Family Law · Legal issue collection

Dower and Khula in Pakistan

Research disputes about nikahnama entries, property dower, return of dower and the distinction between khula and other grounds of dissolution. The linked decisions address different claims and should be compared with the marriage document and relief sought.

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Supreme Court of Pakistan, Appellate Jurisdiction · News Analysis

Supreme Court: Nikahnama Dower Columns Must Be Read Together; Property Mahr Cannot Be Defeated

Mst. Farwa Noreen v Hassan Ali Agha and others (with connected cases) · C.P.L.A. Nos. 372-P and 373-P of 2019 with connected petitions and appeals · Approved for reporting; reported citation not stated in the supplied judgment

A four-member Supreme Court bench held that Nikahnama entries are primary but rebuttable evidence, Columns 13 to 16 must be read together, and an untransferable dower property may be replaced by its value.

Supreme Court of Pakistan · News Analysis

Shiqaq Divorce in Pakistan: Supreme Court Distinguishes Khula and Preserves Dower Rights

Mst. Zainab Bibi v Muhammad Waseem and others; Mst. Iram Naz Begum v Fazal Khaliq and others · CPLA No. 57 of 2025 and CPLA No. 1350 of 2025 · Approved for reporting; reporter citation not stated in the supplied copy

A five-judge Supreme Court Bench sustained dissolution for shiqaq, rejected khula without the wives’ voluntary election and removed dower-surrender orders based solely on khula.

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More relevant judgments and articles

Lahore High Court, Bahawalpur Bench (Pakistan) · News Analysis

Lahore High Court: Khula Decree Is Not Appealable, but Dower-Return Liability Is

Farhan Ahmed Bhatti v Additional District Judge and 2 others · Writ Petition No. 6742 of 2024 · Approved for reporting; reported citation not stated in the supplied judgment

The Lahore High Court held that a Khula decree attains finality, but an appeal remains competent on the wife's civil liability to return dower or other marriage benefits.

Supreme Court of Pakistan, Appellate Jurisdiction · Judgment Commentary

Supreme Court: Wife Cannot Retain Dower After Khula if Cruelty Is Not Proved

Mst. Wajiha Rasheed v Adeel Akhter and others · C.P.L.A. Nos. 2555 and 2556 of 2022 · 2025 SCP 316

In Wajiha Rasheed v Adeel Akhter, the Supreme Court held that a later dissolution decree requiring restoration of dower could make an earlier decree for dower property unserviceable where cruelty was not proved.