How to use this template: Fill in every bracketed placeholder ([...]) with your case details. This suit is filed before the Family Court when an earlier maintenance decree (or interim maintenance order) has become inadequate because of changed circumstances — rising prices, a child's school fees, or an increase in the husband/father's income. Get the plaint verified before the Oath Commissioner, attach copies of the earlier decree and proof of the changed circumstances (school fee receipts, salary evidence, medical bills), and file it in the Family Court that passed the earlier decree or where the plaintiff resides. Court fee is nominal on family suits.

Intro

A maintenance decree is not frozen in time. Under the West Pakistan Family Courts Act, 1964 (which governs family suits across Pakistan), a wife is entitled to maintenance during marriage and during the iddat period, and a father is bound to maintain his minor children according to his means. When a court fixes maintenance at, say, Rs 20,000 a month in 2022, and by 2026 school fees alone have doubled while the husband's salary has risen from Rs 60,000 to Rs 150,000, the old figure no longer does the job the law intended.

Pakistani family law recognises that maintenance must be reviewed when circumstances change. A suit for enhancement of maintenance asks the Family Court to re-examine the decree in light of (a) the increased needs of the wife/children (inflation, education, health), and (b) the increased financial capacity of the husband/father. The plaintiff does not need to prove that the earlier decree was wrong — only that circumstances have materially changed since it was passed. Courts routinely enhance maintenance where the evidence shows the family's needs have grown and the earning spouse can afford more.

What counts as "changed circumstances"? The strongest grounds are concrete and documented: the husband/father's promotion, new job, business growth, or property acquisition; the children's admission to a new school with higher fees; medical needs; or simply the passage of several years during which the cost of living has risen sharply. Vague claims ("prices have gone up") help less than receipts, fee vouchers, and salary evidence.

This is different from an interim-maintenance application (Section 17-A), which secures maintenance while a case is pending. A suit for enhancement re-opens a final decree. If the earlier case is still pending, ask for enhancement within that case instead.

IN THE COURT OF FAMILY JUDGE, [District]

Suit No. [___] of [Year]

[Name of Plaintiff — Wife / Mother on behalf of minor children], w/o, d/o [Father's Name], [CNIC No.], r/o [Full Address] ...Plaintiff

VERSUS

[Name of Defendant — Husband/Father], s/o [Father's Name], [CNIC No.], r/o [Full Address] ...Defendant

SUIT FOR ENHANCEMENT OF MAINTENANCE

Respectfully submitted:

  1. That the plaintiff is the [legally wedded wife / mother and next friend of the minor(s), namely [Child 1, age ___], [Child 2, age ___]] of the defendant. The marriage between the parties was solemnised on [DD/MM/YYYY] at [Place], and the Nikahnama is registered at Union Council [___], [District].
  1. That in [Suit No. [___] of [Year]], this Hon'ble Court / the Family Court, [District], passed a decree/order dated [DD/MM/YYYY] fixing maintenance at Rs [___] per month [for the plaintiff wife / for the minor child(ren)]. A certified copy of the said decree/order is attached as Annexure-A.

3. That since the passing of the said decree, the circumstances of the parties have materially changed, rendering the decreed maintenance grossly inadequate, as detailed below [select and expand the applicable grounds; delete the rest]: (a) The defendant's income and financial capacity have substantially increased. At the time of the earlier decree, the defendant was earning approximately Rs [___] per month as [job/business]. He has since [been promoted to [Designation] with a salary of Rs [___] per month / started a business at [Address] earning approximately Rs [___] per month / acquired [property/vehicle — describe], evidencing increased means]. [Attach salary slip, bank statement, or other evidence as Annexure-B.] (b) The needs of the minor child(ren) have increased. [Child's name] was admitted to [School/College Name] in [Year], where the monthly fee is Rs [___] (fee vouchers attached as Annexure-C). [He/She] requires Rs [___] per month for transport, books, and uniforms. [Child's name] suffers from [medical condition], requiring treatment costing Rs [___] per month (medical record attached as Annexure-D). (c) The cost of living has risen sharply since [Year of earlier decree]. House rent for the plaintiff's residence has increased from Rs [___] to Rs [___] per month (rent receipts attached), and household expenses can no longer be met within the decreed amount. (d) [For the wife's own maintenance:] The plaintiff has no independent source of income and is wholly dependent on the defendant, who is legally bound to maintain her according to his means and her status.

  1. That the plaintiff approached the defendant on [Date(s)] and requested an increase in maintenance commensurate with his increased means, but the defendant [refused / ignored the request / offered an inadequate increase of Rs [___]], leaving the plaintiff with no option but to approach this Hon'ble Court.
  1. That the cause of action accrued to the plaintiff [on the dates the defendant's income increased / when the child was admitted to the new school / continuously as the decreed amount became inadequate], and it continues to accrue each month that inadequate maintenance is paid.
  1. That the plaintiff resides at [Address] within the jurisdiction of this Hon'ble Court, and the earlier decree was also passed by [this Hon'ble Court / the Family Court, [District]], hence this Hon'ble Court has jurisdiction to entertain the present suit.
  1. That the valuation of the suit for purposes of court fee and jurisdiction is Rs [___] [annual maintenance claimed], and the requisite court fee of Rs [___] has been affixed.
  1. That no other suit for the same relief is pending between the parties in any court, and the plaintiff has concealed no material fact from this Hon'ble Court.

PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to:

(a) Enhance the maintenance payable by the defendant to Rs [___] per month [for the plaintiff wife / for each minor child], effective from the date of institution of this suit [or from [Date]]; (b) Direct the defendant to pay arrears of the enhanced amount from the due date; (c) Grant any other relief deemed just and proper in the circumstances; and (d) Award costs of this suit in favour of the plaintiff.

Plaintiff Through: [Name], Advocate [Chamber Address, Phone]

VERIFICATION

Verified on oath at [Place] on this [Date] day of [Month], [Year], that the contents of the above plaint are true and correct to the best of my knowledge and belief, and nothing has been concealed therefrom.

Plaintiff

LIST OF DOCUMENTS / ANNEXURES

  • Annexure-A: Certified copy of earlier maintenance decree/order dated [DD/MM/YYYY]
  • Annexure-B: Proof of defendant's increased income [salary slip / bank statement / business record]
  • Annexure-C: School fee vouchers / admission receipts of the minor(s)
  • Annexure-D: Medical records and bills (if applicable)
  • Annexure-E: Rent receipts / household expense record
  • Annexure-F: Copy of Nikahnama; copies of CNICs of the parties; B-Forms of the minors

Frequently Asked Questions

Q: Can maintenance be increased if the husband's income hasn't changed but prices have gone up? A: A: Yes — inflation and the passage of time are themselves recognised grounds. Courts accept that a figure fixed five years ago cannot meet today's needs, particularly for growing children whose school fees rise every year. But your case is much stronger if you can also show the husband/father's capacity has grown; a bare inflation plea against a genuinely low-income earner may yield only a modest enhancement.

Q: Is there any time limit for filing an enhancement suit? A: A: There is no fixed limitation period running from the original decree in the way a 30-day appeal does — the cause of action is the material change in circumstances, and it is treated as continuing. But do not sleep on your rights: file when the change happens (promotion, school admission, fee hike), because courts enhance maintenance from the date of institution of the suit (sometimes from the date of application), not retrospectively from when the change occurred.

Q: Can the husband also ask for maintenance to be reduced? A: A: Yes. The same principle works in reverse: if the husband/father's income has genuinely fallen (job loss, business failure, illness), he can file for reduction of maintenance. The court weighs both sides' evidence. This is why documented proof — not just assertions — decides these cases.

Q: What evidence matters most in an enhancement suit? A: A: Three kinds: (1) proof of the other side's increased means — salary slips, bank statements, tax returns, business or property records; (2) proof of increased needs — school fee vouchers, medical bills, rent receipts; (3) the earlier decree itself, to show the baseline. Family Courts can also summon the husband's employer or bank records where he conceals income — a common issue in these suits.

Q: Does the wife lose the right to enhancement after khula or divorce? A: A: A divorced wife's maintenance is limited to the iddat period (and any unpaid dower), so enhancement after divorce is generally about the children's maintenance, which continues regardless of the parents' marital status. The father's obligation to maintain his minor children survives divorce and khula — and an enhancement suit for the children can be filed by the mother as their next friend.

The Bottom Line

This article provides general legal information for readers in Pakistan and is not legal advice. For advice about your own situation, consult a qualified advocate.