lIN THE COURT OF SENIOR CIVIL JUDGE LAHORE

Ashraf Masih S/o Rehmat Masih R/o House No. 530-H Farooqia Colony Jahanzib Block Allama Iqbal Town, Lahore. APPELANT Vs Nazia Bibi W/o Ashraf Masih R/o House No. 30 Najaf Colony Bhekewall, Lahore.

RESPONDENT

SUIT FOR DISSULATION OF MARRIAGE U/S 10 OF CHRISTIAN DIVORCE ACT:

Respectfully Sheweth:

1. That the Petitioner was unmarried with the Respondent on 15.04.2005 that the copy of marriage deed is appended here with for kindly perused of Court with the Petition.

2. That during this wed lack two childrens were born Moni Amina and Faizan Ashraf who are under the custody of the respondent.

3. That the respondent lived with the Petitioner as her legal wedded wife in the beginning of our wedded life defendant had relation with some ill reputed persons, but when it come into my knowledge. The Petitioner tried to stop her but the respondent remain intact with those

ill reputed unknown persons, when ever the Petitioner tried to stop her to keep her self away from the company of those the respondent always create a situation of quarrel and its become routine when ever any one of my family request her to keep your self away from those persons respondent always leave the house. 4. That once the Petitioner was out for work proximately at 5.00 oclock the petitioner was crossing in the streets of Gulberg there the petitioner saw the respondent coming out from a house along with an unknown person where as before going to work Petitioner left the respondent at my home, it make the Petitioner conscious, then the Petitioner tried to catch them but unfortunately because of the heavy traffic Petitioner did not succeeded to catch them and reached back to his home as soon as possible but respondent was not at home at that time then the petitioner acquire about her from other family members they told that she left the house by saying so that shes going to met one of her friend soon after you left for work, at that time it come into the mind of petitioner that respondent was committing adultery with that unknown person. 5. That when the respondent returned to home Petitioner asked that where she was respondent tell that she was went to meet on of her friend then the Petitioner asked the respondent that today I saw you with some one there you were coming out with him, from his house, what was you doing there; in return the respondent started hue and cry and said so that I loved him, you cannot stop me to meet him, I will do any thing that I wanted to do this kind of answer, doudt of Petitioner

turn into a reality there after respondent after quarreling left the house of Petitioner along with childrens and never came back. 6. That the Petitioner tried his best to find out that person after that event when the Respondent left the house, the Petitioner tried his best to find that unknown person but all Petitioners efforts gone in vain in this process petitions went again at that place as above said to investigate who was he ? and investigated about that person from the peoples of locality but nothing came into my hands the persons of locality told that a person namely Sadiq or Shafiq was lived there on rent alone few days before he left the house we never saw him again. 7. That the words of respondent and disappearing of the above said person and all other circumstances created a complete belief that respondent is indulged in adultery with that person all the circumstances and conditions are telling that the respondent is living a sinful life of vagabond and adultery, while two years estimatedly are passed and Respondent not even once tried to come to meet the Petitioner while the Petitioner tried his best to rejoin her.

8. That it is to clear from the attitude of Respondent that she is leading a life of an adultery which is very difficult to bear by the Petitioner and know it is not possible by the Petitioner to rejoin with the respondent as a wife in this land of GOD.

9. That there is no connivance and collusion between the spouses and the spouses now cannot live together with each other being Christian husband and wife in the prescribed limits of GOD omnipotent.

10.That cause of action firstly accrued when respondent developed concubinary relations with unknown persons and left the house to live a sinful life. Which is continuing.

11.That spouses lastly resided together at Lahore where the cause of action also accrued, hence this Honorable Court has the jurisdiction to entertain and adjudicate upon the matter.

12.That a prescribed court fee Rs.20/- has been affixed upon the plaint.

Prayer
Under these circumstance, it is mot respectfully prayed that a decree for dissolution of marriage in favour of the Petitioner and against the respondent may kindly be passed, on the basis of adultery committed by the respondent along with unknown persons and desertion.
APPELANT

Through

Muhammad Kamran Siddiquei Advocate High Court Zahid Law Associates 2nd Floor Nawa-I-Waqt Building Shahra-e- Fatima Jinnah Lahore

Verification
Verified on oath at Lahore on this __ day of October 2009 that the contents of the above Para No. 1 to 9 are correct and true to the best of my knowledge and nothing has been concealed those of from 10 to 12 are true and correct to the best of my information and belief.

RESPONDENT