SAMPLE OF SUIT FOR RECOVERY OF MAINTENANCE

IN THE COURT OF SENIOR CIVIL JUDGE / FAMILY JUDGE LAHORE

Family Suit No.______________ /2015

Name of Plaintiff     

…..PLAINTIFFS

VERSUS

Name of Defendant

…..DEFENDANT

SUIT FOR RECOVERY OF MAINTENANCE

Respectfully Sheweth

1.     That the plaintiff No.1 was marriage with defendant on 11-09-2011, in   accordance to Muslim family laws of Pakistan, against the dower amount of 100,000/- which is still unpaid. The copy of Nikahnama was attached herewith and annexed as “A”.
2.     That after  solemnization of marriage  one issue namely  ……. was born on 23-06-2012,  during the tenor of marriage the relationship between the plaintiff and defendant got worse, as on the third day of the marriage the defendant started abusing the plaintiff and beat the plaintiff as well, as the defendant was in toxic condition and asked about the paper for divorce, and after two days of this incident the plaintiff went to the house of her mother, and the plaintiff returned back to the house of the defendant on 20-09-11. But during the tenor of marriage on many occasions insulted the plaintiff on bitty matters, but in the year2012, the disputes got so worse the defendant in anger cut the nerve of his hand, the relative of the defendant took him to the Hospital for treatment, afterwards the plaintiff and the defendant went to house of the mother of the plaintiff for taking rest in the house, but after two days time the defendant again made a fight with the plaintiff and her family members, and went back to his house and since then he never have contacted the plaintiff, nor paid any money towards the maintenance of her and the minor child, and since then the plaintiff is raising the minor by earning the bread and butter for her. The copy of the birth certificate was attached and annexed “B”.
3.    That since 2012, the defendant never contacted the plaintiff nor paid any money towards the maintenance of her and the minor child, and since then the plaintiff is raising the minors by earning the bread and butter for her.
4.     That the defendant is working in private factory and his earning is Rs. 20,000/= every month, the plaintiffs claim maintenance for Plaintiff No.1 @ Rs. 4000/= from 11-09-2011 and maintenance for Plaintiff No.2 @ Rs. 4000/= since her birth.
5.     That the cause of action for the instant suit accrued firstly on 11-09-2011, when the plaintiff married to the defendant, secondly, when the defendant left the house of the plaintiff mother in the year 2012. And the cause of action is still continuing as the defendant did contact the plaintiff for any consolidation.
6.     That the plaintiffs are residing within local limits of Police Station …….. that fall within the territorial jurisdiction of this Hon’ble Court.
7.      That the proper court fee has been affixed as per law.

PRAYER

It is therefore, very humbly and respectfully prayed that this Hon’ble Court may kindly be please to pass judgment and decree in favor of the plaintiff and against the defendant as under:-

•     To direct the defendant to pay past maintenance to the plaintiffs at the rate of Rs.4,000/= per month from 11-09-2011, up till now and in future upto iddat period.
•     to direct the defendant to pay past maintenance to the plaintiffs at the rate of Rs.4,000/= per month since her birth on increment of 10% in future till her marriage.
•     Cost of the suit.

            Any other relief which this Hon’ble Court may deem fit and proper.

                                                PALINTIFF

              Through

Advocate

Dated:____/01/2015