Cross examination of the deposition Atta Muhammad S/o Ismail , by cast abbasi

RE-CALLED AND RE-AFFIRMED ON OATH.

11.12.2010
CROSS TO MISS AMBER IQBAL ADV: FOR DEFENDANT

I may that Shahid is son of my sister, I do not remember date

of marriage of Shahid with Mst. Naheed. I do not remember the date of
birth of minor son of Shahid but he born at Hospital thereafter brought to
the house of Shahid. I say that relation between the spouses were strained
but I do not know the reason. I do not remember when Mst. Naheed was
divorced but I voluntarily. Stay that she has divorced on her demand, while
residing with her parents in their house. I say that Shahid was called by
Naheeds elders at shop opposite to press Club Sukkur, where divorce was
demanded and given, I say that at the time of divorce people from both the
parties were present including, I say that for 3 to 4 times Shahid remained
confined in lockup on complaint by Mst. Naheed. it is incorrect to suggest
that all the expenses incurred delivery of child were borne by parents of
Mst. Naheed I say that Shahid run business of selling laces. I do not know
whether Shahid I sending any maintenance allowance for his son or not. It
is correct to suggest that Shahid did not take efforts for sending
maintenance allowance for his son. It is incorrect to suggest that I am
unaware of facts and just deposing at the instance of Muhammad Shahid.
It is incorrect to suggest that Shahid used to maltreat Naheed so she went
to reside with her parents. It is incorrect to suggest that Shahid never
maintained her wife. It is incorrect to suggest that I am deposing falsely
before this Court.
No-Re S.R.O. & A.G.
Sd/-11-12-2010
(Miss Sadaf Khokhar)
Family Judge Sukkur.
Note.
Typed under diction and
Hearing of parties.
Sd/-11-12-2010
Family Judge Sukkur.
Cross examination of the deposition Mst. Naheed D/o Muhammad Qadeer by
caste Abbasi
RE-CALLED AND RE-AFFIRMED ON OATH.
4.2.2011
Cross to Mr. Ubedullah Malano Advocate for applicant.

I have no private of Government services. I am only have held

lady I and my father and brother are residing jointly. My father as
Shopkeeper of Jusice Shop, I do not know writher the income of my father.
It is a fact that in my objection, I have not mention that the income of my
father, It is a fact that I have not mention in my objection that the
welfare/fully of minor is safe of own read father, the applicant Muhammad
Shahid as own shop of house, and he used to earn much money from the
business, It is not a fact that the divorce was given by the applicant
Muhammad Shahid nor I have demanded me, It is fact that I obtained my
L.T.I of divorce-dead forcibly it is a fact that I have no mentioned in my
objection as well as affidavit-in-evidence that for my maintain and
maintenance of minor, it is a fact that the welfare and well being of minor is
not lies in the hand of applicant. It is a fact that the applicant not meet at
my house with minor boy. It is not a fact that the welfare of minor is not lies
with applicant. It is incorrect to suggest that the welfare of minor is not safe
with me. It is correct to suggest that I am deposing falsely.
No-Re S.R.O. & A.G.
Sd/-04-02-2011
Family Judge Sukkur.
Cross examination of the deposition Mumtaz Ahmed S./o Haji Fajr Ahmed by
caste Abbasi
RE-CALLED AND RE-AFFIRMED ON OATH.
4.2.2011
Cross to Mr.Ubedullah Malano Advocate for applicant.

Mst. Naheed is my niece. She is jobless. The father of Mst.

Naheed is rented shop at Gariba Sukkur, They are resides as jointly in
some house the distance between my house and the house of Mst.
Naheed at about 7/8 house away. It is a fact that the divorce-dead was
given by the applicant/Muhammad Shahid. It is incorrect to suggest that
neither the arrested of the brother and father of Mst. Naheed the police, I
do not remember the arrest of applicant and his brother. The divorce-deed
was written in Sukkur house (MNA House). It is a fact that the welfare of
the minor is lies in the hand of his mother. It is a fact that I am deposing at
the instance of the opponent Mst. Naheed it is a fact that I am deposing is
true and correct the applicant Muhammad Shahid his own shop and own
house. It is incorrect to suggest that the welfare of minor is lies with his
father, I do not remember the date of incident and maltretily the opponent. I
do not remember the date: month and time, where I was vested the house
applicant and I have came to know through my sister that the relation ship
between opponent and applicant was not good.
No-Re S.R.O. & A.G.
Sd/-04-02-2011
Family Judge Sukkur.
Cross examination of the deposition Altaf Ahmed S/o Azeemuddin by caste
Abbasi.
RE-CALLED AND RE-AFFIRMED ON OATH.
Cross to Mr. Ubedullah Malano Advocate for applicant

Mst. Naheed is my sister-in-law, she is not my ___________, I

was present at the time of Nikah but I am not witness in this Nikah, It is
correct to suggest that the applicant is his brother was arrested by the C
Section Police. The applicant was given the divorce-dead with his own
consent at circuit House Sukkur, he does not meet with minor at the house
of opponent Mst. Naheed, They are residing jointly in some house. She is
jobless lady, her father is shopkeeper is reveled shop at Garibabad, The
applicant have own Shop and own house at Neem-ke-Chari, It is incorrect
to suggest that the welfare of child is lies upon his father, it is a fact that the
minor always remain ill, in the house of mother. It is fact that I am
displaying with my own consent and through the opponent, it is fact that
the applicant is real faithful minor son and he has right it is a fact that at the
time of meeting on minor, not happing with father, it is incorrect to suggest
that I am deposing falsely.
No-Re S.R.O. & A.G.
Sd/-02-04-2011
Family Judge Sukkur.
Cross examination of the deposition Muhammad Shaid S/o Jamaluddin, by caste
Abbasi

RE-CALLED AND RE-AFFIRMED ON OATH.

11,12,2010
CROSS EXAMINATION TO MISS AMBER IQBAL ADVOCATE FOR
DEFENDANT.

I say that my marriage with Mst. Naheed was arrange by my

mother, it is correct to suggest that during substance of marriage relations
remained straight between Naheed and I, it is incorrect to suggest that I
gave divorce as my wife wished but I voluntarily say that I was not willing
to divorce her but she demanded divorce from me. I say that when I
divorced Naheed then she was residing with her parents but I voluntarily
say that she gave application to DPO Sukkur, in which she stated that I
may be compelled to gave divorcee to her, in this connection I was also
confined in police lockup of P.S C section Sukkur. I say that when I gave
divorce to wife then her parents, brothers, cousins, uncles and my father
were present. It is incorrect to suggest that I did not bear delivery
expenses incurred on delivery of child. I say that after delivery when Mst.
Naheed was discharged from Hospital then she came to my house. It is
correct to suggest that parents of Mst. Naheed used to visit her at my
house. It is incorrect to suggest that I used to maltreat Mst. Naheed so she
used to leave my house to stay with her parents. It is incorrect to suggest
that parents of Mst. Naheed borne all the expenses incurred on delivery of
child. It is correct to suggest that I have no paired any maintenance
allowance to my Ex-Wife for maintenance of my child but I voluntarily say
that I am willing to maintain my child but Mst. Naheed refused to take
money from me, so also meeting with the minor. It is incorrect to suggest
that I never took offer from meeting with minor. It is incorrect to suggest
that I am deposing falsely before this court.
No-Re S.R.O. & A.G.
Sd/-11-12-2010
(Miss Sadaf Khokhar)
Family Judge Sukkur.
Note.
Typed under diction and
Hearing of parties.
Sd/-11-12-2010
Family Judge Sukkur.
Cross examination of the deposition Muhammad Zahid S/o Jamaluddin, by caste
Abbasi

RE-CALLED AND RE-AFFIRMED ON OATH.

11,12,2010
CROSS EXAMINATION TO MISS AMBER IQBAL ADVOCATE FOR
DEFENDANT.

I say that Muhammad Shaid is my alder brother. I say that I

am married to the sister of Mst. Naheed who is residing with me, in a joint
family system. it is incorrect t suggest that Shahid gave divorce to his wife
on his own, but I voluntarily say that Mst. Naheed demanded divorced form
my brother. I say that when Mst. Naheed was divorced then she was
residing with her parents. It is correct to suggest that when Shahid
divorced then I was present there, along with so many people from both
sides. I say that my brother was confined in P.S. C Sections Lockup on
complaint made by Mst. Naheed to DPO Sukkur I say that Muhammad
Hamza Born to Mst. Naheed at sodegran Hospital situated at Nimiki Chari
Sukkur, and all the expenses were borne by my brother. I further say that
after discharge from Hospital Mst. Naheed along with infant came to our
house. Is say that relation between Shahid and Naheed got strained after
marriage of her brother in the month of May 2010. it is correct to suggest
that after divorce no maintenance allowance has been sent to Mst. Naheed
and minor child. It is incorrect to suggest that we did not take afforts for
maintaining minor but I voluntarily say that in court when child was brought
for meeting then my brother tried to give them money for maintenance but
Mst. Naheed refused to accept. It is incorrect to suggest that Shahid used
to maltrat Mst. Naheed. It is incorrect to suggest that in marriage ceremony
of Naheeds brother Shahid also maltreated her. It is incorrect to suggest
that due to maltreatment Shahid was confined in lockup of P.S. on her
complaint. It is incorrect to suggest that for number of times Shahid
extended threats of killing hi minor child by throwing him out form window.
It is incorrect to suggest that Shahid used to demand money from
Naheeds parents. It is incorrect to suggest that Shahid never maintained
his wife and child. It is incorrect to suggest that I am deposing falsely at the
instance of my brother Shahid.
No-Re S.R.O. & A.G.
Sd/-11-12-2010
(Miss Sadaf Khokhar)
Family Judge Sukkur.