhanDated: __-04-2010 I know the deponent. AdvocateDOCUMENTS FILED :- 1. Photo Copy Of Nikahnama already attached 2DOCUMENTS RELIED UPON : 1.Any other document(s) found relevantor in rebuttal whereof.ADDRESSES OF THE PARTIES:- Same as mentioned in the cause title. DRAFTED AND PREPARED AS PER INSTRUCTIONSOF MY CLIENT IN MY CHAMBER. (Manzoor Ahmed Panhwar Advocate for the Defendant3 BEFORE CIVIL & FAMILY JUDGE NOIITANDO MUHAMMAD KHAN Family Suit No. of 2010RIZWANA……………………………………………………………………………PLAINTIFFVERSUSMuhammad IQBAL…………………………………………………………..DEFENDANT LIST OF WITNESSES AND GIST OF THEIR EVIDENCE1.Defendant He will depose and corroborate as per his version made in Written statement.2. He will support the averments of the written statement.3. NOTE:- More witnesses will be produced as and when need arises with the graceful permission of this Honourable Court.Tando Muhammad Khan.Dated --- 04-2010 DEFENDANT ADVOCATE FOR THE DEFENDANT 45