1. The respondent No.

1 and her other family members also used very filthy,

abusive, ridiculous and a language of defamation in nature with the petitioner
and other family members.
2. That it also came into the knowledge of the petitioner that the respondent
No. 1 while making collusion with her other family members intending to left the
country for abroad UK and for this purpose, the respondent No. 1 while changing
the name of respondent No. 2 made passport and now then applying for visa for
UK with the respondent No. 2.
3. That the respondent No. 1 and her other family members also extended
threats of dire consequences to the petitioner and other family members on
telephone and they also extending threats that they will left the country and the
petitioner can never even see only an eye to his son / respondent No. 2.
4. That the petitioner is entitled for the custody of the minors inter-alia on
the following grounds:
GROUNDS

1. That the respondent is jobless and source-less lady and she do not have any
independent source of income, so it is not possible for her to maintain and
brought up the minor in the prevailing financial circumstances.

2. That the respondent NO. 1 is a lady of extreme emotions and some time she
behaved like a psycho patient.

3. That the behavior of respondent’s family is disgusting with minor.

4. That the respondent is living with family and parents in a house, where they are
dwelling and in that atmosphere the health of the minor is depreciated.

5. That since the respondent No. 1 has left the house of the petitioner, the
petitioner number of time got the news of illness of the minor due to negligence
of the respondent No. 1.

6. That the environment of the house of the respondent is full of suffocation and
the petitioner is apprehending that the personality of the minor will be damaged
from the environment existing in the house of the respondent No. 1.

7. That the father of the minor is in a position to well maintain him.

8. That father of the minor is in a position to give all the basic necessities of life to
the minor.

9. That it is in the paramount interest of the minor that his custody be handed
over to the petitioner. In short the welfare of the minor lies with the petitioner.

10. That the cause of action accrued a few days earlier, when the respondent’s
family refused to allow the petitioner to meet his son and is still continuing.

11. That the respondents are residing within the territorial limits of this Honorable
Court, hence this Honorable Court has jurisdiction to entertain and adjudicate
upon the matter.

12. That the prescribed court fee shall be affixed on the petition.

PRAYER

It is, therefore, respectfully prayed that the custody of the minor respondent No.
2 may graciously be handed over to the petitioners in the interest of justice. And
application u/s 25 of guardian and wards act 1890 may kindly be accepted.

It is further prayed that during the pendency of instant petition, the interim
custody of the minor may graciously be handed over to the petitioner.

Petitioner

Through

Counsel(s)

Advocate High Court

VERIFICATION

Verified on Oath at Islamabad on this    day of Apr 2009, that the contents of the
above paras are true and correct to the best of our knowledge and belief.

                                                                            
Petitioner
 IN THE COURT OF GUARDIAN JUDGE, SENIOR CIVIL JUDGE, ISLAMABAD.

Shah Rukh Asad                                          …Petitioner

Versus

Mst. Sana Afzal Malik etc                            …Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY

OF MINOR/ RESPONDENT NO. 2.

APPLICATION UNDER SECTION 12 OF GUARDIAN AND WARDS ACT

Respectfully Sheweth,

1, That the petitioner filed the above captioned petition before this Honorable
Court, the contents of the same may be read as an integral part of this
application.

2. That the petitioner has a strong prime facie case and hopes to succeed in it.

3. That the balance of convenience also lies in favor of the petitioner because he
is real father of the minor.

4. That if the interim relief is not granted to the petitioner, the petitioner would
have to suffer an irreparable loss.

PRAYER

It is therefore, respectfully prayed that the instant application u/s 25 of guardian

and wards act 1890 may be accepted and the interim custody of the minor may
kindly be handed over to the petitioner, till the final decision of the main petition.

It is further prayed that till the decision of the application for interim custody the
petitioner may kindly be allowed to meet the minor with the proper arrangement
in a week.

Petitioner

Through
 Counsel(s)

Advocate High Court,

IN THE COURT OF GUARDIAN JUDGE, SENIOR CIVIL JUDGE, ISLAMABAD.

Shah Rukh Asad                                          …Petitioner

Versus

Mst. Sana Afzal Malik etc                            …Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY

OF MINOR/ RESPONDENT NO. 2.

APPLICATION UNDER SECTION 12 OF GUARDIAN AND WARDS ACT

AFFIDAVIT

That I, SRA son of AMH resident of _________ Rawalpindi do hereby solemnly

declare as under.

That the deponent has filed above titled application u/s 25 of Guardian and
Wards act 1890 before this Honorable Court the contents of the same are true
and correct to the best of my knowledge and belief and nothing has been
concealed therein.

Deponent

Verification

Verified on Oath that the above deposition is true and correct to the best of my
knowledge and belief and nothing has been concealed therein

Deponent

IN THE COURT OF GUARDIAN JUDGE, SENIOR CIVIL JUDGE, ISLAMABAD.

Shah Rukh Asad                                          …Petitioner

 Versus

Mst. Sana Afzal Malik etc                            …Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY

OF MINOR/ RESPONDENT NO. 2.

APPLICATION FOR THE GRANT OF STAY.

Respectfully Sheweth,

1. That the petitioner filed the above captioned petition before this
Honourable Court, the contents of the same may be read as an integral part of
this application.
2. That the petitioner has a strong prime facie case and hopes to succeed in
it.
3. That the balance of convenience also lies in favour of the petitioner
because he is real father of the minor.
4. That the respondent No. 1 while making collusion with her other family
members intending to left the country for abroad UK and for this purpose, the
respondent No. 1 while changing the name of respondent No. 2 made passport
and then applying for visa for UK with the respondent No. 2. Moreover, the
respondent No. 1 and her other family members also extended threats that they
will left the country and the petitioner can never even see only an eye to his son /
respondent No. 2 and in case the respondent NO. 1 succeeded in her nefarious
designs, the petitioner shall suffer irreparable loss.
PRAYER

In view of above, it is most humbly prayed that instant petition may please be
accepted. The respondent No. 1 may kindly be restrained from changing their
residence along with the minor from District Islamabad to any other District,
country without prior permission of this Honorable Court, till the final disposal of
the main application u/s 25 of guardian and wards act 1890, in the interest of
justice.

Petitioner

Through
 Counsel(s)

Advocate High Court

IN THE COURT OF GUARDIAN JUDGE, SENIOR CIVIL JUDGE, ISLAMABAD.

Shah Rukh Asad                                          …Petitioner

Versus

Mst. Sana Afzal Malik etc                            …Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY

OF MINOR/ RESPONDENT NO. 2.

APPLICATION FOR THE GRANT OF STAY.

AFFIDAVIT

That I, SRA son of AMH resident of _________ Rawalpindi do hereby solemnly

declare as under.

That the deponent has filed above titled application u/s 25 of Guardian and
Wards act 1890 before this Honourable Court the contents of the same are true
and correct to the best of my knowledge and belief and nothing has been
concealed therein.

Deponent

Verification

Verified on Oath that the above deposition is true and correct to the best of my
knowledge and belief.Deponent

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