IN THE COURT OF ________ FAMILY JUDGE AT KARACHI (EAST)
Family Suit No._________/2023
…………………………………………………………Plaintiff
V/S
………………………………………………………..….Defendant
WRITTEN STATEMENT
Respectfully Sheweth,
1. That the contents of para 1 are formal and does not require a reply.
2. That the contents of para 2 are admitted as a matter of fact.
3. That the Defendant in the aforementioned family suit is the wife of the Plaintiff–however
–it must be noted that the couple had separated a while ago due to the constant violence
inflicted on by the Plaintiff on the Defendant. Against this backdrop, the Defendant had no
option but to file a family suit bearing number ____________for dissolution of marriage
by way of khula to once and for all put an end to the cycle of violence and free herself of
this relationship that has –for years –remained the cause of torment, fear and hurt for the
Defendant.
4. That the contents of para 3 are admitted to the extent that previously compromise
agreement was signed between the parties. However, same was violated by the Plaintiff
himself. When he continued to inflict domestic violence on the Defendant and use coercive
control over the Defendant.
5. That it is highly significant to mention that the present case is filed soon after the Defendant
filed the khula case which goes to show the vindictive nature of this suit, hence creating
grounds for unequivocal rejection of the same by this Honorable Court. At this juncture, it
becomes imperative to also mention that this vengeful conduct is evidenced in this Court’s
previous and similar proceedings where the Plaintiff repeated this behavior ___________
Needless to say, proceeding with this suit, which is marred by revenge and desperation,
will only lead to wastage of the precious time of this Court.
6. The contents of paragraph 4 are vehemently denied, as the Plaintiff never allowed the
Defendant to live happily. He made her life miserable, which led her to leave the marital
home and start living with her parents in order to protect her life.
7. That the contents of para 6 and 7 are denied and the fact that must be mentioned here is
that the Defendant is a homemaker, a responsible, loving and caring lady who always put
her family first. This is why in the previous similar proceedings; she joined the Plaintiff
soon after he approached her with the promise of amended good behavior despite the
threats to her physical and mental well-being.
8. That the contents of para 8 are denied because of being false and fabricated. It is submitted
that Defendant does not want to re-join Plaintiff in any case, since she fears her life due to
Plaintiff’s ill behavior
9. That the contents of para 9, 10 and 11 are formal hence does not require a reply.
COUNTER-PRAYER
It is prayed on behalf of the Defendant that this Honorable Court may graciously be pleased
to pass the judgment and decree in favor of the Defendant as follows.
1. That the Khula must be granted to the Defendant.
2. Any other relief which this Honorable Court deems appropriate in the
circumstances of the proceedings.
Dated: ____________
ADVOCATE FOR THE DEFENDANT
IN THE COURT OF ________CIVIL AND FAMILY JUDGE
AT KARACHI EAST
Family Suit No. ______
Hamid Rehman Khan …….……………………………………………….Plaintiff
VERSUS
Shumaila Hamid Khan………………………………………………Defendant
AFFIDAVIT IN SUPPORT OF WRITTEN STATEMENT
I, _______________________________,Karachi, do hereby solemnly affirm on oath as
under:
1. That I am the Defendant and I am fully conversant with the facts of this case.
2. That the marriage between me and Plaintiff took placed on dated_______________,
in consideration of dower amount of Rs 51,000, which has not been paid to me by
Plaintiff till today.
3. The accompanying Suit has been drafted under my instructions, contents of which
and the above affidavit for the sake of brevity is deemed to form an integral part
thereof.
4. That I have no other equally efficacious and adequate alternate remedies, save
preferring the subject Suit.
5. Unless the accompanying Suit n is granted as prayed, the Defendant shall be
seriously prejudiced and suffer irreparable loss and injury.
Whatever is stated herein above is true and correct to the best of my knowledge, information
and beliefs and the legal pleas have been taken upon advice received from counsel, which
advice I verily believe to be true and correct.
DEPONENT
Dated _______________-
