Arsalan Written Statement Redacted

IN THE COURT OF [COURT REDACTED] (WEST)

AT KARACHI

Family Suit No. [REDACTED]/2024

Mst. [REDACTED]

D/o [REDACTED]

Muslim, Adult, R/o House no [REDACTED],

Sector [REDACTED] Muhalla Orangi Town [REDACTED]

Karachi …………………………………………….. Plaintiff

V/s

[REDACTED]

S/o [REDACTED]

Muslim, Adult, R/o House no [REDACTED], 13-D

Near Uni School [REDACTED], Orangi Town [REDACTED]

Karachi ……………………………………………….. Defendant

WRITTEN STATEMENT

It is respectfully submitted by the respondent as follows:

PRELIMINARY OBJECTIONS:

That the above suit is liable to be dismissed on all or any of the following grounds, amongst others, viz:-

That the plaintiff has no cause of action to institute and maintain this suit.

That the plaintiff has concealed material and true facts from this Hon'ble Court therefore she is not entitled for equitable and discretionary relief from this Hon'ble Court.

That the plaintiff has not approached this Hon’ble Court with clean hands and since her action is based on ill will and malice, therefore, she is not entitled for equitable and discretionary relief from this Hon’ble Court.

That the suit being frivolous, baseless and vexatious is liable to be dismissed at an initial stage to save the respondent from further harassment and to save the precious time of this Hon'ble Court.

That the allegations contained in the suit are baseless and malicious against the defendant in order to pressurize and blackmail him.

That the suit has been filed with malafide and ill will and with the objective of engaging the defendant in frivolous litigation in order to harass him and to extract illegitimate financial gains.

Without prejudice to the above, it is further submitted by the respondent as follows: -

That in view of the preliminary legal objections as to the maintainability of the suit, the above suit being still born is liable to be buried at an initial stage to save the precious time of this Hon’ble Court and to save the defendant from further hardship, loss, damages and inconvenience.

Additional Facts/ Pleas:

In addition to the above pleas, the Respondent crave leave of this Hon’ble Court to place following facts, whi