SUIT FOR SEPARATION.

IN THE COURT OF CIVIL JUDGE/FAMILY JUDGE & JUDICIAL MAGISTRATE-1  HYDERABAD
Family Suit No.        of 2009



Dhellan d/o Manyo by caste Bheel
wife of  Assan, hindu, adult,
Resident of village Haji Siddique Baloch
P-O Bukera Sharif Taluka Chambar
District Tando Allahyar          ---------------------     PLAINTIFF

VERSUS

Assar s/o Gangaram by caste Bheel
hindu, adult, resident of village Mir Ashiq
Ali Talpur Mirwah Gorchani, Mirpurkhas    ---------    DEFENDANT



SUIT FOR SEPARATION.
        The plaintiff above named respectfully begs to submit as under:-
1-        That, plaintiff was married with the defendant about seven(7) years back as per Hindu custom

2-        That, after Rukhsati plaintiff started residing with the defendant at his house at above given address as his legally wedded wife and performed all the marital obligation and proved herself a loyal, obedient and loving wife. Out of such wedlock plaintiff has no issue.
3-        That, at the time of marriage plaintiff was given dowry articles viz. One Haar of Silver 1/2-Kg, bangles, Half Kg Silver, gold Mangalsutar weighing 01-Tola, one gold Lakhi Jhumka, Nosal ring weighing 7-Ana, ear-rings of gold and other house hold articles were given to the plaintiff which she brought at the house of defendant and are lying at his home.

4-        That, defendant is a man of questionable character, habitual drunkard, even do not maintain the plaintiff, not only this but

( 2 )
used to beat her on petty matter and plaintiff being a loving and obedient wife always borne all such attitude with a hope that one day defendant will amend his attitude.

5-        That,  plaintiff has passed very painful life with the defendant as the defendant is a man of short tamper and he not only beat the plaintiff, but also burn her with the burning cigarettes and such marks are available on her person.

6-        That, on              at odd hours of night when defendant was under the influence of wine, after giving severe beating ousted out the plaintiff from his house in three plain clothes and all the dowry articles, even gold ornaments are lying with the defendant and since then plaintiff is residing at above mentioned address, but defendant has never come ahead to take back the plaintiff to his house.

8-        That, due to maltreatment, cruel conduct and non-maintenance the plaintiff has created extreme hatred against the defendant in her heart and mind and she is not ready to join the plaintiff in a hateful union and she will prefer to die rather to reside with plaintiff and now it become difficult for the plaintiff to pass her life with the defendant within the limits prescribed by ALLAH Almighty.

7-        That, it is worth mention here that defendant is also extending threats to the plaintiff that if she will not again join him, he will kidnap her or will kill her so also will make his family members horrible example.
8-        That, cause of action for filing the instant suit has accrued to the plaintiff when defendant failed to maintain her and her children, beat her on petty matters under the influence of wine and, the cause of action again accrued to the plaintiff on                  when she was ousted out by the defendant from his house in three clothes and did not turn up to take back the plaintiff to his house.

9-        That, this Honourable Court has got jurisdiction to adjudicate upon the matter.

10-        That, necessary court fee is affixed in shape of stamp on the memo of plaint.

PRAYER.
11-        That, plaintiff respectfully prays for following judgment and decree against the defendant:-
( 3 )
a)    That, this Honourable Court may be pleased to declare the separation between the plaintiff and defendant as per Hindu custom for the end of their marriage.
   
b)    Any other relief which this Honourable Court deems fit and proper may please be awarded to the plaintiff.



Tando Allahyar
Dated: 10-6-2009                        ( PLAINTIFF )

VERIFICATION.
          I,  Dhellan d/o Manyo by caste Bheel wife of  Assan, hindu, adult, Resident of village Haji Siddique Baloch P-O Bukera Sharif Taluka Chambar  District Tando Allahyar, 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. Aghis-u-Salam Tahirzada,  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 Tando Allahyar on this 10th, day of June 2009 which she confirms by putting her signature as true and correct on solemn affirmation before me.


                     Commissioner for taking  affidavit

DOUCMENTS FILED




DOCUMENTS RELIED UPON
Any document filed relevant.

ADDRESSES OF THE PARTEIS.
Same as shown in cause title.
                               ADVOCATE FOR PLAINTIFF











IN THE COURT OF CIVIL JUDGE/FAMILY JUDGE & JUDICIAL MAGISTRATE-1  HYDERABAD
Family Suit No.        of 2009


Dhellan d/o Manyo    ------------------------------------     PLAINTIFF

VERSUS

Assar s/o Gangaram    ---------------------------------    DEFENDANT





LIST OF WITNESSES.
       
1)    Plaintiff.                    She will depose as per her
                             plaint and will support it.


2)                            He will support the version
                            of plaintiff.


3)                             He will support the version
                             of plaintiff.


Tando Allahyar
Dated: 10-06-2009              ADVOCATE FOR PLAINTIFF