IN THE COURT OF PRINCIPAL
JUDGE, FAMILY COURTS, ---------------------
Guardianship
Petition No._______ of 20--
In the matter
of:
---------- ...Petition
Versus
---------- ...Respondent
APPLICATION U/S. 12 R/W. SECTION 25 OF THE GUARDIANS & WARDS ACT, 1890 FOR INTERIM DIRECTIONS ON BEHALF OF APPLICANT/ PETITIONER
Most respectfully submitted :-
1. That the applicant/ Petitioner has filed the accompanying petition u/s. 7/8/25 Guardians and Wards Act R/w. Section 4 & 6 of Hindu Minority and Guardianship Act.
2. That the applicant/ Petitioner is biological ---- of the minor and has been residing with her minor son separately from the respondent since-----------.
3. That for all purposes, the minor son has been in care and custody of the petitioner ever since he was born. The respondent has intentionally abdicated all his duties and responsibilities towards the son and has shown total apathy towards him. It is the petitioner alone who has brought him up.
4. It is submitted that the respondent is not forthcoming for the welfare of the child and has never even bothered to visit him once call to enquire about him and his well-being, and it is the petitioner who is single-handedly, bringing up the minor child on her own and practically, the petitioner herself is acting as the guardian of the child.
5. That, however, in the facts and circumstances of the case the petitioner is not having any document to show her legal guardianship. The respondent has shown total apathy towards the child and the petitioner.
6. That the welfare of the child requires that interim orders may be passed so---------------.
7. That no prejudice is going to be caused to the respondent. Further, it is well settled position of law that in such matters, it is the welfare of the child which is to be given paramount importance.
8. The balance of convenience also lies in favour of the petitioner and an irreparable loss shall be caused to the child in case, interim orders are not passed.
PRAYER
In view of
above, it is respectfully prayed that this Hon’ble Court, may, by way of an ex
parte ad interim order, kindly be pleased to:-
(a) Pass appropriate interim order or directions to the
effect that the petitioner is entitled to act as lawful guardian of the minor
child ------ till the pendency of the present petition.
(b) Pass any other order/ relief as this Hon’ble Court may
deem just and proper in the facts and circumstances of the present case.
APPLICANT/ PETITIONER
Delhi
Dated:- Through
Advocate
IN THE COURT OF PRINCIPAL
JUDGE, FAMILY COURTS, -----------------------
Guardianship
Petition No._______ of 20--
In the matter
of:
---------- ...Petition
Versus
----------
...Respondent
AFFIDAVIT
I, -----------D/o ----------R/o----------, aged about --- years do hereby solemnly affirm and declare as
under: -
1.
That I am the
Petitioner/applicant in the above-mentioned case and is fully aware about the
facts and circumstances of the present case.
2.
That the
accompanying application U/s 12 R/w Section 25 of the Guardians & Wards
Act, 1890 for temporary custody and meeting rights has been drafted by my counsel
on my instructions and the contents of the same are true and correct.
3.
That the
contents of my accompanying application may kindly be read as part and parcel
of the present affidavit as the contents of the same are not being repeated
herein for the sake of brevity.
DEPONENT
VERIFICATION:-
Verified
at Delhi on this __ day of--------, that the contents of my above affidavit are
true and correct and nothing material has been concealed therefrom.
DEPONENT
