Temporary custody of a child application format Under Section 12 of Guardian and Wards Act

 

Temporary Custody of minor application format 

In the name of ALLAH, the most beneficent, the most merciful

 

IN THE COURT OF SENIOR CIVIL JUDGE/ GUARDIAN JUDGE  RAWALPINDI

 

Rukhsana Kausar   Versus     Farhan Jameel

GUARDIAN PETITION U/S 25 OF GUARDIAN AND WARD ACT 1890 FOR THE  CUSTODY OF  MINOR KAMRAN SOHAIL D.O.B 23-09-2016)

 

 

APPLICATION U/S 12 OF GUARDIAN AND WARD ACT 1890

 

Respectfully Sheweth:

 

 

 

1.   That the petitioner has filed Petition under Section 25 of Guardian and Wards Act, in this Honourable Court, the contents whereof may kindly be read as integral part of instant application. 

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2.   That the applicant has a good prima-facie case and hopes to be succeed in future.

 

3.   That the Balance of convenience is also lies in favour of the applicant.

 

4.   That the instant application is not accepted and interim/  temporary custody of minor is not handed over, then the applicant as well as minor would likely to suffer an irreparable loss.

 

 

PRAYER:

 

 

Under the above mentioned circumstances it is respectfully prayed that the temporary custody of the minor Kamran Sohail (Date of Birth 23-09-2016) may kindly be handed over for his welfare, upbringing, education and bright future till the final disposal of the main petition.

 

Applicant

 

Through

Counsel

Advocate High Court

IN THE COURT OF SENIOR CIVIL JUDGE/ GUARDIAN JUDGE  RAWALPINDI

 

Rukhsana Kausar Malik Khan       Versus     Farhan Jameel

 

GUARDIAN PETITION U/S 25 OF GUARDIAN AND WARD ACT 1890 FOR THE  CUSTODY OF  MINOR KAMRAN SOHAIL D.O.B 23-09-2016)

 

 

PETITION U/S 12 OF GUARDIAN AND WARD ACT 1890

 

AFFIDAVIT

 

I, Rukhsana Kausar Malik Khan wife Farhan Jameel resident of House NO. 445, Street No. 2, DHA, Phase 3, Rawalpindi, do hereby declare as under:

 

That the contents of the accompanying petition are true and correct to the best of my knowledge and belief and nothing has been concealed there from.

                                                       

                                                                              Deponent

                                       

Verified at Rawalpindi on this ___day of __________, that the contents of the above said affidavit are true and correct.

 

                                                                              Deponent

 

 

 

Download application under section 12 of Guardian and Wards Act