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Affidavit in Evidence (Mr. Khowaja) Mohammad Siddique Zangejo

Mohammad Siddique Zangejo has filed a guardianship application for his son Nabi Bux. Nabi Bux was taken by his maternal uncles in April 2014 and given to his mother Mst. Sara without Mohammad's consent. Mohammad argues that Mst. Sara is an unfit guardian as she has contracted a second marriage and cannot properly care for or educate Nabi Bux. Mohammad states he is Nabi Bux's biological father, can financially support him, and provide a better home environment. Therefore, Mohammad requests that he be appointed as Nabi Bux's legal guardian.

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Naeem Ahmed Shah
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2K views3 pages

Affidavit in Evidence (Mr. Khowaja) Mohammad Siddique Zangejo

Mohammad Siddique Zangejo has filed a guardianship application for his son Nabi Bux. Nabi Bux was taken by his maternal uncles in April 2014 and given to his mother Mst. Sara without Mohammad's consent. Mohammad argues that Mst. Sara is an unfit guardian as she has contracted a second marriage and cannot properly care for or educate Nabi Bux. Mohammad states he is Nabi Bux's biological father, can financially support him, and provide a better home environment. Therefore, Mohammad requests that he be appointed as Nabi Bux's legal guardian.

Uploaded by

Naeem Ahmed Shah
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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IN THE COURT OF FAMILY/GUARDIAN JUDGE SUJAWAL

Guardianship Application No. of 2014

Mohammad Siddique Zangejo ……………..…………………...…… Plaintiff

VERSUS

Mst. Sara ……………………………..…..……………………………… Opponent

AFFIDAVIT-IN-EVIDENCE

I, Mohammad Siddique s/o Mohammad Achar, adult,


Muslim, b/c Zangejo, r/o Ward No.5, Sujawal town, Taluka & District
Sujawal, do hereby state on solemn affirmation as under:

1. I am plaintiff in the above matter and am fully

conversant with the facts of the case.

2. That I was married with opponent on 25.10.2003

against a prompt dower amount to opponent just after the marriage

to be the dower before the witnesses. I produce copy of

Nikkahnama at Exh.___.

3. That the opponent lived with me for about eight years

and out of the said wedlock, there is one son Nabi Bux aged about 8

yers who was living with me but in the mont of April 2014, the said

Nabi Bux was playing outside the hosue in street where his maternal

uncles took him away and handed over to opponent without consent

of applicant, since then he is living with opponent. I produce

photocopy of Birth Certificate of Nabi Bux at Exh.____.


4. That the opponent after beign divorced by me,

contracted second marriage with one Rakhial Shah and said Rakhial

Shah is already married person and he has also many children from

his first wife. I produce Divorce Deed at annexure ____.

5. That I firstly tried to bring back the minor son through

the meditation but could not succeed.

6. That I again tried to see and visit the minor son at the

house of the opponent.

7. That the opponent being ill character lady is not entitled

to custody of minors as welfare of minor is not protected with

opponent and she has also second marriage.

8. That if the minor will reside with opponent any more,

his education and future will be destroyed.

9. That in presence of a responsible father of minor, the

opponent being irresponsible lady is not entitled to have the custody

of the minor as she can not bring up and give him proper education

as well as maintain him properly because she is household wife and

has no source of income.

10. That being real father, I am entitled to have the

custody of minor while the opponent is not entitled to have custody

of the minor as the life of minor would be ruined if he remains with

the opponent.

11. That I am earning for livelihood of minor and am in

position to provide proper education, welfare and atmosphere to the

minor.

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12. That the future of minor would be ruined if remains

with the opponent as the minor requires proper care and better

education by his father.

13. That the welfare of minor lies with me being his real

father, therefore I am entitled to be appointed as guardian of the

person of the minor and the said Nabi Bux be handed over to me,

hence I have filed the present application.

14. That I therefore pray that my application may kindly be

allowed as prayed.

15. That whatever is stated above, is true and correct to

the best of my knowledge and belief.

Sujawal
Dated: .09.2015 DEPONENT

Identified by me

Advocate

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