Legal Notice Sample Draft

date______________

To,

Mr. _____

S/o______,

R/o____________

_____,

Karachi

Subject: - LEGAL NOTICE

Dear Sir,

This communication is being addressed to you on behalf of my client Mst. _______D/o-S/O _______Resident of , ______________, who has instructed me to address you as follows:-

That on dated: _____marriage was solemnized between you and my client according to the Muslim rites and Shariat against the dower amount of Rs. _____/- (_____________only). Which was already paid to my client and the same has been returned back to you.

That the marriage was consummated and out of this wedlock there are three children born namely ______about___ years old, _____about __years old and _____about __ years old.

That after the marriage, your behavior was not proper towards my client and very inception days of marriage, she found you as a trouble maker and you used derogatory and abusive language against her on petty matters.

That soon after the marriage your behaviour became very harsh and cruel towards my client. My client was also a victim of verbal abuse and mental torture. Further that my client tried her level best to save this marriage bond but she failed to do so, due to your uncooperative behaviour.

That you never ever gave my client the respect, attention and love desiring attitude that she always expected as a husband from you. Instead you kept treating her in a harsh manner and that you have always been deliberately negligent towards the client and her needs.

That my client tried her level best to maintain and continue the marital relation with you. However all of her efforts went into the vain since you never made any attempt of reconciliation and kept her as well as the children in the desertion. Hence, having left with no other option my client approached the Honourable Court and filed a suit for dissolution of marriage by way of khula bearing family suit no. ____/202__ to part her ways in a peaceful manner after spending four years of desertion from your side.

That the pre-trial proceedings were held in the said family suit and the same was declared failed under section 10(4) of West Pakistan Family Courts Act 1964, the marriage between you and m