Family court plaint claiming past and future maintenance with an annual increase, supported by proof of the husband financial means.
When to use this draft
Use where a husband or father has failed to maintain the wife or minor children.
Essential contents
- Relationship established by nikahnama or birth certificates
- Period of non-maintenance with dates
- Income and means of the defendant with proof
- Rate of maintenance claimed with justification
- Prayer for interim maintenance during the suit
Drafting notes
- Always pray for interim maintenance - it is granted early and funds the litigation.
- Plead an annual increase; family courts routinely allow ten percent.
- Attach salary slips, property records or lifestyle evidence to establish means.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.