Legal guide
Haq Mehr Petition Format
Haq Mehr Petition Format on haq mehr matters in Pakistan.
Haq Mehr Petition Format
A Haq Mehr Petition is a legal document filed before the Family Court seeking recovery of unpaid dower (Mehr) agreed between the spouses at the time of marriage.
Haq Mehr is a legal right of the wife arising from the Nikah and recorded in the Nikah Nama.
Where the husband fails to pay the agreed amount voluntarily, the wife may file a recovery suit before the Family Court.
Basic Haq Mehr 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 HAQ MEHR
Opening Paragraph
RESPECTFULLY SHEWETH:
1. That the plaintiff is the legally wedded wife/former wife of the defendant.
2. That the marriage between the parties was solemnized on __________ according to Islamic injunctions.
3. That the marriage was duly recorded through Nikah Nama.
Marriage Details
4. That according to the Nikah Nama, Haq Mehr was fixed at Rs. __________.
5. That the said Haq Mehr was agreed between the parties at the time of marriage.
6. That the defendant became liable to pay the said amount in accordance with the terms recorded in the Nikah Nama.
Facts Giving Rise To The Claim
7. That despite repeated requests and demands, the defendant has failed and neglected to pay the Haq Mehr.
8. That the plaintiff has repeatedly approached the defendant for payment.
9. That the defendant has unlawfully withheld the amount due to the plaintiff.
10. That the plaintiff is legally entitled to recover the unpaid Haq Mehr.
Prompt Or Deferred Haq Mehr
11. That the Haq Mehr was:
( ) Prompt Haq Mehr
OR
( ) Deferred Haq Mehr
12. That the amount became payable on __________.
Amount Claimed
13. That the plaintiff is entitled to recover:
Principal Haq Mehr Amount:
Rs. __________________
Total Amount Claimed:
Rs. __________________
Cause Of Action
14. That the cause of action arose when the defendant failed to pay the Haq Mehr despite demand and continues to accrue till realization of the amount.
Jurisdiction Clause
15. That this Honourable Court has jurisdiction because the marriage was solemnized within its jurisdiction and/or the parties reside within its territorial limits.
Prayer Clause
PRAYER
In view of the above facts and circumstances, it is respectfully prayed that this Honourable Court may kindly:
a. Decree the suit in favour of the plaintiff.
b. Direct the defendant to pay Haq Mehr amounting to Rs. __________.
c. Award costs of the proceedings.
d. Grant any other relief deemed just and proper.
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 Haq Mehr Petition
CNIC of the plaintiff.
Nikah Nama.
Marriage Registration Certificate.
Family Registration Certificate (FRC).
Divorce Certificate (if applicable).
Khula Decree (if applicable).
Passport copy (for Overseas Pakistanis).
Evidence of demands for payment.
Any correspondence relating to Haq Mehr.
Common Types Of Haq Mehr Claims
Prompt Haq Mehr Recovery.
Deferred Haq Mehr Recovery.
Post-Divorce Haq Mehr Claims.
Post-Khula Haq Mehr Claims.
Overseas Pakistani Haq Mehr Cases.
Family Settlement Disputes Involving Mehr.
Common Mistakes In Haq Mehr Recovery Cases
Not attaching the Nikah Nama.
Confusing Haq Mehr with dowry articles.
Claiming an incorrect amount.
Failing to identify whether the Mehr is prompt or deferred.
Submitting incomplete marriage records.
Ignoring related financial claims.
Can Haq Mehr Be Claimed After Divorce Or Khula?
Yes. In many cases, unpaid Haq Mehr remains recoverable even after divorce or Khula, depending upon the facts of the case and the terms recorded in the Nikah Nama.
Related guides:
Need Help Drafting A Haq Mehr Petition?
At Malhi Law Associates, we assist clients with Haq Mehr Recovery Petitions, Prompt Dower Claims, Deferred Dower Claims, Divorce Financial Claims, Khula Matters, and family court proceedings throughout Pakistan.
Written By Adv. Khurram Shahbaz Malhi
Reviewed by Adv. Khurram Shahbaz Malhi