Legal Notice to wife

 

ABC                                                                                        Dated.06.06-2021

,

Karachi.

 

Subject.                                                           LEGAL NOTICE

           Under the instructions from our client namely Mr. ………………………………../o Karachi, we have to address you as under:

1.     That our client is belonging to well reputable family & have good reputation in neighborhood, relatives and among the circle around.

 

2.     That you were married with our client on dated 10.12.2014 according to the Christian law.  

 

3.     That you get pregnant in the year of 2015 and started living with your parent’s house even our client insisted you to not leave the home in this crucial condition which could be rhetoric for you and the baby, However you  turned a deaf ear and went to your  parents home and lived their till delivery and all delivery expenses had borne by our client and you came back to home along with the ward.

 

4.     That due to negligence in care ward get unwell and admitted in National Medical Center where it is diagnosed that ward had a chest congestion for which the ward had to admitted  upto 10 days which expenses was also borne by our client.

 

5.     That on 04.05.2019 you were going to attend event in school of minor but had not returned back to our client’s home in this regard our client approach to your father to inquire whereabouts of you and minor, However he could not helped him and told him to not come to my house again.

 

6.     That on 13.05.2019 you had filled the petition C.P No ------ of 2019 for dissolution of marriage by way of judicial separation  U/S 22 Of the divorce act 1869 and maintenance in the court of the XXXI Civil & family Judge East at Karachi and same was return by Court through order dated 05.12.2019.

7.     That all of sudden on 01.12.2019 you called to our client for minor ‘B Form’ so ward could get admission in school so our client accept this for sack of is minor career thus you along with minor came back to home  and you apologized to our client which he accepted and solemnly promised that you will not do this again.

 

8.      That after the B form made then our client apply for admission of minor namely……….. in scent Joseph school sadder, and on 18.01.2020  test has been conducted by the school for admission, however before that on 17.12.2020 in evening you told in home that you went to church for pray along with minor but in reality you skipped again along with all original documents and minor towards khairpur to our client’s younger brother.

 

9.     That from the inception of the marriage, your attitude  remained harsh, indifferent and not becoming a good wife towards our client. many times tried to bring the things to normal condition and kept on tolerating each and every misbehavior  with the hope that one day you will  mend yourself, but you  became adamant day by day lastly it come to our knowledge client you have illicit relation with our clients brother.

 

10.  That there after you came back to Karachi due to Covid 19 and had contacted to our client for reconciliation with our client again apology to our client. It is submitted that our client again accept your apology with big heart and you were start  resided with our client and his parents.

 

11.  That after some days you again disappear with minor and call to our client you are at your parent’s home. It is submitted that within a day you had called to our client due to your mental illness you could not able to look after the minor so our client took the minor in his house but you refuse to come with our client.

 

12.  That after some days our  client received a notice from the court of Xth District and session judge south at Karachi Petition No. ………/2020 Under Section 491 Cr.P.C , Which our client appear before the Honble Court with his counsel on 22.07.2020. it is submitted that you were tender apology with lame excuse and stated that you are not mentally fit, in this regard our client agreed for compromise. 

 

13.  That on 22.07.2020 on the base of compromise statement the Hon’ble Court dispose off your above mention petition on the term of compromise statement. Which is as under:

it is agreed that the respondent No.1 will keep the minor for two days in a week and unless the school are not open then the respondent No.1 will take the minor on Friday but when school will re-open the respondent No.1 will bring the minor on Saturday.

 

 

15. That on 23.08.2020 you took the minor with you and never returned back which is violation of compromise order date 22-07-2020 and you were committed contempt of Court.

 

16. That our client have serious apprehension about the minor and his future  and you were filed deferent case against our client with ulterior motives and malafide intention and even throughout marriage life, you showed yourself greedy at first.

 

17. That our client want to celebrate birth day of minor on 09-07-2021 at his home and our client have already informed you through telephone. 

 

            In the above circumstances, you are hereby called upon to specifically perform your  obligations as per the terms and condition of compromise order date 22-07-2020  and give physical custody of minor to our client  within three days of receipt hereof; failing which we have instructions to proceed against you in due course of law at your sole risk as to cost and consequences.

 

Thanking you

 

                                                                 Gulam Abbas Goyal