PETITION FOR APPOINTMENT OF GUARDIAN OF PERSON OF MINOR AND OBTAINING GUARDIANSHIP CERTIFICATE
درخواست برائے حصولِ سرٹیفیکیٹ گارڈین
(English & Urdu)
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BEFORE HONOURABLE GUARDIAN JUDGE, LAHORE.
GUARDIAN PETITION NO:____________________/2013
__________, DAUGHTER OF ______, RESIDENT OF_____, LAHORE.
……..Petitioner
V E R S U S
1. ______, SON OF ______, RESIDENT OF ____, LAHORE.
2. PUBLIC AT LARGE
……..Respondents
PETITION UNDER SECTION 7 & 12 OF GUARDIAN & WARDS ACT, 1890 FOR APPOINTMENT OF THE PETITIONER FOR GUARDIAN OF THE PERSON of “_____”, MINOR, AND GRANTING PERMANENT CUSTODY OF HER TO THE PETITIONER.
Respectfully Sheweth:
1. That the addresses of the parties have been given above correctly for the purpose of issuance of summons by this Honourable Court from time to time.
2. That through the instant petition, the petitioner humbly seeks indulgence of this Honourable Court for her appointment as Guardian of the person of the Minor namely, _____ and for grant of permanent custody of the minor to the petitioner, keeping in view welfare of the minor.
3. That succinctly stated facts giving rise to the filing of instant petition are that the petitioner and Respondent No. 1 were married to each other according to Muslim rites and rituals on _____. Out of wedlock of the parties, ______ (Minor) was born on _____.
4. That for a couple of months after marriage, the relations between the parties remained cordial, but soon thereafter, Respondent No.1 started mis-behaving with the petitioner and it went up to beating the petitioner on petty matters without any reason. He started ridiculing and misbehaving with the petitioner and her family. Even he did not hesitate to abuse her and to torture her physically without any rhyme or reason. Parents of the petitioner also spent huge amount for establishing business of Respondent No.1, however, the marriage proved to be a farce.
5. That in aforementioned circumstances, the petitioner was constrained to file a suit for dissolution of marriage and recovery of dowry & maintenance allowance before Learned Family Judge, Lahore; same was decreed vide judgment & decree dated _____. However, Respondent No.1 has not paid even a single penny as maintenance allowance of the minor. Divorce certificate dated ____ has been issued to the petitioner.
6. That Respondent No.1 has totally neglected the minor and welfare of the minor lies with the petitioner. The particulars of the minor are as following:
a. Name of Minor ______
b. Sex _____
c. Date of Birth ____
d. Religion ____
d. Ordinary residence ________, Lahore.
7. That the petitioner is a ____ years old graduate of _______(University etc) and permanent resident of _____, Lahore. Custody of the Minor has remained with the petitioner throughout till now.
8. That the names and addresses of the near relatives of the minor has been given herein below:
a. The petitioner herself
b. Respondent No.1
c. Maternal Grand Parents of the minor namely ______ & Mst. _____ wife of ______, both residents of ______, Lahore.
9. That according to the best knowledge and belief of the petitioner, neither guardian of the person of the minor has been appointed nor has any application for such appointment been filed prior to the instant petition.
10. That there is no substitute of lap of mother and lap of mother is “God’s own cradle” and Respondent No.1 has totally neglected his obligations towards the minor, therefore, for larger interest of justice & welfare of the minor ______ it is necessary that the petitioner may be appointed as her Guardian to look after her and to manage her affairs as guardian in accordance with law.
11. That the cause of action has arisen in favour of the petitioner and against Respondents from the date of effectives of divorce i.e. ______ and same still continues.
12. That the cause of action has arisen at Lahore, therefore, this Honourable Court has got jurisdiction to adjudicate upon the matter.
13. That requisite court fee has been affixed at the instant petition.
P R A Y E R
In aforementioned circumstances, it is humbly prayed from this Honourable Court that instant petition may kindly be accepted and the petitioner may be appointed as Guardian of the person of the Minor ______; furthermore, permanent custody of the minor may be granted to the petitioner.
Any other relief which this Honourable Court deem fit and appropriate and which has not been prayed inadvertently may graciously be granted.
PETITIONER
THROUGH
A. B. C
Advocate High Court
VERIFICATION:
Verified on Oath at Lahore on this ____ day of April, 2013 that the contents of Paras No. 1 to 10 are correct to the best of my knowledge and those of paras No. 11 to 13 are correct to the best of my belief.
PETITIONER
____________________________________
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