IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE SUKKUR

Family Suit No. 225/2011

Mst. Nargis W/o Nazir Ahmed, D/o Shahzado

Muslim, Adult by caste Shaikh, R/o Village
Muhammad Arab Shaikh Near New Sabzi
Mandi Taluka New Sukkur--------------------------------------------Plaintiff.
VERSUS
Nazir Ahmed S/o Gahi Khan by caste Shaikh
Muslim Adult R/o Near New Sabzi Mandi
Taluka New Sukkur District Sukkur------------------ ----------Defendant.

CIVIL & FAMLIY DEPOSITION

Dated 20th day of March year 2012

Witness No.
I do hereby state on oath that

My name is: Shahzado F/Name: Yar Muhammad

Caste: Shaikh Religion: Islam
Caste: Shaikh Occupation: Retired Servant Age
about: 57 years
Residence: Village Muhammad Arab Shaikh, near Sabzi Mandi,
Shikarpur road Sukkur
RE-CALLED AND RE-AFFIRMED ON OATH
CROSS EXAMINATION TO MR.SHABIR AHMED KHOSO ADVOCATE

I have passed intermediate examination. It is fact that I

along with Nazir Ahmed are residing in same village. There would be
100 houses in village Arab Shaikh. Various tribes are residing in village.
It is not a fact that the my wife is the pubhi of defendant. It is fact that
Ali Sher, Haji Barkat, Gulzar and Ali Mardan are Nak Mards of our
society. The marriage of plaintiff was arranged. It is a fact that we were
on volition existing with defendant Nazeer Ahmed. It is incorrect to
suggest that we were in knowledge about first marriage of defendant
Nazeer Ahmed it is correct that my Daughter/Plaintiff was residing with
first wife of defendant Nazeer Ahmed. It is incorrect to suggest that
defendant is doing labour in saozi Mandi, voluntarily says that the
defendant Nazeer Ahmed is contractor of Banana in Sabzi Mandi. It is
incorrect to suggest that defendant Nazeer Ahmed earns Rs.6000/- per
month, voluntarily says that the defendant earns one, lac rupees one
month. It is incorrect to suggest that defendant Nazeer Ahmed is not
having business of Banana, brick cline and state agency. It is incorrect
to suggest that the receipt does not show the name of defendant, it
shows the name of Zahid Hussain, as he is his Munshi. It is fact that
the card does not bear the name of defendant Nazeer Ahmed. It bears
the name of Abdul Majeed Muhammad Ramzan and company.
Voluntarily says that the defendant is labor contractor of Banana. It is
fact that I have not produced other proof regarding of business of
defendant Nazeer Ahmed. It is also fact that I have not produced any
proof that the defendant Nazeer Ahmed is owner of state agency. It is
fact that the cutting of news of Bakhar news paper pertains to 29 th
April 2011. It is fact that the news paper shows that an application is
pending before family court. It is fact that the suit was filed before this
court on 01-10-2011. It is fact that before 01-10-2011 the plaintiff did
not file any other suit, before this honorable court. It is fact that the
defendant did not receive the notice in person voluntarily says that it
was received by one Sadiq. It is fact that complained against defendant
Nazeer Ahmed before police and the Nekmard of community. The
Nekmard refused to entertain I have produced any proof regarding
complaints made by me before police and Nekmard. It is fact that I
have not show Nekmard Ali Sher, Barkat, Gulzar Ahmed Ali Mardan as
witnesses of the case, nor produced them as witnesses before this
court. It is fact that I have not shown any independent witness from
village Arab Sheikh, it is a fact that we remained silent for 2009 till 2011
and complained to Nekmard. Prior to filling of this suit, I complained the
parents of the defendant, for reconciliation but failed. It is incorrect to
suggest that defendant Nazeer Ahmed came to us to see the plaintiff
but we gave beatings and insulted him. It is fact that I have produced
no witness of village as independent. Baby Mehrunisa studies in school
form 2010, the school is a government school there is no fees for the
education of baby Mehrunisa. It is fact that I have not produced the
school teacher who issued certificate of baby Mehrunisa, before this
court. It is fact that we did not give any proof for the expenses of the
plaintiff and her child. To be Rs.20,000/- for plaintiff and Rs.100,000/-
for each child. It is incorrect to suggest that I am deposing false.
No Re
SRO & AC
Sd/-20-03-2012
Family Judge Sukkur
 IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE SUKKUR
Family Suit No. 225/2011

Mst. Nargis W/o Nazir Ahmed, D/o Shahzado

Muslim, Adult by caste Shaikh, R/o Village
Muhammad Arab Shaikh Near New Sabzi
Mandi Taluka New Sukkur--------------------------------------------Plaintiff.
VERSUS
Nazir Ahmed S/o Gahi Khan by caste Shaikh
Muslim Adult R/o Near New Sabzi Mandi
Taluka New Sukkur District Sukkur------------------ ----------Defendant.

Cross Examination of the deposition of Mst. Shahzadi W/o Shahzado by

caste Shaikh
RE-CALLED AND RE-AFFIRMED ON OATH
CROSS EXAMINATION TO MR.SHABIR AHMED KHOSO ADVOCATE FOR
DEFENDANT SIDE.

I have passed 8th class. It is fact that I and defendant are

residing in same village. The village Arab Shakhai are caste Shaikh
contains about 30/40 houses. The distance between my house and the
house of Nazir would be about (100) paces. The Ali Sher, Haji Bhakt,
Gulzar and Ali Mardan are also are relative. Ali sheer and Haji Bhakt
one rescinding in billage Arab and other are residing village Qureshi
(Azizabad) My marriage, was solemnized with the consent of my
parents the mother of Nazir is my relative. I do not know whether the
mothers of Nazir is my puphe in (Relative) I came to the house of
Nazir since child hood. It is incorrect to suggest that I came to know
that Nazir has already contracted second marriage. It is correct to
suggest that the second wife of Nazir alongwith his child and I were
residing in same house. It is correct to suggest that the defendant
always maintained his first wife and he did not monition me it is
incorrect to suggest that the Nazir is laborer at Sabzi Mandi Sukkur. It
is incorrect to suggest that defendant use to earn monthly at Rs.6000/-
it is fact that the Nazir is doing the business of banana and bricks and
having State Agency. It is fact that the name of Nazir is not shown as
owner on receipt of bricks line. I voluntarily say that the receipt is an
the name of his son. It is a fact that I have not produce any proof
regarding the bricks cline the owner of in the name of Nazir son. It is
fact that the name of defendant Nazir Ahmad is not mentioned in the
AMR Company. I voluntarily say that the Nazir Ahmed is partner of said
Company. It is a fact that I have not produce any prove before this
court. I voluntarily say that it have produce the visiting card of Nazir
Ahmed. It is correct to suggest that there is no name of Nazir Ahmed
produce by me. It is a fact that I have not produce that any prove
before this court. It is fact that I have produce the cutting of News
paper Bhakr dated: 29-04-2011, which is correct as well as it is
correct to suggest that I have mention in same which is correct that the
notice was not served to Nazir Ahmed. It is fact that I have filed the
present suit against the defendant Nazir on: 01-10-2011. It is fact that I
have not produce the application before this court before filling of said
suit. It is fact that notice given by me did not receive to Nazir but it was
received by one sadiq. It is correct to suggest that I did not complain to
any Nek Mards or police due t apprehension of maltreating by
defendant. It is fact that I have not produce the list of witness in my
suit. It is fact that I have not produce the witness form village Arab
Shaikh as witness in my suit. It is correct to suggest that I have not
produced any prove regarding bad character of defendant. I left the
house of defendant on 07-02-2009 prior to filling of he suit my parents
tried to settlement for re-conciliation with defendant but failed. It is
correct to suggest that the defendant did not come to my parents
house for meeting purpose. I do not remember that from when baby
Mehrunisa statement going to school. I do not remember the name of
school. It is correct to suggest that my baby is studying in government
school where is expenses are free of cost. It is correct to suggest that I
have not produce any single witness from school. It is fact that today
the baby did not go to the school. It is correct to suggest that the Nazir
did not give me Talaq. It is correct to suggest that the written Talaq was
received to me through. Pas on 18-10-2011, my father is retire
government servant. I do not know the earrings my father. it is correct
to suggest that I have no produce any prove regarding expenses as
mention in the plaint. It is incorrect to suggest that I am deposing
falsely.
To Court.
It is fact that I was read over all the contains in my affidavit
in evidence by my counsel.
No Re SRO & AC
Sd/-20-03-2012
Family Judge Sukkur