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Family Suit No. 291/13
MST. Farzana...PLAINTIFF
V/S
Khalid Hussain.DEFENDANT.
AFFIDAVIT-IN-EXPARTE PROOF
I Farzana Akram, D/o M. Akram,
Muslim, Adult, R/o House No. 1678,St#31, Liaquat Ashraf Colony# 2,
Mehmoodabad #6, Karachi, do hereby state on oath as under:1.
That I am the Plaintiff and hence fully conversant with
the facts of the case.
2.
That I say that the plaintiff was married to the defendant on 24-
02-2002.
3.
That I say that for about 3 months after marriage, the attitude of
That I say that the defendant is suffering from some complex and
That I say that the plaintiff has undergone very uncertain conditions
for the last about seven years. She has been subjected to mental torture,
agony and serious hardship.
7.
That I say that the defendant is not a hardworking and steady earning
person. He does not permanently work on one place and leaves his jobs
after fighting with his employers for trifles. As such, he is not providing
proper maintenance to the plaintiff and the children.
8.
considerate husband. The plaintiff does not feel comfortable and safe while
living with him as his wife.
9.
That I say that the plaintiff has developed sheer hatred and despise for
the defendant on account of his very cruel conducts. She cannot Live with
the defendant as his wife any more within the prescribed LIMITS OF
ALMIGHTY ALLAH.
10.
That I say that the defendant has Thrown out the plaintiff and he is not
That I say that the plaintiff can not live with the defendant as his
wife. She wants the dissolution of marriage with the defendant on the basis
of KHULA against waiver of payment of Dower amount -to the plaintiff.
12.
That all the modes of service were exhausted. The defendant has been
served but he has failed to file his written statement. He has been declared to
be proceeded against ex-parte.
14.
That unless the instant Family Suit of the plaintiff is allowed the
Plaintiff will be seriously prejudiced and will suffer heavy civil injuries.
15.
That whatever has been stated above is true and correct to the best of
DEPONENT
The deponent is identified by me
ADVOCATE