IN THE COURT OF FAMILY JUDGE HYDERABAD
Family Suit No. of 2009
GULZAR ALI S/O QAIMUDDIN
by caste Bhatti, adult, musim,
Resident of House No.228 Block-E
Unit NO.5 Latifabad Hyderabad. ------------- PLAINTIFF
VERSUS
MST. NASEEMA RASHEED wife of
Gulzar Ali, d/o Rasheed Qureshi,
Adult, muslim, Resident of House No.406
Block-B Unit NO.10 Latifabad Hyderabad ----------------- DEFENDANT
SUIT FOR RESTITUTION OF CONJUGAL RIGHTS.
The plaintiff respectfully submits as under:-
1- That, plaintiff entered into marriage tie with the defendant Mst. Naseema on 11-8-2006 against the dower amount of Rs.50,000/-. After the marriage Rukhsati was took place on same date and plaintiff spouses started residing as husband and wife.
2- That, out of such wedlock plain tiff has a son namely Nabeel Gul aged about 2-1/2 years.
3- That, since the first day of marriage, plaintiff kept the defendant happily and maintained her properly in all respects and not a single occasions provided any opportunity of any complaint of maltreatment or non-maintenance.
4- That, unfortunately the defendant has failed to prove herself a loyal, obedient and loving wife and she was habitual to pickup quarrel with the plaintiff on petty matter. In fact she is under the influence of her brothers namely Rais Qureshi, Waqar Qureshi, Zulfiqar Qureshi and Jawed Qureshi, who used to pressurize the defendant to demand money from plaintiff. On numbers of occasions, the plaintiff paid money to the defendant which he handed over to her brothers, even she taken away an amount of Rs.20,000/- from her dower amount which she also gave to her brothers.
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5- That, on 14-4-2009 defendant left the house of plaintiff in his absence while leaving the minor Nabeel Gul in the house of defendant, so also taken away gold complete set, one gents finger ring, gold set weighing 5-Tolas total gold valued Rs.300,000/- .
6- That, when defendant came at his house from his duty as he is working as Inspector Quality Safety Health Environment Centre Civil Aviation Authority Hyderabad Airport, he did not find his wife/defendant in the house, he made inquiry from her mother who disclosed that after quarreling with her went away.
7- That, thereafter plaintiff went to the house of his in-laws where he met with the defendant and when plaintiff asked her to accompany him to his house, she flatly refused. At that time her above named brothers were also available in the house who misbehaved with the plaintiff and did not allow the defendant to go with him.
8- That, thereafter plaintiff went to his house back, informed the nek mard and again approached the defendant and her brothers agreeing them to allow the defendant to join him and lead a harmonious life, but they did not allow.
9- That, since then time and again plaintiff is paying visits to the defendant, but being influenced by her brothers, she is not ready to join the plaintiff.
10- That, it is pertinent to submit here that on one occasions the brothers of defendant to leave the above said gold ornaments with them which she brought from his house and pay them Rs.100,000/- then they will allow the defendant to live with the plaintiff as his legally wedded wife, otherwise they will not allow her to join the plaintiff.
11- That, defendant is legally wedded wife of the plaintiff, but she under the influence of her brothers who are greedy type of persons is not ready to perform her marital obligations.
12- That, cause of action has accrued to the plaintiff to file present suit on 14-4-2009 when defendant left his house in her absence and taken away all the gold ornaments. The cause of action again accrued to the plaintiff on all the dates when he approached the defendant to take back her to his house, but she refused flatly on the instance of her brothers. The cause of action again accrued to the plaintiff when brothers of defendant pressurized the plaintiff to withdraw from the above said gold ornaments and pay them Rs.100,000/- (Rupees one lac only) then they will allow the defendant to join the plaintiff as his legally wedded wife and same cause of action is continued day to day till today, hence this suit.
13- That, this Honourable Court has got jurisdiction to adjudicate upon the matter.
14- That, necessary court fee is affixed in shape of stamps.
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PRAYER.
10- That, plaintiff respectfully prays for following judgment and decree against the defendant:-
a) That, this Honourable Court may be pleased to direct the defendant to join the plaintiff as his legally wedded wife and perform all the conjugal rights/conjugal rights towards the plaintiff within the limits prescribed by ALLAH almighty.
b) Any other relief which this Honourable Court deems fit and proper may please be awarded to the plaintiff.
Hyderabad
Dated: 11-8-2009 ( PLAINTIFF )
VERIFICATION.
I, GULZAR ALI S/O QAIMUDDIN by caste Bhatti, adult, musim, Resident of House No.228 Block-E Unit NO.5 Latifabad Hyderabad, do hereby verify on oath that whatever stated above are true and correct to the best of my knowledge and belief.
Deponent/plaintiff
I know the deponent above named.
( Advocate )
The deponent above named is identified by Mr.
, Advocate who is personally known to me.
Commissioner for taking affidavit.
The contents of above affidavit have been read over and explained to the deponent above named in her language at Hyderabad on this 27th, day of June 2008 which she confirms by putting her signature as true and correct on solemn affirmation before me.
Commissioner for taking affidavit
DOUCMENTS FILED
Nikahnama
DOCUMENTS RELIED UPON
Any document filed relevant.
ADDRESSES OF THE PARTEIS.
Same as shown in cause title.
ADVOCATE FOR PLAINTIFF
IN THE COURT OF FAMILY JUDGE HYDERABAD
Family Suit No. of 2009
GULZAR ALI S/O QAIMUDDIN ---------------------------------- PLAINTIFF
VERSUS
MST. NASEEMA RASHEED --------------------------- DEFENDANT
LIST OF WITNESSES.
1- Plaintiff. He will support the contents of his
Plaint
2-
3-
Hyderabad
Dated: 11-8-2009 ADVOCATE FOR PLAINTIFF
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