Applicant Evidence Misbah Redacted

IN THE COURT OF CIVIL AND FAMILY JUDGE AT KARACHI

(EAST)

G & W Application No. 193/ 2023

[REDACTED] ---------------------------------- Applicant

Versus

[REDACTED] ----------------------------------- Respondent

AFFIDAVIT IN EVIDENCE OF APPLICANT

I, [REDACTED] D/o [REDACTED]Muslim, Adult, R/o H.no [REDACTED] Jamshed Road [REDACTED]

That I say that the applicant got married with the above named respondent on dated [DATE REDACTED] at Karachi the Nikkah was performed in accordance with the Muslim tradition and the dower amount of fixed Rs. [AMOUNT REDACTED] (Rupees [AMOUNT REDACTED])

That I say that two issues were born out of the wedlock namely:

That I say that both the children are under the custody of the respondent and being tender age they both require proper attention and utmost love and sheer affection of their mother i.e. applicant.

That I say that the respondent and his family has always been negligent towards the applicant and both of their children.

That I say that the household environment of the respondent is unhealthy for both the children due to day to day fights between the respondent and his family members.

That I say that it is pertinent to mention here that the mother of the respondent committed suicide inside the house of respondent due to unknown reason which has put the applicant in extreme worry for both of her children.

Photocopy of the newspaper cutting attached herewith as annexure: “___________”.

That I say that it is pertinent to mention here that due to the untimely and suspicious demise of the mother of the respondent the household environment has now become more threatening for both the children and that their lives are at stake with the respondent and his family members.

That I say that it is pertinent to mention here that both the children have been deprived of motherly love and affection due to the ill intentions of the defendant and his family members.

That it is pertinent to mention here that both the children are being abused both physically and mentally at the house of respondent. Further that the neighbors often hear the screams of children while being beaten from the house of respondent .

(S