Khula Petition Sample in Pakistan: PDF & Filing Guide

What is a khula petition sample, and what is it not?

A khula plaint is the written pleading that opens a dissolution suit before a Family Court. Section 7 of the Family Courts Act, 1964 deals with instituting the suit and the supporting witness and document material. The downloadable PDF illustrates a completed structure, not an official blank form or a ready-made pleading for another woman.

Khula and dissolution on grounds under the Dissolution of Muslim Marriages Act, 1939 are different legal bases. A wife may plead khula and separately set out provable statutory grounds in one carefully structured suit when appropriate. The distinction can matter to dower and how the court records its decree; copying a list of allegations without facts and evidence can obscure it.

Pages 1–2 of the PDF: court heading and parties

The sample names the Senior Civil/Family Judge at Rawalpindi and identifies wife and husband in its opening lines. In a new plaint, use the court designation required by the court that actually has jurisdiction, and give each party's full name, parentage, CNIC if available and workable address for service.

The sample's heading is not a form for Islamabad or every part of Rawalpindi. Wrong district, inconsistent identity details or an incomplete address may send the draft back for correction or delay service. Confirm the defendant's present and last known addresses and identify any overseas service issue before filing.

Page 1 and paragraph 11: show why this court can hear the case

The specimen was prepared for a wife residing in Rawalpindi; paragraph 11 asserts the court's territorial jurisdiction. Rule 6 of the West Pakistan Family Courts Rules, 1965 includes the court where a wife ordinarily resides for a dissolution or dower suit, alongside the other jurisdictional grounds in that rule. State the actual residence and supporting facts, not merely the city of the wedding.

If the wife lives in Rawalpindi but married in Lahore, ordinary residence may connect her to a Rawalpindi Family Court. The correct filing district still depends on the real facts, the territorial rules in force and connected claims. Islamabad Capital Territory and Punjab use distinct court administrations; have counsel confirm the designated Family Court before inserting a city heading.

PDF paragraphs 1–3: marriage, nikah nama, dower and children

The sample records a Gujrat marriage, a stated paid dower and one son. Replace all of those particulars with verified information from the current nikah nama, payment records and children's documents. Say whether dower is prompt or deferred, what was actually delivered, and what remains unpaid or disputed.

The PDF's stated amount and single-child facts belong only to its example. A common drafting error is to copy them, label unpaid dower as received or omit a child's correct name and date of birth. Identify a child's separate maintenance or custody needs in the prayer if those remedies are sought.

PDF paragraphs 4–9: facts, legal basis and cause of action

The sample describes years of separation and non-payment of maintenance, then seeks khula. A new petition should set out a truthful dated sequence, indicate whether reconciliation has been attempted, and plead any statutory ground relied upon with facts that can be supported. Avoid importing the PDF's time periods, emotive words or allegations that the client cannot verify.

Do not treat every complaint about marital conduct as proof of a Dissolution of Muslim Marriages Act ground. Plead khula and any separate statutory ground clearly, identify when and where relevant events occurred, and ensure the wife's requested remedy is consistent with her instructions. A lawyer can help decide whether combined pleading improves the case.

PDF paragraph 10 and prayer: what the court is asked to order

The existing sample includes a court-fee statement and asks mainly for dissolution. It does not set out detailed prayers for a child's maintenance, return of dowry articles, recovery of outstanding dower or a custody order. If any of those remedies is needed, investigate entitlement, parties, documents, valuation and the proper relief before filing.

Section 7(2) of the Family Courts Act, in the applicable version, permits a dissolution plaint to include related claims such as dowry, maintenance, dower, wife's personal belongings, custody and visitation. A generic request for 'other relief' is not a substitute for identifying concrete claims. Do not concede dower in a copied paragraph without checking the correct legal basis, sums already paid and the province-specific khula provision.

PDF pages 3–4: signature, verification and annexures

The example ends with a prayer, counsel identification and a verification dated in 2023. The eventual claimant must confirm which paragraphs are within her knowledge, sign or authorise signing as the applicable rules permit, and attach the evidence and copies required at filing. An old verification date, a copied advocate signature or the wrong court location must never remain in a new filing.

Section 7 calls for witness details, a document list and copies for service in the applicable statutory text. The four-page PDF does not itself show a complete witness schedule or every possible annexure. Prepare those materials for the current case rather than assuming the sample is a complete filing bundle.

Documents to gather before drafting a khula suit

Collect the nikah nama or certified marriage record, the wife's identity document and available details of the husband, the dates and addresses relevant to jurisdiction, and a reliable address for serving the defendant. For children, gather Form B or birth certificates. For dower and dowry, bring receipts, bank transfers, photographs, the dowry list and evidence of ownership or delivery where available.

If records are unavailable, tell counsel what is missing instead of inventing an entry. Foreign-issued marriage material or a court's language requirement may call for a suitable translation; the Nikah Nama translation service linked below covers that separate task. Check the court's current copies, document and witness-list requirements before lodging the plaint.

A quick worksheet for reviewing the draft before signing

Bring a simple chronology of nikah, rukhsati if any, changes of residence, separation, attempted settlement and the latest relevant event. Identify each child's school and regular expenses; distinguish groceries, tuition, transport, medicines and housing when maintenance is requested. Make an inventory of bridal gifts and household items with invoices, wedding photographs, messages or delivery receipts where they exist.

Mark each document as original, scan, certified copy or currently unavailable. Note any prior litigation, interim support order, police report, signed compromise, bank remittance or disputed jewellery. This worksheet is for fact gathering; omit private details that are irrelevant to the relief, and agree with counsel how sensitive material should be filed or protected.

For service, collect the spouse’s workplace location, landmark, postal code and any recent verified delivery address. For witnesses, write each person’s occupation, relationship, residential location and the precise event they observed. For disputed assets, identify the item, approximate acquisition date, possession history and current custodian. These small distinctions make the schedule and annexures easier to check.

Rawalpindi and Islamabad: filing the correctly titled plaint

For a wife who ordinarily resides in Rawalpindi, counsel should verify the territorial Family Court within the Rawalpindi district court system, use the proper court title and arrange the defendant's service particulars. For a wife ordinarily resident in Islamabad Capital Territory, verify the assigned Islamabad Family Court and its relevant filing counter or allocation before adopting a West/East Islamabad caption.

The PDF says 'Rawalpindi' because it is a Rawalpindi specimen. Marriage registration elsewhere does not alone force filing there. Ask whether dower, property or children claims affect the forum and whether the court requires specific duplicate sets or annexure formatting. Court allocations and filing desks can change, so confirm them when filing.

What usually happens after the petition is filed?

The court processes the suit and arranges summons or notice to the husband. At the pre-trial stage it considers the pleadings and attempts reconciliation under the applicable Family Courts Act. The court's khula provision addresses a dissolution decree when reconciliation fails; in Punjab the 2015 amendment places that rule in section 10(5), while other consolidated texts may still label the corresponding provision section 10(4). Connected claims can require their own evidence and orders.

Drafting and filing may take days to weeks depending on missing papers and court checks. Service, hearing dates and any dispute can take weeks to months. After the decree, obtain the certified copy and confirm transmission to the relevant Arbitration Council/Union Council and the procedure under the Muslim Family Laws Ordinance, 1961. A statutory notice or waiting interval may apply from receipt of the required communication, and the certificate can take additional time. These are planning ranges, not guaranteed dates.

Cannot attend? Filing through a Special Power of Attorney

Where the wife cannot easily attend, ask counsel early whether a case-specific special power of attorney is suitable for filing and procedural steps. It does not make personal participation unnecessary in every Family Court. The separate Power of Attorney for Khulla guide linked below explains that route and the existing sample authority.

Have the petition drafted or reviewed for the rights at stake

PK-Legal & Associates, led by Fahmida Naz Sheikh, Advocate High Court, works on family court matters in Rawalpindi and Islamabad and can coordinate drafting remotely for overseas clients. A review can identify mismatched nikah details, missing maintenance or property evidence, and whether the prayer actually requests every remedy the wife intends to pursue. Self-filers can also use that review before submitting their own document.

The firm references Islamabad's F-8 Markaz and its Rawalpindi office at 468-E, Street 21, Sector 2, Khayaban-e-Sir Syed. Attock, Taxila, Wah Cantt, Murree, Gujar Khan, Jhelum, Chakwal and Fateh Jang are considered on request, subject to availability and proper court venue; no permanent office in those cities is claimed. Use the current general contact details on this page, not the historical footer printed inside the unaltered PDF.