Petition for Protection For Court Marriage Couples (Specimen-Draft)

Draft: Constitutional Petition for Protection (Karachi)

In the High Court of Sindh, at Karachi

Constitutional Petition No. ______ of 2026

1. [Groom’s Name] S/o [Father’s Name]
2. [Bride’s Name] W/o [Groom’s Name] Both Residents of: [Current Address in Karachi] … PETITIONERS

VERSUS

1. Province of Sindh, through the Secretary Home Department.
2. The Inspector General of Police, Sindh.
3. The SHO, Police Station [Relevant Area, e.g., Defence/Gulshan].
4. [Bride’s Father/Brother Name] (Private Respondent). … RESPONDENTS

Subject: Petition under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973.

The Petitioners Humbly State as Under:

1. Legal Age: That both Petitioners are sui-juris (adults), aged above 18 years, and are legally competent to enter into a marriage contract under the Sindh Child Marriage Restraint Act.
2. Solemnization: That on [Date], the Petitioners solemnized their marriage of their own free will and without any coercion at [Location/Office], Karachi, in the presence of witnesses. (Copy of Nikah Nama and NADRA Certificate attached as Annexure A & B).
3. Harassment: That Respondent No. 4 (the family) is unhappy with the marriage and is continuously extending life threats to the Petitioners. They are misusing their influence to pressure Respondent No. 3 (the SHO) to register a false FIR under Section 365-B PPC (Kidnapping).
4. Violation of Rights: That the actions of the private respondents violate Article 9 (Security of Person) and Article 35 (Protection of Family) of the Constitution.

Prayer: It is, therefore, most humbly prayed that this Honourable Court may:

• Direct Respondents No. 1 to 3 to provide effective legal protection to the lives and liberty of the Petitioners.
• Restrain Respondent No. 3 from registering any FIR or taking any adverse action against Petitioner No. 1 at the behest of the girl’s family.
• Direct the police not to harass the couple in their lawful place of residence.

Karachi
DATED: PETITIONERS

1……………………………………………

2……………………………………………

Next Steps for Protection

• The Affidavit: Petitioner No. 2 (the bride) must sign a “Free Will Affidavit” before an Oath Commissioner in Karachi, stating she was not kidnapped.
• Statement under Section 164: If a police case is already initiated, the bride should record her statement before a Magistrate to clarify her voluntary marriage.