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Official Citation: 2026 LHC 4758
Court / Jurisdiction: Lahore High Court
Parties: Arslan . vs Nisha Shahid etc
Ruling Summary: This decision was rendered by the Lahore High Court, officially reported as 2026 LHC 4758. In this matter between Arslan . and Nisha Shahid etc, the court adjudicated key questions of statutory construction, procedural regularity, and legal precedent under Pakistani law.
Core Holding: The honorable bench evaluated governing statutory provisions and judicial authorities to establish the rights of the parties, delivering the binding reasoning set out below.
COURT: Lahore High Court (Honorable Mr. Justice Mohsin Akhtar Kayani) DECISION DATE: 01-07-2026 TAGLINE: Family Law?Dissolution of Marriage?Dower (Haq Mehr)?Effect of declaration by the Federal Shariat Court regarding Section 10(5) & (6) of the Family Courts Act, 1964?Distinction between Khula and dissolution under the Dissolution of Muslim Marriages Act, 1939?Wife's entitlement to dower where dissolution is granted on account of husband's cruelty?Principles for determination by Family Courts ?Following questions determined: i) Whether, after the declaration of sub-sections (5) and (6) of Section 10 of the Family Courts Act, 1964 as repugnant to the Injunctions of Islam, the Family Court retains jurisdiction to determine a wife's entitlement to dower on a case-to-case basis? ii) Whether a decree for dissolution described as "Khula" necessarily entails forfeiture or return of dower irrespective of the cause of dissolution, or whether a distinction exists in law between dissolution founded on the wife's mere aversion (Khula simpliciter) and dissolution occasioned by the husband's cruelty or other grounds under law? iii) Whether physical, psychological, emotional, verbal or economic abuse amounts to cruelty sufficient to disentitle the husband from claiming return of dower, in whole or in part? iv) What principles ought to govern the exercise of judicial discretion by Family Courts in determining the question of dower where dissolution is sought on the ground of cruelty or matrimonial misconduct? v) Whether the learned Family Court erred in awarding fifty percent (50%) of the deferred dower to the wife on the facts of this case? CASE DETAILS: Family 20300/23 ============================================================ Form No:HCJD/C-121 ORDER SHEET IN THE LAHORE HIGH COURT, LAHORE JUDICIAL DEPARTMENT
Writ Petition No.20300 of 2023
Arslan. Versus Nisha Shahid etc.
S. No. of order/ proceeding. Date of order/ proceeding Order with signature of Judge, and that of parties or counsel, where necessary.
01.07.2026. Mr. Muhammad Asif Kainth, Advocate for the petitioner. Ms. Amber Qayyum, Advocate/Amicus Curiae. Mr. Muhammad Farooq-e-Azam, Civil Judge/Research Officer, Lahore High Court, Lahore.
Through this writ petition, the petitioner, Arslan, has assailed the order and decree dated 01.09.2022 passed by the learned Senior Civil Judge (Family Division), Toka Tek Singh, whereby the suit filed by respondent No.1, Nisha Shahid, for dissolution of marriage, recovery of maintenance for the iddat period and dower, was partially decreed. The appeal filed by the petitioner against the said order and decree was dismissed as not maintainable, vide judgment and decree dated 07.02.2023 passed by the learned District Judge, Toka Tek Singh. 2. Brief facts of the case are that Nikah between the parties was solemnized on 18.03.2022 against Haq Mehr of Rs.100,000/-, recorded as Ghair Mu'ajjal (deferred) in columns No.13 and 14 of the Nikahnama. It is not disputed that the deferred dower remains unpaid. Respondent No.1 instituted the suit alleging, in para-4 of the plaint, that shortly after Nikah, upon her demanding payment of dower, the petitioner began beating her over trivial matters, remained unemployed, resorted to theft and intoxication, demanded that she should bring money from her parents, and used abusive language when she refused; and that within days of the Nikah he beat her and turned her out of the matrimonial home, after which he made no effort for reconciliation, paid no maintenance, and made no enquiry after her. Her pleaded case, in her own words, was as under:- 2 Writ Petition No.20300 of 2023 "یہ کہ ش ادی کے بعد مدعیہ کے آگے مدعا علیہ کا اصل چہرہ سامنے آ گیا جبب مدعیہ نے حق مہر مبلغ ایک روپے کا مطالبہ کیا تو مدعا علیہ نے معمولی معمولی بباتوں پر مدعاا علیہ، مدعیہ کو مارپیٹ کرب ا۔ کوئی کام کاج بھی نہ کرب ا ا رچہ مانگنے پر تشدد کرب اا
ہے بلکہ چوربکاں کرب ا ہے۔ نشہ کرب ا ہے۔ خ ابلکہ مدعیہ کو کہتا ہے کہ اپنے والدین سے رقم ا لے کر آ ؤ انکار پر گھٹ یکاا زببان استعمال کرب ا۔ مدعا علیہ نے ش ادی کے چند دن بعد ہی مدعیہ کو مار پیٹ کرکے اپنے گھر سے نکال دبکا اور مدعیہ اپنے سے لے کر والدین کے ہاں آ گئی اور اس وق آج ی نہ تو مدعا علیہ نے مدعیہ کو آبباد کرنے کی کوشش کی ہے رچہ ب ان و نفقہ ادا کیا ہے اور نہ ہی کوئی خبر گیری کی۔"ا
اور نہ ہی خ ا
The learned trial Court decreed the suit on 01.09.2022 in terms of Section 10(4) of the Family Courts Act, 1964, and awarded 50% of the dower, being the extent to which respondent No.1 had herself confined her claim. 3. Learned counsel for the petitioner contends that sub-sections (5) and (6) of Section 10 of the Family Courts Act, 1964, having been declared repugnant to the Injunctions of Islam vide judgment of the Federal Shariat Court reported as PLD 2022 Federal Shariat Court 25 (Imran Anwar Khan and others vs. Government of Punjab and others), and the matter being sub judice before the Hon’ble Supreme Court, the award of any part of the dower was without lawful basis. 4. In view of the above, the following questions arise for determination in this petition: i) Whether, after the declaration of sub -sections (5) and (6) of Section 10 of the Family Courts Act, 1964 as repugnant to the Injunctions of Islam, the Family Court retains jurisdiction to determine a wife’s entitlement to dower on a case-to-case basis? ii) Whether a decree for dissolution described as "Khula" necessarily entails forfeiture or return of dower irrespective of the cause of dissolution, or whether a distinction exists in law between dissolution founded on the wife’s mere aversion (Khula simpliciter) and dissolution occasioned by the husband’s crue lty or other grounds under law? iii) Whether physical, psychological, emotional, verbal or economic abuse amounts to cruelty sufficient to disentitle the husband from claiming return of dower, in whole or in part? iv) What principles ought to govern the exercise of judicial discretion by Family Courts in determining the question of 3 Writ Petition No.20300 of 2023 dower where dissolution is sought on the ground of cruelty or matrimonial misconduct? v) Whether the learned Family Court erred in awarding fifty percent (50%) of the deferred dower to respondent No.1 on the facts of this case?
Section 10 of the Family Courts Act, 1964 requires the Family Court, after pleadings are filed, to ascertain the real controversy between the parties and attempt reconciliation before proceeding to trial. Where reconciliation fails, sub-section (4) permits the Family Court to frame issues and record evidence. Sub -sections (5) and (6), inserted by the Family Courts (Amendment) Act, 2015 (XI of 2015), provided: “(5) In a suit for dissolution of marriage, if reconciliation fails, the Family Court shall immediately pass a decree for dissolution of marriage and, in case of dissolution of marriage through khula, may direct the wife to surrender up to fifty percent of her deferred dower or up to twenty -five percent of her admitted prompt dower to the husband. (6) Subject to subsection (5), in the decree for dissolution of marriage, the Family Court shall direct the husband to pay whole or part of the outstanding deferred dower to the wife."
Two things follow from the words actually used. First, sub -section (5) speaks only of dissolution “through Khula”; it said nothing about dissolution granted on the ground of cruelty or any other fault of the husband. Second, the sub -section used the word “ may”, not “shall”. Surrender of dower, even in Khula, was left to the Family Court’s discretion, subject to an upper ceiling, and was never automatic. Even under the provision that has since been struck down, the Legislature did not intend dower to be surrendered automatically in every decree of dissolution, and certainly not in one granted for cruelty. 5. This distinction between Khula and dissolution on other grounds is not new. Part I of the Schedule to the Family Courts Act, 1964 assigns to the Family Court suits for “dissolution of marriage, including Khula” — the word “including” itself signaling that Khula is one species of a wider genus. Khula, as recognized in PLD 1967 SC 97 (Khurshid Bibi vs. Muhammad Amin), is the wife’s own right to seek dissolution of her marriage through the Court, even against her husband’s will, where she 4 Writ Petition No.20300 of 2023 satisfies the Court that continuing the marriage within the limits prescribed by Allah has become impossible. In other words, Khula can be granted to a woman without any fault of a husband, as recognized in PLD 1971 SC 192 (Muhammad Siddiq v s. Ghufran Bibi) . The Dissolution of Muslim Marriages Act, 1939, by contrast, entitles a wife to a decree of dissolution upon proof of specific matrimonial wrongs. Section 2(viii) of that Act provides that a wife is entitled to a decree where the husband: "treats her with cruelty, that is to say — (a) habitually assaults her or makes her life miserable by cruelty of conduct even if such conduct does not amount to physical ill-treatment, or (b) associates with women of evil repute or leads an infamous life, or (c) attempts to force her to lead an immoral life, or (d) disposes of her property or prevents her exercising her legal rights over it, or (e) obstructs her in the observance of her religious profession or practice, or (f) if he has more wives than one, does not treat her equitably in accordance with the injunctions of the Quran."
Clause (ii) of the same section entitles her to dissolution where the husband “has neglected or has failed to provide for her maintenance for a period of two years. ” Respondent No.1’s pleaded case i.e. physical beating, being turned out of the house, no maintenance paid thereafter, falls squarely within these words. More importantly, Section 5 of the same Act provides: "Rights to dower not to be affected. — Nothing contained in this Act shall affect any right which a married woman may have under Muslim law to her dower or any part thereof on the dissolution of her marriage."
This could not have been put more plainly. Where a wife obtains dissolution on a ground recognized under Section 2, her right to dower is preserved by the express words of the statute. Sub -sections (5) and (6) of Section 10 of the Family Courts Act, 1964 never purported to touch this provision; they spoke only to Khula, which is a separate and 5 Writ Petition No.20300 of 2023 independent right. The same distinction is rooted in the Quran, and it is this rooting the Federal Shariat Court was applying when it examined sub-sections (5) and (6). The verse governing Khula provides: وَ لََ یَحِلُّ لَكُمْ اَنْ تَاْخُذُوْا مِمَّاۤ اٰتَیْتُمُوْهُنَّ شَیْــٴًـا اِلََّۤ اَنْ یَّخَافَاۤ اَلََّ یُقِیْمَا حُدُوْدَ اللِّه -فَاِنْ خِفْتُمْ اَلََّ یُقِیْمَا حُدُوْدَ اللِّه -فَلََ جُنَاحَ عَلَیْهِمَا فِیْمَا افْتَدَتْ بِه ه - تِلْكَ حُدُوْدُ اللِّ فَلََ تَعْتَدُوْهَا - (البقرة: 229 ) "And it is not lawful for you to take back anything of what you have given them, unless both fear that they will not be able to observe the limits set by Allah. And if you fear that they cannot observe those limits, there is no blame on either of them in w hat she gives up to secure her release. These are the limits set by Allah, so do not transgress them." (Al-Baqarah, 2:229) ر نہیں کہ جو کچھ تم انہیں دے چکے ہو اس میں سے کچھ واپس لو، سوائے اس کے کہ دونوں کو یہ خ دشہ ہو کہ وہ اور تمہارے لیے جائ اہ نہیں کہ عورت اپنی رہائی کے لیے کچھا
اللہ کی مقرر کردہ حدود قائم نہ رکھ سکیں گے۔ اور اگر تمہیں یہ خ دشہ ہو تو دونوں پر کوئی گ دے دے۔ یہ اللہ کی حدیں ہیں، انہیں نہ توڑو۔ا This verse was revealed in the matter of Habiba bint Sahl and her husband Thabit ibn Qais, and classical commentators explain that the dispensation to receive something back from the wife applies where the discord, the fear of transgressing the limits of Allah, arises from the wife’s own conduct. Where the fault lies with the husband, a different verse governs: وَلََ تَعْضُلُوهُنَّ لِتَذْهَبُوا بِبَعْضِ مَا آتَیْتُمُوهُنَّ إِلََّ أَنْ یَأْتِینَ بِفَاحِشَةٍ مُبَیِِّنَةٍ (النساء 19) ... وَإِنْ أَرَدْتُمُ اسْتِبْدَالَ زَوْجٍ مَكَانَ زَوْجٍ وَآتَیْتُمْ إِحْدَاهُنَّ قِنْطَارًا فَلََ تَأْخُذُوا مِنْهُ شَیْئًا أَتَأْخُ ذُونَهُ بُهْتَانًا وَإِثْمًا مُبِینًا (النساء: 20) وَكَیْفَ تَأْخُذُونَهُ وَقَدْ أَفْضَىٰ بَعْضُكُمْ إِلَىٰ بَعْضٍ وَأَخَذْنَ مِنْكُمْ مِیثَاقًا غَلِیظًا (النساء 21) "And do not make things difficult for them, so as to take back part of what you have given them, unless they have committed a clear act of indecency... And if you wish to replace one wife with another, and you have given the former a great amount, do not take back any of it. Would you take it through slander and manifest sin? And how could you take it, when you have already been intimate with one another, and they have taken from you a solemn covenant?" (An-Nisa, 4:19–21) اور انہیں تنگ نہ کرو ب اکہ جو کچھ تم نے انہیں دبکا ہے اس میں سے کچھ واپس لے لو، سوائے اس کے کہ وہ کھلی بے حیائی کا ارتکاب کریں... اور اگر تم ایک بیوی کی جگہ دوسری لاب ا چاہو اور پہلی کو ڈھیروں مال دے چکے ہو، تو اس میں سے کچھ واپس نہ لو۔ کیا تم اسے بہتان اور کھلے ریکب جا چکے ہو اور
اہ کے ذریعے واپس لو گے؟ اور تم اسے کیسے واپس لے سکت ہو جبکہ تم ایک دوسرے کے ق
گ انہوں نے تم سے پختہ عہد لیا ہے؟ The marriage contract is described here as "میثاقاً غلیظاً a solemn, weighty covenant, and the husband is permitted to take back any part 6 Writ Petition No.20300 of 2023 of the dower only where the wife herself is guilty of open misconduct ("فاحشة مبینة Where the fault is his, the Quran gives him no such licence. In PLD 2002 SC 273 (Mukhtar Ahmad vs. Ansa Naheed), the Hon’ble Supreme Court held that the question of return of dower falls to be decided on the facts of each case, separately from the merits of dissolution, and that a wife ’s legal rights cannot be curtailed by implication merely because she has invoked one ground rather than another. The Supreme Court in Ibrahim Khan v s. Mst. Saima Khan has since confirmed this reading of Mukhtar Ahmad , describing the right under the Dissolution of Muslim Marriages Act, 1939 as an independent right, with each ground under Section 2 being separate and sufficient in itself for dissolution. This Court has consistently applied the same principle: in 2014 CLC 1270 (Syed Haroon Sultan Bukhari vs. Syeda Mubarak Fatima), and by the Peshawar High Court in 2012 MLD 1576 (Nasir vs. Rubina), where it was held, in each case, that a wife whose aversion is attributable to her husband ’s maltreatment or default cannot be deprived of her dower merely because the decree passed is described as one of Khula. The Supreme Court, in P L D 2024 Supreme Court 645 (Ibrahim Khan v s. Mst. Saima Khan) , held that Khula and dissolution under the Dissolution of Muslim Marriages Act, 1939 sit in separate legal domains, with separate consequences. Three differences were noted. A woman seeking Khula need not prove any ground; a woman seeking dissolution under Section 2 of that Act must prove one. Where she proves such a ground, Section 5 protects her dower; where she seeks Khula, she gives it up as the price of her release. And procedurally, once reconciliation fails, a decree of Khula follows immediately, without evidence being recorded, while a decree on a ground such as cruelty can only be passed after evidence is recorded under Section 11 of the Family Courts Act, 1964 , though it is not necessary in every case to record evidence if admissible evidence in the shape of any report, document or record is available or admission has been made by the witness . This last point matters. A decree passed at the pre-trial stage, before any evidence is taken, cannot lawfully dispose 7 Writ Petition No.20300 of 2023 of a claim of cruelty. Where a wife has pleaded cruelty and the Family Court proceeds straight to a decree without recording evidence, proper procedure is not followed. 6. It is, therefore, imperative to ascertain what precisely the Federal Shariat Court declared to be repugnant. The Federal Shariat Court did not hold that every wife seeking dissolution through Khula must return her dower. Nor did it hold that every wife sha ll invariably retain the whole of her dower. Equally, the Federal Shariat Court did not hold that the jurisdiction of the Family Court to determine proprietary rights arising from marriage stands extinguished. Rather, the Federal Shariat Court rejected the application of a predetermined statutory formula that was capable of operating without regard to the factual cause of matrimonial breakdown. The judgment repeatedly emphasizes that the obligation to return dower depends upon the reason for dissolution and, more particularly, upon whether the wife herself is solely responsible for seeking separation or whether the husband’s conduct has furnished lawful justification for the dissolution. The following observations made by the Federal Shariat Court leave little room for ambiguity:
"عورت ایک خاص رقم حق مہر کے عوض اپنا نفس حوالہ کرتی ہے اور نکاح کی تنسیخ بکا اس بندھن سے علیحدگی بصورت خ لع کی علت کا تعین اور تیقن ضروری ہے۔ کیونکہ عورت اگر محض نفرت اور ب اپسندیگی کی بنیاد پر خ لع کی طالبہ رہتی ہے تو ایسی صورت میں جو حق مہر وہ وصول کر چکی ہے ا قابب واپسی ہے۔ اس سے زبکادہ لینا صحیح نہیں۔ نبی ب اک صلی اللہ علیہ وسلم رمابکا۔ دوسری صورت مرد کے نشوز کی ہو سکتی ہے۔ ایسی صورت میں نکاح جیسے شرعی معاہدے
نے زبکادہ دینے سے منع ق کے حصار میں آ کر عورت عزت نفس، جان، مال، آئبرو، مقام اور حیثیت سب کا شرعاً و قانوب اًا اتحفظ اور امان ب اتی ہے۔ ان حقوق میں دس اندازی، ان کی خلاف ورزی اور بے احترامی قابب تعزئکر خبرم ہونے کے ساتھ ساتھ طلب خ لع کے لیے راہم کرتی ہے۔ ایسی صورت حال میں شرعاً، قانوب اً، اخلاقاً اور روایتاً حق مہر کی واپسی کا تقاضا بکا واپسی کا حکم
معقول جواز ق درس نہیں بلکہ مطلق مہر بکا اس کے خاص خب رو کی واپسی کا حکم بھی حق خ لع پر حملہ متصور ہو گا۔ کیونکہ ان حالات کے تحت عدال پر لازم ہے کہ وہ تعین کرے کہ کس قدر مال کی واپسی مناسب رہے گی۔ اگر عورت خ لع کا حق محض ب اپسندیگی کی ا بنیاد پر اور شوہ ر کے کسی قصور کے بغیر استعمال کر تی ہے تو پورا حق مہر واپس کرب ا ہو گا ۔"
Read in this light, learned counsel ’s argument does not survive. The Federal Shariat Court did not hold that a wife must always return her dower, nor that she must never return it. It held that the answer depends on which of the two Quranic situations the case falls into: the wife ’s aversion, or the husband’s nashuz. It required the Family Court to make 8 Writ Petition No.20300 of 2023 that determination on the facts, rather than apply a fixed formula. That is precisely what sub -sections (5) and (6) of Section 10 of the Family Courts Act, 1964 had failed to do, and precisely why they were struck down. Their removal restores the Family Court to the position the Quran and Section 5 of the Dissolution of Muslim Marriages Act, 1939 had already placed it in: cruelty, once proved, carries no conseque nce for dower. Unfortunately, much of the subsequent difficulty experienced by the Family Courts appears to have arisen from treating every decree passed after reconciliation fails as if it were an identical category of Khula irrespective of the factual foundation of the claim. Such an approach overlooks the distinction carefully preserved by both Islamic jurisprudence and the Federal Shariat Court itself between a dissolution founded upon unilateral aversion and one occasioned by the husband's own misconduct. Therefore, the Family Court’s jurisdiction to determine a wife’s entitlement to dower on a case -to-case basis has not been taken away. What is gone is the fixed ceiling that once did some of that work for the Family Court. In its place, the Family Court itself must now do the work of deciding each case on its own fact s. Secondly, a decree does not carry the consequences of Khula merely because it calls itself one. The consequence follows only where the wife has, in substance, sought and consciously elected Khula, and not where she has proved a ground under Section 2 of the Dissolution of Muslim Marriages Act, 1939. 7. This brings me to the third question framed above i.e. whether physical, psychological, emotional, verbal or economic abuse amounts to cruelty sufficient to preserve a wife ’s dower. Cruelty, within the meaning of Section 2(viii) of the Dissolution of Muslim Marriages Act, 1939, is not a term confined just to physical blows. The six illustrations set out in that clause are illustrative, not exhaustive. The Legislature never intended th em to mark the outer limit of what a husband ’s conduct may amount to. A husband ’s cruelty may lie as much in humiliation, verbal abuse, false imputations upon his wife ’s character, cold indifference and calculated neglect, as in the raising of a hand. Where the domestic environment itself is made hostile, where a 9 Writ Petition No.20300 of 2023 husband tolerates, or encourages, the ill -treatment of his wife by his own family- that too is cruelty within the clause. The inquiry is not whether the conduct fits a named category; it is whether its cumulative effect upon the particular wife before the Court has made it impossible for her to go on living with dignity and safety in her own home. Physical injury is not a precondition, and criminal-style proof has no place here. A suit under the Dissolution of Muslim Marriages Act, 1939 remains a civil disp ute, to be decided, like any other, on the balance of probabilities. A wife is not required to produce a medico -legal certificate for every slap, or a first information report for every episode of abuse, before her word can be acted upon. Her own testimony, tested in cross -examination and weighed against the surrounding circumstances, the conduct of the husband ’s witnesses or the absence of any, and the pattern and timing of events, is evidence like any other. It is for the Family Court to look at all of this and decide whose account is more probably true. A Family Court that sets aside a wife ’s sworn testimony for want of documentary corroboration has misapplied the standard of proof. Reference in this regard may be made to the judgment of the Hon'ble Supreme Court in PLD 2026 Supreme Court 91 (Dr. Seema Hanif Khan v s. Waqas Khan and others) , authored by Mrs. Justice Ayesha A. Malik, where these principles were authoritatively restated and applied. This also answers, in part, the second question framed above. Where cruelty is established to this standard, the decree of dissolution does not, in law, carry the consequences of Khula. The mere fact that a wife ’s suit is disposed of once reconciliation fails, or that the word “Khula” finds its way into the plaint or the decree sheet out of habit or convenience, does not convert a suit founded on cruelty into one founded on aversion. The filing of a suit for dissolution is not, without more, a request for Khula, and a Family Court has no authority to treat it as one unless her informed consent to Khula, understood as such, appears on the record. To proceed otherwise is to take from her a statutory right she never gave up. It was stated in PLD 1971 SC 192 (Muhammad Siddiq vs. Ghufran Bibi), where the Supreme Court held that a Court could not decree a 10 Writ Petition No.20300 of 2023 suit on the footing of Khula where Khula had not been the wife ’s prayer. It was restated with greater force in PLD 2024 SC 645 (Ibrahim Khan vs. Mst. Saima Khan) , where the Hon’ble Supreme Court held that the right to Khula belongs to the wife alone, that she must place her offer to waive dower before the Court in clear and unambiguous terms, and that a Court cannot grant Khula of its own motion where it has not been sought. 8. The danger of assuming aversion too readily was illustrated in C.P.L.A. No. 3767 of 2025 (Mst. Naila Javed vs. Nasir Khan), where a wife who had pleaded cruelty, non -payment of dower and her husband’s second marriage was found below to have shown mere unwillingness to live with him, and was granted Khula on that footing, losing her outstanding dower. The Hon’ble Supreme Court found the cross-examination conducted below improper, testing nothing but her character through irrelevant and prejudicial questions asked to embarrass her, and dissolved the marriage on the ground of cruelty instead, with her dower restored. An appearance of aversion produced by an unfair trial is not evidence that a case is simple Khula; it is evidence that the case was not properly tried. It would be an incomplete account of this question to leave…
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