Suit For Divorce By Muslim Wife (Talaq-Tafweez)

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BEFORE THE HON’BLE JMFC/CITY CIVIL COURT

_____________AT _______________, MUMBAI

Suit no.______ of 20_____

Mrs. ABC W/o DEF                  )

Aged about ……. Years,           )

Occ: Service/Business             )

R/o ________________         )

Mob: ………………………..            )                 

….…………Plaintiff

            Versus

Mr. XXX S/o YYY                      )

Aged about ……. Years,           )

Occ: Service/Business             )

R/o ________________         )

Mob: ………………………..            )              

…………Defendants

 MAY IT PLEASE YOUR HONOUR;

The Plaintiff abovenamed begs to states as follows;

1. That the Plaintiff and the defendant are Mohammedans governed by the Hanafi law.
2. That the Plaintiff was married to the defendant on………….according to the Muslim rites and the Nikahnama was reduced to writing.
3. That the Nikahnama the Plaintiff who at the time of marriage had attained puberty and was in possession of sound mind was delegated the power to effect a Talaq by the Defendant husband. The Nikahnama is attached alongwith this plaint.
4. That after the marriage the Plaintiff came along with the Defendant to reside with him at………………….
5. That during her stay with the Defendant the Defendant treated the Plaintiff with utter cruelty. He would often come home completely drunk and would abuse the Plaintiff in the filthiest terms and also beat the Plaintiff.
6. That utterly disgusted and given to desperation the Plaintiff on………….exercised her right Talaq-e-Tafweez and divorced the Defendant.
7. That in spite of the aforesaid divorce, the Defendant is still pestering and harassing the Plaintiff and the Plaintiff is entitled to a declaration from the court that she is no longer the wife of the Defendant in order to set the matter at rest.
8. Cause of action.
9. The Plaintiff, therefore, claims the following reliefs:

• Decree of Divorce may be granted;
• The defendant may be order to pay Rs……………./- being the permanent alimony;
• The defendant may be order to pay Rs……………./- being the monthly compensation;
• Defendant may be ordered to pay the sum of Rs.__________/- being the amount for mental torture & agony;
• Costs of suit may be awarded to the Plaintiff;
• Any other relief that this Court may deem just and proper.

Plaintiff

Advocate of the Plaintiff

V E R I F I C A T I O N

   I, …………………….., of Mumbai, Hindu, Indian Inhabitant, the Petitioner abovenamed, do hereby solemnly declare that what is stated in Paragraphs ..….. to…….. of the fore going petition is true to my own knowledge.

 Solemnly declared at Mumbai           )

Dated this       day of               , 20___)

  , 20                                                     )    

Plaintiff

Interpreted & Explained by me

Advocate for Plaintiff