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| Guardian Petition format |
In the name of ALLAH, the most beneficent, the most
merciful
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IN THE COURT OF SENIOR
CIVIL JUDGE/
Nasira Parveen Gujar
Khan wife of Arshad Khan resident of House No. 122, Street No. ,2,
…Petitioner
Versus
Arshad Khan Raja Malik son of Muhammad Aslam
Pervez R/O House No. 1, Street No. 4, Mohallah Shah Chan Chiragh, Rawalpindi
Respondents
PETITION
UNDER SECTION 25 OF THE GUARDIAN AND WARDS ACT 1890 FOR THE CUS
Respectfully Sheweth:
1.
That the marriage ceremony
of the petitioner was solemnized with respondent on
2.
That after the
marriage, petitioner started residing with respondent and performed her
matrimonial obligations. Out of this wedlock, 2 kids (1) Muhammad Ayan age
about 13 years, (2) Muhammad Ali aged about 08 years were born who are alive
and one of them namely Muhammad Ali is under the custody of respondent.
3.
That after the
marriage, differences were cropped-up between the parties, and since August 2018
both the parties are residing separately.
4.
That the petitioner
seeks custody of minor Muhammad Ali on the following grounds:-
GROUNDS
a.
That the respondent is
not a man of good character and under the above mentioned circumstances, living
of minor Muhammad Ali with respondent would not be good in any way for the minor.
b.
That currently the minor
is studying in a school “Ahmed Public School” situated in backward area of Shah
Chan Chiragh, Rawalpindi and the educational standard of above mentioned school
is not of so much high quality therefore, the petitioner wants his son Muhammad Ali to be admitted in Army Public
School for his better education and bright future.
c.
That the petitioner financially
sound person, serving her duties at NADRA as Assistant Director, deriving handsome salary, therefore she can provide
every necessity of life to the minor.
.
d.
That the minor cannot
be brought up properly without his real
mother.
e.
That the act of the
respondent is totally improper and only to deprive the petitioner from her real
son.
f.
That the petitioner
being real mother of the minor is entitled for the custody of the minor.
g.
That welfare of the
minor lies with the petitioner.
h.
That the petitioner is
in a better position to lookafter, bring up and educate the minor.
5.
That the minor has not
been handed over to the petitioner till today despite of the repeated efforts/
requests made by the petitioner, hence this Guardian Petition.
6.
That the cause of
action accrued to the petitioner against the respondent lastly few days ago, when
respondent refused to handover the custody of minor, which is continuing day by
day.
7.
That the minor is
under the custody of respondent, who is living in
8.
That prescribed court
fee has been affixed.
PRAYER:
In the circumstances, it is
humbly prayed that the custody of minor son namely Muhammad Ali aged
about 08 years may kindly be handed over to the petitioner for his welfare,
upbringing, best education and bright future.
Any other relief, which this
Honourable Court deems fit and proper may also be granted to the petitioner.
Petitioner
Through
Counsel
Advocate High Court
VERIFICATION:
Verified on oath at
Petitioner
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| Petition under section 25 of Guardian and Wards Act format |