IN THE COURT OF XVITH FAMILY JUDGE AT KARACHI

south
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

the defendant remained normal, affectionate and considerate. Thereafter,

he became rude, rash unreasonable, cold and cruel. He started ignoring the
plaintiff No.1 and beating her from time to time without any reasons.
4.

That I say that defendant became ruthless and authoritarian person.

He could not be predicted. He beat the plaintiff very mercilessly. He

threatened the plaintiff many times to kill her.
5.

That I say that the defendant is suffering from some complex and

Psychological problems. He is not a mentally and emotionally fit person.

6.

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.

That I say that the defendant is not a loving, affectionate and

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

maintaining the plaintiff since July, 2012.

11.

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 I say that the defendant is liable to make payment of the

maintenance charges to the plaintiff.

13.

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

my knowledge and belief.

Karachi.
Dated:-07-10-13

DEPONENT
The deponent is identified by me
ADVOCATE

Affirmed on oath before me at Karachi on this 07 day of October , 2013

by the Deponent identified to me by MR. ADIL HAYAT SANDHU
ADVOCATE, who is personally known me.

COMMISSIONER FOR TAKING AFFIDAVIT