Sample Shameel Written Statement

IN THE COURT OF CIVIL & FAMILY JUDGE AT KARACHI (SOUTH)

FAMILY SUIT NO._____/2024

[APPLICANT NAME]

S/o [FATHER NAME]

Muslim, adult, R/o H.no 59/60-A

Bait ul Valika

New Queens Road, [AREA REDACTED]

Karachi …..….………………………..………. Applicant

Versus

[RESPONDENT NAME]

D/o [FATHER NAME] Muslim, Adult,

R/o FT-4-6/2 Frere town [AREA REDACTED]

OPP-ISL

Karachi ……………………………………….. Respondent

[MINOR 1 NAME] D/o [APPLICANT NAME]

Aged 13 years and 2 months old;

[MINOR 2 NAME] S/o [APPLICANT NAME]

Aged 06 years & 08 months old;

[MINOR 3 NAME] D/o [APPLICANT NAME]

Aged 04 years and 11 months…………...Minors

WRITTEN STATEMENT

It is respectfully submitted by the Defendant as follows:-

PRELIMINARY OBJECTIONS:

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

That the applicant has no cause of action to institute and maintain the instant suit.

That the applicant has not come with clean hands before this Hon’ble Court and the allegations contained in the plaint are baseless and malicious against the respondent in order to pressurize and blackmail her.

That the above suit is based on absolutely incorrect, false and baseless grounds and hence liable to be dismissed with cost.

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

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

That the contents of Para no.1 as well as annexure A are vehemently denied being irrelevant in the instant suit. That the applicant is deliberately attempting to pressurize this Honorable Court by giving an impression of his family being influential and powerful in the society.

That the contents of Para no.2 are vehemently denied being irrelevant and baseless in the instant suit. That the applicant is deliberately attempting to show off himself as pious while the applicant has not approached this Honorable Court with clean hands. Further that by mentioning th