Format of Written Statement In Suit of Dissolution of Marriage on the Basis of Khula

When the suit of dissolution of marriage on the basis of khula is filled. The court send notices to the defendant to file written statement within 15  days. These days can further extended by the court which must not exceed 15 days. After which if defendant does not file written statement in suit of dissolution of dissolution of marriage than the right of defendant to produce evidence will be struck off and ex prate khula will pronounced. Grounds of Dissolution of Marriage on the Basis of Khula are provided in Dissolution of Muslim Marriage Act 1939

In this post i have provided a format of written statement in suit of dissolution of marriage on the basis of Khula.

IN THE COURT OF JUDGE FAMILY COURT, (WEST) ISLAMABAD

In re:

Wife ABCD         Vs     Husband GHI

SUIT FOR DISSOLUTION OF MARRIAGE ON THE BASIS OF KHULA

WRITTEN STATEMENT ON BEHALF OF DEFENDANT

Respectfully Sheweth,

  1. Para No. 1 is admitted to the extent of date of marriage inter-se the parties and prompt dower of Rs. 50,000/-. It is worth mentioning that apart from the payment of prompt dower of Rs. 50,000/-, the defendant had gifted gold ornaments worth Rs. 60,000/- (according to the contemporary market rates). The detail of gold ornaments has been mentioned in annexure “A”, appended with the written statement. Moreover, at the time of Nikah, the plaintiff was also given clothes, shoes and other bridal gifts, appended as annex “B”. Ever-since the Nikah, the defendant and his family members have been giving gifts on certain occasions as appended in annexure “C”. The articles and gifts as mentioned in annexure A, B and C are still in the use and possession of the plaintiff. it is also worth mentioning here that the father of the plaintiff had obtained a loan of Rs. 100,000/- Cash from the elder brother of the defendant for Rukhsati, which amount is also outstanding.
  2. Para No. 2 is not admitted as stated. The facts are that neither the defendant is previously married nor he was cruel and harsh towards plaintiff. Rather he was kind and showed his love to plaintiff, but she didn’t care about this sacred relationship.
  3. Para No. 3 is vehemently denied. There has been good understanding between the plaintiff and the defendant as both are closely related to each other. The defendant never victimized plaintiff and he was very cooperative with paintiff.
  4. Para No. 4 is denied which is totally incorrect. The defendant have a good business and provided plaintiff with mouthful necessities of life. It is the intention of plaintiff to get rid of defendant this is the reason plaintiff is making such a fabricated story.
  5. Para No. 5 is not admitted as stated. The plaintiff is not working rather she lives with her parent and their parent are compelling the plaintiff to get khula from defendant.
  6. Para No. 6 is vehemently denied.
  7. Para No. 7 is also denied being incorrect. The defendant and his family members have been giving gifts and money to the plaintiff on different occasions, as mentioned in reply to para No. 1. So, there is no question of not providing maintenance.
  8. Para No. 8 is not admitted. The plaintiff has got no justification asking for dissolution of marriage. Plaintiff is being played in the hands of family member because the family member of plaintiff does not like defendant.
  9. Para No. 9 is not admitted as stated. All this story narrated by plaintiff is false and concocted hence on the basis of these facts plaintiff cannot be granted with Khuls.
  10. Para No. 10 is denied.
  11. Para No. 11 is legal
  12. Para No. 12 is legal, hence not controverted.

In the light of above, it is, therefore, respectfully prayed that the suit for dissolution of marriage on the basis of khula may graciously be dismissed. And the decree of conjugal right in favor of defendant may kindly be granted.

Defendant

……………….

Through

(Malik Awais Alam)

Advocate High Court.

Verification

Verified on oath at Islamabad on ____ of December 2016 that the contents of this written reply from Para No. 1 to 10 are true and correct to the best of my knowledge and belief, whereas rest of the paras are believed to be correct.

                                                        Defendant

……………..….

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