Legal guide
Divorce And Khula Petition Format
Divorce And Khula Petition Format on divorce & khula matters in Pakistan.
Divorce And Khula Petition Format
A Divorce Petition or Khula Petition is the formal legal document filed before the Family Court to seek dissolution of marriage.
Although every case has unique facts, most divorce and Khula petitions follow a standard legal structure.
The exact contents depend upon whether the matter involves divorce by the husband, Khula by the wife, or related claims such as child custody, maintenance, Haq Mehr, or dowry articles.
Basic Divorce And Khula Petition Format
IN THE COURT OF JUDGE FAMILY COURT, LAHORE
Family Suit No. _______ / 20____
Mrs. ______________________
Daughter/Wife of __________________
Resident of _______________________
PLAINTIFF
VERSUS
Mr. ______________________
Son of ____________________
Resident of _______________________
DEFENDANT
SUIT FOR DISSOLUTION OF MARRIAGE
THROUGH KHULA
Or where applicable:
PETITION FOR DISSOLUTION OF MARRIAGE
Introductory Paragraph
RESPECTFULLY SHEWETH:
1. That the plaintiff is the legally wedded wife of the defendant.
2. That the marriage between the parties was solemnized on __________ according to Islamic Shariah.
3. That the marriage was duly recorded through Nikah Nama.
Marriage Details Section
4. That after marriage the parties started living together as husband and wife.
5. That from the said wedlock the following children were born:
a. ______________________
b. ______________________
c. ______________________
Facts Leading To Divorce Or Khula
6. That serious differences arose between the parties.
7. That the plaintiff made repeated efforts to save the marriage but all efforts failed.
8. That it has become impossible for the parties to continue their matrimonial relationship peacefully.
9. That the plaintiff has lost all affection and respect for the defendant and cannot live within the limits prescribed by Islam.
10. That no possibility of reconciliation remains.
Grounds For Seeking Khula
11. That the plaintiff seeks dissolution of marriage through Khula on the following grounds:
a. Irreconcilable differences.
b. Breakdown of matrimonial relationship.
c. Mental incompatibility.
d. Continuous disputes and conflicts.
e. Loss of mutual trust and confidence.
f. Any other grounds available under law.
Cause Of Action
12. That the cause of action accrued when the defendant failed to maintain a peaceful matrimonial relationship and continues to accrue every day.
Jurisdiction Clause
13. That this Honourable Court has jurisdiction because the parties last resided together within the territorial jurisdiction of this Court and/or the plaintiff presently resides 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. Dissolve the marriage between the parties through Khula.
b. Issue the necessary decree of dissolution.
c. Grant any other relief deemed just and proper.
d. Award costs of the proceedings.
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 Divorce Or Khula Petition
CNIC of the petitioner.
Nikah Nama.
Marriage Registration Certificate.
Passport copy (if Overseas Pakistani).
Children's Birth Certificates.
Family Registration Certificate (FRC).
Proof of residence.
Supporting documents relevant to the dispute.
Additional Claims Often Filed With Divorce Or Khula Petitions
Many clients file additional family law claims together with the divorce or Khula matter, including:
Child Custody.
Child Maintenance.
Visitation Rights.
Haq Mehr Recovery.
Dowry Articles Recovery.
Jewellery Recovery.
Maintenance Arrears.
Related guides:
Need Help Drafting A Divorce Or Khula Petition?
At Malhi Law Associates, we assist clients with Divorce Petitions, Khula Petitions, Child Custody Petitions, Maintenance Claims, Haq Mehr Recovery Cases, Dowry Articles Recovery Cases, and family court proceedings throughout Pakistan.
Written By Adv. Khurram Shahbaz Malhi
Reviewed by Adv. Khurram Shahbaz Malhi