IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS
OF JUDGE FAMILY COURT, LAHORE
Family Suit No. -----------------------------------2024
1. Mst. ANAM RAMZAN W/o ALI HASSAN
2. As the name of the plaintiff No. 2 has been deleted
by the order of the learned Trial Court
3. RAMEEN ALI D/o ALI HASSAN(29-10-2018)
4. AMNA ALI D/o ALI HASSAN (29-09-2022)
Minors through their birth mother: the plaintiff no. 1
All the plaintiffs presently residing at both R/o Street No. 2,
Mohallah Hakim Ghulam Hussain Colony, Lahore
Plaintiffs
VERSUS
1. Ali Hassan S/o Muhammad Arshad R/o House No. 8, Street
No. 28-B, Mohallah Shaheen Park, Sultan Pura, Lahore.
Defe
ndant
AMENDED PLAINT
SUIT FOR RECOVERY OF;
DOWERY ARTICLES OR SUBSTITUTED
AMOUNT @ 1635000/- AS PER LIST
MAINTENANCE ALLOWANCE OF THE
PLAINTIFFS,
MEDICAL EXPENDITURE BORNE BY
PLAINTIFF NO. 1 AT THE TIME OF THE
BIRTH OF PLAINTIFF NO. 4 @ 100000/-
AND ALL OTHER MISCELLANEOUS
EXPENSES.
Respectfully Sheweth:
1. The concise facts giving rise to filing the instant suit are
that on 16-03-2015 with Late Faisal Arshad, elder
brother of the defendant. Faisal Arshad died on 25-07-
2017, leaving behind plaintiff No. 1 as a widow and
plaintiff No. 2 as the only minor son of the deceased.
It is pertinent here that all the notables of the family
got plaintiff No. 2 married to the defendant on 22-12-
2017 after the demise of his elder brother, so the
liability and responsibility to look after the minor,
plaintiff No. 2 shifted to the defendant.
2. The plaintiff No one was married to the defendant
according to Muslim rites and Sharia Muhammadi, and
the dower amount was paid at the time of the marriage.
Out of this wedlock, a minor, namely RAMEEN ALI, born
on 29-10-2018, and AMNA ALI, born on 29-09-2022,
respectively, is living with the plaintiff. No one is at the
above-given address. A copy of the Nikah Nama with
the birth registration certificate of the minor/ plaintiff
no.2, 3, and 4 is attached here with the plant.
3. That from the very inception of the marriage, the
defendant's attitude remained reprehensible and
condemnable. Still, the plaintiff, being a pure Eastern
and Islamic woman, put up with all his cruelties and
excesses and tried her utmost to make the conjugal life
smooth, palsy-palsy-walsy, unruffled. No stone was left
unturned in his obedience, but the defendant started to
treat her inhumanly, hellishly, and barbarously.
Resultantly, outrageous hatred developed between the
couple because the defendant was habitual, brutalized,
and self-absorbed and married the plaintiff just to grab
dowry articles.
4. the defendant is very narrow-minded and a bundle of
time. He blamed the character of Plaintiff No. One and
often beat Plaintiff No.1 in petty household matters and
made her life miserable by his act and conduct and
tortured Plaintiff No. 1 badly and resultantly the
defendant, after harsh beating to plaintiff No. 1, ousted
her on 20-07-2022 in three wearing clothes in a
miserable plight when she was pregnant of 7 months
with the plaintiff No. 4 and the plaintiffs No. 1,2,&3
were left deserted and penniless since then she is living
with her family at the address mentioned above.
5. That the defendant is a man of greed who married the
plaintiff just to usurp value-able dowry articles given to
the plaintiff at the time of marriage
6. That plaintiff No. 2 is minor. All the expenses are being
borne by plaintiff No. 1. The defendant did not pay even
a single penny to plaintiff no 1 in the name of
maintenance allowance from the very first day of
marriage till now and did not pay even a single rupee to
the plaintiff No. 2, 3 & 4 in the name of maintenance
allowance from the very first day of their birth till the
filing of this suit.
7. At the time of marriage, a significant quantity of the
dowry articles was given to the Plaintiff by her parents
as per a list valuing 1635 000/- list lying in the
defendant's possession and is liable to be returned. If
any ornament has been damaged or destroyed,
substitute the amount for all these articles.
8. That plaintiff no one, along with notables of the locality,
time and again asked the defendant for reconciliation
and to pay the dower amount and maintenance
allowance of the plaintiffs and other medical and
miscellaneous expenses borne by plaintiff No. 1 and
return the dowry articles of the plaintiff no. 1 but the
defendant making flimsy excuses refused to do so
hence this suit.
9. The defendant is a man of means who is professional in
aluminum work and running his thekedari with
professional facilitation with different companies. He
earns about 200,000/—per month, so he can quickly
pay Rs-50.000/—for the maintenance of plaintiffs no. 2,
3, and 4 from the first day of their birth and Rs.
50,000/—for the upkeep of plaintiff no. 1 from the very
first day of the marriage.
10. That the cause of action accrued against the defendant
firstly when the defendant married the plaintiff,
secondly when the defendant kicked the plaintiff out of
his house in three wearing clothes and miserable plight,
thirdly when the plaintiff No 2, 3 & 4 were born and
fourthly when the defendant refused to pay the
maintenance allowance of the plaintiffs and other
medical and miscellaneous expenses borne by the
plaintiff no. 1 and return the dowry articles of the
plaintiff no. 1
11. The plaintiffs reside in Lahore, and the cause of action
also arose there, so this honorable court has jurisdiction
to adjudicate the matter.
12. The prescribed court fee has been affixed.
PRAYER
Given the above submissions, it is, therefore, most
respectfully prayed that a decree for the payment
maintenance allowance of the plaintiffs and other
medical and miscellaneous expenses borne by
plaintiff no. 1 and returning of the dowry articles of
plaintiff no. 1 might kindly be passed in favor of the
plaintiffs against the defendant.
Any other relief this Honorable Court deems fit
may also grant the plaintiffs.
PLAINTIFFS
MUHAMMAD AZEEM KHUSHI
Advocate High court
AFSHAN SHAHEEN
Advocate High court
