IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE SUKKUR
Family Suit No. 225/2011
Mst. Nargis W/o Nazir Ahmed, D/o Shahzado
Muslim, Adult by caste Shaikh, R/o Village Muhammad Arab Shaikh Near New Sabzi Mandi Taluka New Sukkur--------------------------------------------Plaintiff. VERSUS Nazir Ahmed S/o Gahi Khan by caste Shaikh Muslim Adult R/o Near New Sabzi Mandi Taluka New Sukkur District Sukkur------------------ ----------Defendant.
CIVIL & FAMLIY DEPOSITION
Dated 20th day of March year 2012
Witness No. I do hereby state on oath that
My name is: Shahzado F/Name: Yar Muhammad
Caste: Shaikh Religion: Islam Caste: Shaikh Occupation: Retired Servant Age about: 57 years Residence: Village Muhammad Arab Shaikh, near Sabzi Mandi, Shikarpur road Sukkur RE-CALLED AND RE-AFFIRMED ON OATH CROSS EXAMINATION TO MR.SHABIR AHMED KHOSO ADVOCATE
I have passed intermediate examination. It is fact that I
along with Nazir Ahmed are residing in same village. There would be 100 houses in village Arab Shaikh. Various tribes are residing in village. It is not a fact that the my wife is the pubhi of defendant. It is fact that Ali Sher, Haji Barkat, Gulzar and Ali Mardan are Nak Mards of our society. The marriage of plaintiff was arranged. It is a fact that we were on volition existing with defendant Nazeer Ahmed. It is incorrect to suggest that we were in knowledge about first marriage of defendant Nazeer Ahmed it is correct that my Daughter/Plaintiff was residing with first wife of defendant Nazeer Ahmed. It is incorrect to suggest that defendant is doing labour in saozi Mandi, voluntarily says that the defendant Nazeer Ahmed is contractor of Banana in Sabzi Mandi. It is incorrect to suggest that defendant Nazeer Ahmed earns Rs.6000/- per month, voluntarily says that the defendant earns one, lac rupees one month. It is incorrect to suggest that defendant Nazeer Ahmed is not having business of Banana, brick cline and state agency. It is incorrect to suggest that the receipt does not show the name of defendant, it shows the name of Zahid Hussain, as he is his Munshi. It is fact that the card does not bear the name of defendant Nazeer Ahmed. It bears the name of Abdul Majeed Muhammad Ramzan and company. Voluntarily says that the defendant is labor contractor of Banana. It is fact that I have not produced other proof regarding of business of defendant Nazeer Ahmed. It is also fact that I have not produced any proof that the defendant Nazeer Ahmed is owner of state agency. It is fact that the cutting of news of Bakhar news paper pertains to 29 th April 2011. It is fact that the news paper shows that an application is pending before family court. It is fact that the suit was filed before this court on 01-10-2011. It is fact that before 01-10-2011 the plaintiff did not file any other suit, before this honorable court. It is fact that the defendant did not receive the notice in person voluntarily says that it was received by one Sadiq. It is fact that complained against defendant Nazeer Ahmed before police and the Nekmard of community. The Nekmard refused to entertain I have produced any proof regarding complaints made by me before police and Nekmard. It is fact that I have not show Nekmard Ali Sher, Barkat, Gulzar Ahmed Ali Mardan as witnesses of the case, nor produced them as witnesses before this court. It is fact that I have not shown any independent witness from village Arab Sheikh, it is a fact that we remained silent for 2009 till 2011 and complained to Nekmard. Prior to filling of this suit, I complained the parents of the defendant, for reconciliation but failed. It is incorrect to suggest that defendant Nazeer Ahmed came to us to see the plaintiff but we gave beatings and insulted him. It is fact that I have produced no witness of village as independent. Baby Mehrunisa studies in school form 2010, the school is a government school there is no fees for the education of baby Mehrunisa. It is fact that I have not produced the school teacher who issued certificate of baby Mehrunisa, before this court. It is fact that we did not give any proof for the expenses of the plaintiff and her child. To be Rs.20,000/- for plaintiff and Rs.100,000/- for each child. It is incorrect to suggest that I am deposing false. No Re SRO & AC Sd/-20-03-2012 Family Judge Sukkur IN THE COURT OF CIVIL JUDGE AND FAMILY JUDGE SUKKUR Family Suit No. 225/2011
Mst. Nargis W/o Nazir Ahmed, D/o Shahzado
Muslim, Adult by caste Shaikh, R/o Village Muhammad Arab Shaikh Near New Sabzi Mandi Taluka New Sukkur--------------------------------------------Plaintiff. VERSUS Nazir Ahmed S/o Gahi Khan by caste Shaikh Muslim Adult R/o Near New Sabzi Mandi Taluka New Sukkur District Sukkur------------------ ----------Defendant.
Cross Examination of the deposition of Mst. Shahzadi W/o Shahzado by
caste Shaikh RE-CALLED AND RE-AFFIRMED ON OATH CROSS EXAMINATION TO MR.SHABIR AHMED KHOSO ADVOCATE FOR DEFENDANT SIDE.
I have passed 8th class. It is fact that I and defendant are
residing in same village. The village Arab Shakhai are caste Shaikh contains about 30/40 houses. The distance between my house and the house of Nazir would be about (100) paces. The Ali Sher, Haji Bhakt, Gulzar and Ali Mardan are also are relative. Ali sheer and Haji Bhakt one rescinding in billage Arab and other are residing village Qureshi (Azizabad) My marriage, was solemnized with the consent of my parents the mother of Nazir is my relative. I do not know whether the mothers of Nazir is my puphe in (Relative) I came to the house of Nazir since child hood. It is incorrect to suggest that I came to know that Nazir has already contracted second marriage. It is correct to suggest that the second wife of Nazir alongwith his child and I were residing in same house. It is correct to suggest that the defendant always maintained his first wife and he did not monition me it is incorrect to suggest that the Nazir is laborer at Sabzi Mandi Sukkur. It is incorrect to suggest that defendant use to earn monthly at Rs.6000/- it is fact that the Nazir is doing the business of banana and bricks and having State Agency. It is fact that the name of Nazir is not shown as owner on receipt of bricks line. I voluntarily say that the receipt is an the name of his son. It is a fact that I have not produce any proof regarding the bricks cline the owner of in the name of Nazir son. It is fact that the name of defendant Nazir Ahmad is not mentioned in the AMR Company. I voluntarily say that the Nazir Ahmed is partner of said Company. It is a fact that I have not produce any prove before this court. I voluntarily say that it have produce the visiting card of Nazir Ahmed. It is correct to suggest that there is no name of Nazir Ahmed produce by me. It is a fact that I have not produce that any prove before this court. It is fact that I have produce the cutting of News paper Bhakr dated: 29-04-2011, which is correct as well as it is correct to suggest that I have mention in same which is correct that the notice was not served to Nazir Ahmed. It is fact that I have filed the present suit against the defendant Nazir on: 01-10-2011. It is fact that I have not produce the application before this court before filling of said suit. It is fact that notice given by me did not receive to Nazir but it was received by one sadiq. It is correct to suggest that I did not complain to any Nek Mards or police due t apprehension of maltreating by defendant. It is fact that I have not produce the list of witness in my suit. It is fact that I have not produce the witness form village Arab Shaikh as witness in my suit. It is correct to suggest that I have not produced any prove regarding bad character of defendant. I left the house of defendant on 07-02-2009 prior to filling of he suit my parents tried to settlement for re-conciliation with defendant but failed. It is correct to suggest that the defendant did not come to my parents house for meeting purpose. I do not remember that from when baby Mehrunisa statement going to school. I do not remember the name of school. It is correct to suggest that my baby is studying in government school where is expenses are free of cost. It is correct to suggest that I have not produce any single witness from school. It is fact that today the baby did not go to the school. It is correct to suggest that the Nazir did not give me Talaq. It is correct to suggest that the written Talaq was received to me through. Pas on 18-10-2011, my father is retire government servant. I do not know the earrings my father. it is correct to suggest that I have no produce any prove regarding expenses as mention in the plaint. It is incorrect to suggest that I am deposing falsely. To Court. It is fact that I was read over all the contains in my affidavit in evidence by my counsel. No Re SRO & AC Sd/-20-03-2012 Family Judge Sukkur