IN THE HON’BLE COURT OF PRINCIPAL JUDGE,
FAMILY COURT, GHAZIABAD COURT, UTTAR
                  PRADESH
IN THE MATTER OF:
SANDEEP RUNGTA                             …PETITIONER
                          VERSUS
SWATI MITTAL                              …RESPONDENT
PETITION ON BEHALF OF PETITIONER NAMELY,
SANDEEP RUNGTA UNDER SECTION __ OF THE ____
FOR GRANT OF CUSTODY OF THE PETITIONER’S
CHILD.
RESPECTFULLY SHOWETH:
  1. That the petitioner got married with the Respondent
    on _____ and out of the said wedlock ____ sons
    namely ____aged about ____years was born.
  2. That on ____ respondent left her matrimonial house
    alongwith the minor son to her parental house and
    since then the respondent alongwith the minor child
    is living at her parental house.
  3. Then after a petition U/s ____ C.P.C. was filed by
    the respondent herself and on behalf of both the
    minor children and she is getting maintenance for
    herself   and   for   the   minor   children   from   the
     applicant   /petitioner.   However   the   respondent
     alongwith both the minor children came to the
     house of the petitioner on ____ and started living
     with the petitioner. On ____ both the children got
     admission for their education in ____ and the
     petitioner was providing all the facilities to the
     respondent and both the children of their livelihood,
     education etc. but after some the respondent again
     left her matrimonial house in the month of ____.
     Inspite of that the respondent charged the amount
     of maintenance of herself and for both the children
     from the petitioner and she is still getting the
     maintenance         allowances         from        the
     petitioner/applicant.
4- That the atmosphere of family of the petitioner is
better than the family of the respondent and the
petitioner has good reputation in the society. It is
pertinent note herein the parents of the respondent have
recently been to the judicial custody ina case with FIR
No. ____ Under section ___ registred at P.S. ____________.
The petitioner is fully competent person who can provide
quality education, can properly take care and look after
the child and manage to provide good atmosphere to the
child.
That in these circumstances the custody of the child is
liable to be given to the petitioner who is the natural
guardian, next friend and father of the minor child.
PRAYER
It is therefore, prayed that the application of the
applicant/petitioner may kindly be accepted and the
respondent may kindly be directed to handover both the
minors children namely ____ to the applicant /petitioner
in the interest of justice.
Dated : ____                                                                                  
APPLICANT/PETITIONER
____S/o ____R/o ____