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IN THE COURT OF JUDGE.

CASE NO. /20

IN THE MATTER OF
...PETITIONER
VERSUS
...RESPONDENT

PETITION UNDER SECTION 25 OF THE GUARDIAN AND WARDS ACT 1890 FOR THE
CUSTODY OF MINOR SON AGED ABOUT YEARS AND DAUGHTER
AGED ABOUTYEARS TO FATHER, THE PETITIONER

MOST RESPECTFULLY SHOWETH:

1. That the marriage of the petitioner was solemnized with the respondent on
at according to Hindu rites and ceremony in
presence of friends relative and members of the society. The marriage was registered with
on Copy of the Marriage Registration Certificate is annexed
herewith as Annexure - A.

2. That after 6 months of the marriage the respondent started inflicting cruelties mentally
and physically upon the petitioner and she started abusing, misbehaving, insulting
maltreating to the petitioner. The petitioner tried to mend the ways of the respondent but
the behavior and attitude of the respondent remained indifferent and adamant towards the
petitioner.

3, That in many occasions the respondent left the matrimonial home without the consent
and intimation to the petitioner. The petitioner made efforts to bring her back but the
respondent flatly refused to join the company of the petitioner. So the filed a petition under
section 9 of the Hindu marriage on in the court of Civil Judge, in which is
pending for adjudication.

4. That from the said legal wedlock of the petitioner and respondent one boy namely master
aged about years and one girl namely Baby aged about
Years born.

5. That the respondent along with two children left her matrimonial home on
after quarreling with the petitioner. At present both the Children are in the
custody of the respondent.

6. That the petitioner is working as and has regular income. The

petitioner is interested to keep the minor children.

7. That the petitioner hereby apply for the custody of his minor chlldren being the father,
next friend and natural guardian on the following grounds:
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i.
That the respondent mostly remains out of her house due to which the care and of the
minors is being effected badly.

That the behaviour of the respondent and her family members are very rude, arrogant
ii.
towards the minor children.

iii, That the respondent is not taking care for the proper upbringing of the minor children
namely and

iv. That good schools are not available at the place where the Respondent resided and she
is unable to provide good educational facilities and social culture to
the children.
v. That the petitioner is educated person and he is presently posted as
and
he can give the proper education to the minor children.

vi. That the petitioner is keenly interested to support, welfare, provide good health, extreme
good education and proper upbringing of minor children.

vii. That the petitioner is able to look after the minor in better way with full love and
affection. The petitioner is only persons being the father of the minor who can make the
bright future of minor children.

viii. That after completing his duty the petitioner will give sufficient time to minor children
for their development and growth, Besides this the parents of the petitioner willalso take
proper care of minor in the absence of the petitioner

x. That the petitioner is fully committed and able to give a good atmosphere to the minor
children.

x. That now the age of minor children namely and is more than years
and years and as per the law the father, petitioner is entitled to take custody of minor
children.

8. That the respondent has neither been appointed nor has been declared as the lawful
guardian of minor children namely and by any court of law so
far. The respondent has also not been lawfully entrusted the custody of minor children by
any order of the court.

9. That the petitioner requested the respondent number of times to handover the custody of
minor children namely and to him but every time the respondent avoided
to the legitimate requests of the petitioner on one pretext or the other and finally on
the respondent flatly refused to handover the custody of the minor daughter
and son. Hence this petition.

10. That the cause of action to file the present petition arose on each and every dates when
the petitioner requested the respondent to handover the custody of minor children namely
and The cause of action finally arose on when the
respondent finally refused to handover the custody of minor children to the petitioner.

11. That both the parties are Hindus by religion.

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12. That no other petition on the same subject matter has previously been filed, pending or
has been decided by any court of competed jurisdiction.

13. That the petitioner and the respondent lastly resided at the children were also
born at the respondent left the house of petitioner along with the minor
children from and the entire cause of action for filing the present petition arose
within the territorial jurisdiction of this Hon'ble court hence this Hon'ble court has the
jurisdiction to entertain, try and decide the present petition.

14. That a fixed court fee has been paid on the present petition.

PRAYERS
In view of the above it is most respectfully prayed that his Hon'ble Court may graciously be
please to:

i) Accept the petition of the petitioner and the respondent may kindly be directed to
handover the custody of minor children namely aged about years and
minor aged about years to the petitioner, father, permanently, a decree to
this effect may kindly be passed infavour of the petitioner and against the respondent;
ii) Grant any other relief which this Hon'ble court deems fit and proper in favour of the
petitioner and against the respondent.

PETITIONER

THROUGH

Advocate
Place:

Date:

VERIFICATION:
Verified at Delhi on this Day of the. 20 that the contents of paragraph no. 1
to are true to the best of my knowledge and based on the records of the Petitioner and
paragraph no. to are true and correct based on the information received
and believe to be true and correct. The last paragraph is prayer to this Hon'ble Court.
PETITIONER
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IN THE COURT OF JUDGE.

CASE NO. J20

IN THE MATTER OF
...PETITIONER
VERSUS
..RESPONDENT

AFFIDAVIT

S/o R/O do hereby

solemnly affirm and declare as under:

1. That the deponent is the father of minor children namely aged about
years and minor aged about years.

2. That the deponent has filed above noted petition under section 25 of the Guardians &
Wards Act, 1890, the content of which may be read as part and parcel of this affidavit for
the sake of brevity and avoidance of repetition.
3. That the contents of above petition have been read over to me by my counsel whlch are
true to best of my knowledge and belief.

Deponent
VERIFICATION:
Verified at Delhi on this Day of the 20
that the contents of paragraph no. 1
to are true to the best of my knowledge and based on the records of the Petitioner and
paragraph no. to are true and correct based on the information recelved
and believe to be true and correct. The last paragraph is prayer to this Hon'ble Court.

Deponent