Suit Under Defamation Ordinance 2002 For Recovery of Damages

IN THE COURT OF DISTRICT JUDGE, LAHORE.
___________Daughter of ___________Resident of ___________l,

Near Government High School, care of Zaman General Store, Multan
Road, Lahore.
….Plaintiff
VERSUS
___________ Son of ___________, Caste ___________Resident of

Chah Gulabi Wala, Mouza Rukanabad, Tehsil & District Multan.
….Defendant
SUIT UNDER DEFAMATION ORDINANCE 2002

FOR THE RECOVERY OF RS. 20,000,000/-
Respectfully Sheweth:-
1. That plaintiff belongs to a very noble, pious educated
family and having a very good reputation in family as well
as in society.
2. That the plaintiff was married with the defendant on
04.06.2000 but the behaviour and conduct of the
defendant was not good with the plaintiff and he made
his habit to torture and misbehaved with the plaintiff.

2
Out of this wedlock one son Muhammad Kaashan aged
about 11 years and Pakeeza aged six years were born.
3. That at the time of marriage the defendant posed himself
as bachelor and he concealed his earlier marriage. It is
pertinent to mention here that firstly defendant was
married on 25.12.1993 with one Rafia Sultana Daughter
of Muhammad Ali Resident of Firdous Market, Gulberg-
III, Lahore, from this wedlock two children Tehreem
Iftikhar and Muhammad Arslan were born.
The defendant entered into second marriage in the
year 1998 with one Rubina.
4. That the plaintiff was third wife of the defendant but this
fact was concealed by the defendant at the time of
marriage and posed himself as bachelor.
5. That on 18.12.2012 the defendant divorced the plaintiff
through written divorce deed without any reason by
levelling defamatory allegations in the divorce deed,
which are reproduced hereunder:
6. That the above referred words of the defendant are
highly defamatory and due to which the plaintiff and her
family has suffered great mental torture and also a loss

3
of their reputation among their family, locality and
friends.
7. That a statutory notice under the defamation ordinance
dated 01.04.2013 through registered Post A.D. was duly
sent to the defendant but the defendant failed to reply
the same.
8. That these acts of defendant were illegal and with
malafide intention just to defame the plaintiff in the
eyes of public and due to these acts of the
defendant, the reputation of the plaintiff injured.
This action caused extreme adverse humiliation to
the goodwill of the plaintiff and her family, sustain
mental torture and also damage the health of the
plaintiff especially her parents. Moreover, the
damages claimed by the plaintiff in this suit against
defamatory words used by the defendant against the
plaintiff in divorce deed cannot be compensated in
shape of money but however, the plaintiff is entitled
to recover damages from the defendant as follows:
(i) Damages for defamatory Rs. 10,000,000/-

words, loss of reputation
and loss of profession
(ii) Damages for mental torture, Rs. 9,000,000/-
tension of plaintiff and his
parents
(iii) False allegations and loss of Rs. 900,000/-
profession
4
(iv) Legal charges / expenses Rs. 100,000/-

TOTAL Rs. 20,000,000/-
9. That the cause of action accrued in favour of the plaintiff
and against the defendant firstly when the defendant
made above mentioned defamatory words, secondly
when the plaintiff sent the statutory notice to the
defendant who didn’t reply the same and the defendant
did not redress the grievances of the plaintiff.
10. That the plaintiff is of Lahore, the cause of action
accrued at Lahore, hence this Honourable Court has got
jurisdiction to try and entertain the suit.
11. That the value of the suit for the purposes of court fee
and jurisdiction is fixed at Rs. 20,000,000/- and the
requisite court fee shall be affixed as and when ordered
by this Honourable Court.
It is, therefore, respectfully prayed that a

suit under Defamation Ordinance 2002 may please
be decreed in favour of the plaintiff and against
the defendant by awarding a maximum
punishment to the defendants and also directed to
pay Rs. 20,000,000/- as damages under the
Defamation Ordinance 2002.
It is further prayed that any other relief

which this court deems fit may also be awarded.
5
Plaintiff
Through
Advocate High Court
VERIFICATION
Verified on oath at Lahore this 30th day of April 2013 that
the contents of paras No. 1 to 8 are correct to the best of
my knowledge and remaining paras No. 9 to 11 are true
to the best of my belief.
Plaintiff

Suit Under Defamation Ordinance 2002 For Recovery of Damages

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IN THE COURT OF DISTRICT JUDGE, LAHORE.

___________Daughter of ___________Resident of ___________l,

___________ Son of ___________, Caste ___________Resident of

SUIT UNDER DEFAMATION ORDINANCE 2002

1. That plaintiff belongs to a very noble, pious educated

family and having a very good reputation in family as well

2. That the plaintiff was married with the defendant on

04.06.2000 but the behaviour and conduct of the

defendant was not good with the plaintiff and he made

his habit to torture and misbehaved with the plaintiff.

Out of this wedlock one son Muhammad Kaashan aged

about 11 years and Pakeeza aged six years were born.

3. That at the time of marriage the defendant posed himself

as bachelor and he concealed his earlier marriage. It is

pertinent to mention here that firstly defendant was

married on 25.12.1993 with one Rafia Sultana Daughter

of Muhammad Ali Resident of Firdous Market, Gulberg-

III, Lahore, from this wedlock two children Tehreem

Iftikhar and Muhammad Arslan were born.

The defendant entered into second marriage in the

year 1998 with one Rubina.

fact was concealed by the defendant at the time of

marriage and posed himself as bachelor.

5. That on 18.12.2012 the defendant divorced the plaintiff

through written divorce deed without any reason by

levelling defamatory allegations in the divorce deed,

which are reproduced hereunder:

6. That the above referred words of the defendant are

highly defamatory and due to which the plaintiff and her

family has suffered great mental torture and also a loss

of their reputation among their family, locality and

7. That a statutory notice under the defamation ordinance

dated 01.04.2013 through registered Post A.D. was duly

sent to the defendant but the defendant failed to reply

8. That these acts of defendant were illegal and with

malafide intention just to defame the plaintiff in the

eyes of public and due to these acts of the

defendant, the reputation of the plaintiff injured.

This action caused extreme adverse humiliation to

the goodwill of the plaintiff and her family, sustain

mental torture and also damage the health of the

plaintiff especially her parents. Moreover, the

damages claimed by the plaintiff in this suit against

defamatory words used by the defendant against the

plaintiff in divorce deed cannot be compensated in

shape of money but however, the plaintiff is entitled

to recover damages from the defendant as follows:

(i) Damages for defamatory Rs. 10,000,000/-

(iv) Legal charges / expenses Rs. 100,000/-

9. That the cause of action accrued in favour of the plaintiff

and against the defendant firstly when the defendant

made above mentioned defamatory words, secondly

when the plaintiff sent the statutory notice to the

defendant who didn’t reply the same and the defendant

did not redress the grievances of the plaintiff.

10. That the plaintiff is of Lahore, the cause of action

accrued at Lahore, hence this Honourable Court has got

jurisdiction to try and entertain the suit.

and jurisdiction is fixed at Rs. 20,000,000/- and the

_____Daughter of _Resident of _______l,

_____ Son of _, Caste _______Resident of