IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

W.P. No._____________/2000

Ejaz Ahmad S/o Jumma Shah, caste Syed, R/o Usmanabad, Near
Railway Station, Muzaffarabad, Multan.
Petitioner
VERSUS
Mst. Mussarat Bibi D/o Muhammad Saeed (wife of Ejaz Ahmad),
caste Syed, R/o H. No. 40, Street No. 2, Chah Thallay Wala, Old
Shujabad Road, Multan.
Respondent

Writ Petition under Article 199 of the

Constitution of Islamic Republic of
Pakistan, 1973, against the judgment
& decree dated 12.10.2000 passed by
Mr. Muhammad Akram Rana the
learned Family Judge, Multan, by
which the suit “Restitution of
Conjugal Rights” was dismissed when
suits “Dissolution of Marriage” was
decreed.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That the petitioner filed a suit for “Restitution of Conjugal

Rights” against the respondent, and respondent filed five suits
namely (i) “Recovery of Maintenance Allowance” for herself (ii)
 “Recovery of Maintenance Allowance” for children (iii)
“Recovery of Haq-ul-Mehr” (iv) Recovery of Dowry Articles” &
(v) “Dissolution of Marriage” against the petitioner.

3. That all the six suits were consolidated and disposed of by single
judgment. The “Suit for Restitution of Conjugal Rights”, “Suit
for Haq-ul-Mahr”, “Suit for Maintenance Allowance” of
respondent were dismissed and “Suit of Dissolution of Marriage”
was decreed. Copy of plaint, written statement, issues, judgment
and decree are Annexes “A, B, C, D & E”.

4. That the impugned judgment is liable to be set aside inter alia on

the following: -

GROUNDS

i) That the impugned judgment is against the principles of

natural justice and law of equity.

ii) That the impugned judgment is against the law and facts
of the case.

iii) That the impugned judgment is result of non-reading

and mis-reading of evidence.

iv) That the learned trial court failed to take the notice that
the respondent could not produce any cogent and
substantial evidence against the petitioner.

v) That there was every likelihood of compromise between

the parties but no serious efforts were made by the
learned trial court.

vi) That the impugned judgment has caused a great

miscarriage of justice to the petitioner.

vii) That there is no other alternate, adequate and

efficacious remedy available to the petitioner except to
 invoke the constitutional jurisdiction of this Hon’ble
Court.

In view of the above submissions, it is

respectfully prayed that this petition may
graciously be allowed, the impugned judgment
dated 12.10.2000 may please be set aside.

Humble Petitioner,

Dated: ___________

Through: -

CERTIFICATE: -

Certified as per instructions of the client,

that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.

Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 W.P. No. ______________/2000

Ejaz Ahmad Versus Mst. Mussarat Bibi

AFFIDAVIT of: -
Ejaz Ahmad S/o Jumma Shah, caste Syed, R/o
Usmanabad, Near Railway Station, Muzaffarabad,
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above petition are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of November 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 In re: C.M. No. _____________/2000
In
W.P. No.____________/2000

Ejaz Ahmad Versus Mst. Mussarat Bibi

APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth:-
That certified copies of Annexures “____________”
are not available. However, uncertified/photo state copies of
the same have been annexed with the Petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
PETITIONER

Dated: __________
(Ejaz Ahmad)

Through: -
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

In re: C.M. No. _____________/2000

In
W.P. No.____________/2000

Ejaz Ahmad Versus Mst. Mussarat Bibi

DISPENSATION APPLICATION

AFFIDAVIT of: -
Ejaz Ahmad S/o Jumma Shah, caste Syed, R/o
Usmanabad, Near Railway Station, Muzaffarabad,
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above application are true and correct to the
best of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of November 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

W.P. No.____________/2000

Ejaz Ahmad Versus Mst. Mussarat Bibi

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit
5 Copy of Plaint. A
6 Copy of written statement. B
7 Statement of DW-1 C
8 Copy of Judgment D
9 Copy of Decree. E
10 Dispensation Application.
11 Affidavit.
12 Vakalatnama

PETITIONER

Dated: ____________

Through: -