Farhan Khaliq Anwer Advocate; The Lords International [Magazine of Law & Law Fields]

IN THE COURT OF CIVIL & FAMILY JUDGE – KARACHI . Suit No: 000/2000 Mst. S. Bol…………………… PLAINTIFF. VERSUS A. E. Khan. ……………………      DEFENDANT. COUNTER AFFIDAVIT TO APPLICATION U/S 17-A OF FAMILY COURT ORDINANCE. I, A. E. Khan S/O Late Khan, Muslim, adult, presently residing at House No. B, Housing Society, Karachi, do hereby state on oath as under: 1.     That I say that I, belong to a noble and civilized family and I used to earn my livelihoods by doing Private Job / works on daily wages in America /USA. Now just because of attitude of plaintiff, I am encircled in financial and other metromonial problems as and since last 10 months, I could not go to my workplace to earn, therefore I am jobless now. 2.     That I say that I had sufficient means to provide comfort and necessities of life to plaintiff and my son / baby. After the marriage, I / the answering defendant has paid handsome amounts to...

COMMON GROUNDS FOR BAIL APPLICATION 1.          That, applicant/accused is innocent and has falsely implicated in this case by police due to enmity. 2.          That, applicant / accused is ready to furnish surety for the satisfaction of the court.  3.          That, applicant / accused is neither previous convicted nor hardened criminal. 4.          That out of three culprits, none of them is specifically named, as assailant. 5.          That, the accused is no more required for investigation or recovery; the final challan has been submitted. 6.          That, the case of applicant/accused falls under proviso 3-A of S/497(1) Cr.P.C. 7.          That, the applicant / accused has g...