Legal Question in Family Law in Pakistan

sir iss case ka kya dicision hoo ga court ka. RESTITUTION OF CONJUGAL RIGHTS RESPECTFULLY SUBMITTED 1- That the addresses given in the heading of the plaint are sufficient for the service of the notices/summons etc. of the parties. 2- That the brief facts giving rise to file the present case are that the marriage ceremony was solemnized between the plaintiff and defendant on 05-06-2011 and dower amount was fixed at Rs. 11,000/- (In Dul Talab which the defendant had forgiven. Photo copy of NIKKAH NAMA is annexed herewith as ANNX �A�. 3- That out of this wedlock two children namely Minal aged almost 2 years and Maham Shaikh aged 9 months were born, it is pertinent to mention here that Minal has been left in custody of plaintiff by the father of the defendant and Maham is in custody of the defendant. 4- That on 06-06-2014 the mother of the defendant had asked her to accompany her to attend �Quran Khani� which on request the plaintiff allowed defendant to go with her mother, father and other family members, the defendant then went with her mother, and brothers along with 9 months old Maham and wearing 07 tolas gold ornaments. 5- That on said date 6-6-2014 while the plaintiff alongwith the defendant on way to the house of defendant�s mother, the defendant disrespected the plaintiff which caused intense anger then the plaintiff hit two slap the defendant then ran into the house of her mother when defendant�s brother Shahid came out he took the plaintiff into the house where he and others also disrespected, spoken untowords, misbehaved the plaintiff alleging him to have hitted slaps and simultaneously divorced the defendant two times. The defendant was divorced when menstruating. 6- That it is also pertinent to mention here when defendant�s father and brother came to plaintiff house on when the plaintiff went to market for buying some refreshment articles for them and left his mobile at home. In meanwhile the brother of the defendant appears to have used plaintiff�s mobile and wrote SMS of divorce words Talaq Talaq Talaq and sent it to defendant�s mobile number and deleted the message from outbox/sent message from plaintiff mobile which is not in the knowledge of plaintiff. 7- That the plaintiff many times visited the house of the parents of the defendant and requested them to return back the defendant to the plaintiff, for her conjugal house of the plaintiff and perform her marital obligations but parents and brother of the defendant paid no heed in this regard lingering on the matter on one pretext or other and put the matter deaf ear. The parents and brother of the defendant are not good persons although the defendant is gentle women and obedient wife. 8- That a week ago the plaintiff along with respectables of family approached the defendant and requested her to join plaintiff and perform her marital obligations but the parents of the defendant flatly refused to listen the genuine request of the plaintiff hence the necessity of this suit. 9- That the cause of action accrued in favour of the plaintiff against the defendant firstly when the marriage was solemnized between the parties secondly when the plaintiff many times requested the defendant to join the plaintiff and lastly a week ago when the defendant totally refused to listen the request of the plaintiff only because of the pressure put on by the parents therefore the cause of action is still recurring. 10- That the plaintiff resides in Hyderabad and the cause of action accrued at Hyderabad, therefore, this Hon�ble court has jurisdiction to entertain and adjudicate upon the matter. 11- That the requisite fee stamp has been affixed on the plaint. PRAYER Under these circumstances it is respectfully prayed that this Hon�ble court may be pleased to pass a decree for restitution of conjugal rights in favour of the plaintiff against the defendant directing the defendant to join the plaintiff and perform marital obligations to meet the end of justice. sir kya wife merey ghar aa jaa ey gi ya nahi. aur meri 2 daughters merey pass hey.divorce hoo gi ya nahi. kisi na kisi tareeqay sey wife aa jaa ey

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