Child Maintenance Petition Format

Child Maintenance Petition Format

A Child Maintenance Petition is the legal document filed before the Family Court by a parent or legal guardian seeking financial support for a minor child.

The petition explains why maintenance is required and requests the Court to order monthly financial support for the child's upbringing, education, healthcare, and daily expenses.

Although every case has different facts, most child maintenance petitions follow a similar structure.

Basic Child Maintenance Petition Format

IN THE COURT OF JUDGE FAMILY COURT, LAHORE

Family Suit No. _______ / 20____

Mrs. ______________________
Wife/Daughter of __________________
Resident of _______________________

             PLAINTIFF

VERSUS

Mr. ______________________
Son of ____________________
Resident of _______________________

             DEFENDANT

SUIT FOR RECOVERY OF CHILD MAINTENANCE

Opening Paragraph

RESPECTFULLY SHEWETH:

1. That the plaintiff is the mother/legal guardian of the minor child.

2. That the defendant is the father of the minor child and is legally responsible for the maintenance of the child.

3. That the present suit is being filed for recovery of child maintenance.

Details Of The Minor Child

4. That the minor child details are as follows:

Name: ______________________

Date of Birth: ______________

Age: _______________________

School: ____________________

Present Residence: __________

Marriage And Family Background

5. That the parties were married on __________.

6. That from the said marriage the following child/children were born:

a. ______________________

b. ______________________

c. ______________________

7. That due to disputes between the parties they are living separately.

Facts Giving Rise To The Maintenance Claim

8. That the minor child is presently residing with the plaintiff.

9. That the defendant has failed and neglected to properly maintain the minor child.

10. That the plaintiff alone is bearing the expenses of the child.

11. That repeated requests were made to the defendant for maintenance but the defendant failed to fulfill his obligation.

Monthly Expenses Of The Child

12. That the approximate monthly expenses of the minor child are:

School Fee: Rs. __________

Books & Stationery: Rs. __________

Food Expenses: Rs. __________

Medical Expenses: Rs. __________

Clothing Expenses: Rs. __________

Transportation: Rs. __________

Other Expenses: Rs. __________

Total Monthly Expenses: Rs. __________

Financial Position Of The Defendant

13. That the defendant is financially sound and earns approximately Rs. __________ per month from employment/business/other sources.

14. That the defendant is capable of paying proper maintenance for the minor child.

Cause Of Action

15. That the cause of action arose when the defendant failed to provide maintenance for the minor child and continues to accrue every month.

Jurisdiction Clause

16. That this Honourable Court has jurisdiction because the minor child resides within the territorial jurisdiction of this Court and/or the parties reside within its jurisdiction.

Prayer Clause

PRAYER

In view of the above facts and circumstances, it is respectfully prayed that this Honourable Court may kindly:

a. Award monthly maintenance for the minor child.

b. Direct the defendant to pay maintenance regularly.

c. Award maintenance arrears from the date entitlement arose.

d. Grant any other relief deemed just and proper.

e. Award costs of the proceedings.

Prayer For Maintenance Arrears

Where previous maintenance remains unpaid, the petition may also include:

It is further prayed that maintenance arrears amounting to Rs. __________ be awarded in favour of the minor child.

Verification

VERIFICATION

Verified on oath at Lahore on this ____ day of _________ 20___ that the contents of this petition are true and correct to the best of my knowledge and belief.

_____________________
PLAINTIFF

Documents Commonly Attached With A Child Maintenance Petition

• CNIC of the petitioner.

• Birth Certificate of the child.

• B-Form.

• Family Registration Certificate (FRC).

• Nikah Nama.

• Marriage Registration Certificate.

• School fee receipts.

• Medical bills.

• Expense records.

• Proof of residence.

• Any evidence showing the defendant's income.

What Factors Does The Court Consider?

When deciding maintenance matters, the Family Court may consider:

• Age of the child.

• Educational requirements.

• Medical needs.

• Standard of living.

• Father's financial capacity.

• Special needs of the child.

• Current expenses of the child.

Common Mistakes In Child Maintenance Petitions

• Failing to provide expense details.

• Ignoring school and medical costs.

• Not claiming maintenance arrears.

• Submitting incomplete documentation.

• Providing unrealistic expense calculations.

• Failing to present evidence of the defendant's financial position.

Can Maintenance Be Claimed By Overseas Pakistani Mothers?

Yes. Many mothers living abroad seek child maintenance for children residing in Pakistan, while others pursue maintenance claims in Pakistan even though the father is living overseas.

Related guide: Can Child Maintenance Be Handled From Abroad.

Need Help Drafting A Child Maintenance Petition?

At Malhi Law Associates, we assist parents with Child Maintenance Petitions, Maintenance Arrears Recovery Cases, Child Custody Matters, Visitation Rights Cases, and family court proceedings throughout Pakistan.