LEGAL DRAFTING SEARCH

Here you will get all type of legal or law

Pages

Home Disclaimer About Us

PETITION
UNDER
SECTION 25
OF THE
GUARDIAN
AND WARDS
ACT 1890
FOR THE
CUSTODY
OF MINORS

March 07, 2022

H
SHARE
ere is

Labels

the Petitions

actual format of a

petition UNDER

SECTION 25 OF

THE GUARDIAN

AND WARDS ACT

CUSTODY OF

MINOR children to a

father.

IN THE COURT OF

HON’BLE CIVIL

JUDGE (SR.

DIVN.)………..

Vijay Kumar son of

Shri Narayan Singh,

R/o ..

……..Petitioner
 VERSUS

Mrs. Pooja, wife of

Shri Vijay Kumar,

D/o Shri Karan

Singh.

…Respondent

PETITION

UNDER

SECTION

25 OF THE
GUARDIAN

AND

WARDS ACT

1890 FOR

THE

CUSTODY

OF MINOR

DEEPAK

AGED

ABOUT 12

YEARS AND
 DAUGHTER

NAMELY

HIMANSHI

AGED

ABOUT 7

YEARS TO

THE

PETITIONE

R –FATHER

MOST

RESPECTFULLY

SHOWETH :
1- That the
marriage
of the
petitione
r was
perform
ed/
solemniz
ed with
the
respond
ent on
8th
August,
2002 at
……
accordin
g to
Hindu
rites and
ceremon
y in
presence
of
friends
relative
and
member
s of
society.
The said
marriage
was
quite
 simple
and
dowry
less
marriage
and was
solemniz
ed in a
very
simple
manner.

2- That
just
after the
marriage
the
respond
ent
started
inflictin
g
cruelties
mentally
and
physicall
y upon
the
petitione
r and
she
started
abusing,
misbeha
ving,
insulting
maltreat
ing to
the
petitione
r. The
petitione
r tried to
mend
the ways
of the
respond
ent but
the
behavior
and
 attitude
of the
respond
ent
remaine
d
indiffere
nt and
adamant
towards
the
petitione
r.

3- That
many a
times
the
respond
ent left
the
matrimo
nial
home
without
the
consent
and
intimati
on to the
petitione
r. The
petitione
r made
many
efforts
to bring
her back
and the
respond
ent but
the
respond
ent flatly
refused
to join
the
company
of the
petitione
r. So the
petitione
r also
filed a
petition
under
section 9
of the
Hindu
marriage
on 11-
06-2011
in the
court of
Civil
Judge, in
which a
compro
mise was
perform
ed
between
both the
parties
and the
petitione
r
withdra
wn the
said
petition
on 12-
08-2011.
4- That
the
respond
ent left
her
matrimo
nial
home in
the
month of
Decemb
er, 2011
after
quarrelli
ng with
the
petitione
r. The
petitione
r again
filed
petition
under
section 9
of the
Hindu
marriage
on 24-
02-2012
in the
court
against
the
respond
ent
which is
now
pending.
It clearly
shows
the
petitione
r was
ready
and he is
still
ready to
keep and
maintain
the
 respond
ent.

5- That
from the
said
legal
wedlock
of the
petitione
r and
respond
ent
children
namely
master
Deepak
aged
about 12
years
and one
female
child
namely
Baby
Himansh
i aged
about 7
Years
born and
at
present
both of
them are
 in the
custody
of the
respond
ent.

6- That
the
respond
ent
made a
false
complai
nt before
D.C.P,
…… to
harass
and
humiliat
e the
petitione
r on 16-
12-2011
and
thereaft
er the
FIR No.
680
dated
22-02-
2013
Under
section
498A/40
6/506/3
4 IPC
was
registere
d against
the
petitione
r and his
family
member
s. The
criminal
case
titled as
“State
Vs. Vijay
Kumar”
 is
pending
before
the
court.

7- That the
petitione
r is
employe
d as a
JBT
Teacher
and the
petitione
r is
intereste
 d to keep
the
minor
children.

8- That
the
petitione
r hereby
apply for
the
custody
of his
minor
children
being
the
father,
next
friend
and
natural
guardian
on the
followin
g
grounds:
-

(i) That the

environm

ent of the

house of

the
responde

nt is very

bad in

nature

where

minor is

residing.

The

responde

nt and

her

parents

use very

ugly

filthy,

language
 with each

other.

(ii) That the

responde

nt mostly

remains

out of her

house

due to

which the

future of

the

minors is

being

effected

badly.
(iii) That the

behaviour

of the

responde

nt and

her

family

members

are very

rude,

arrogant

towards

the minor

children.

(iv) That the

responde
nt is not

taking

care for

the

proper

upbringin

g of the

minor

children

namely

Deepak

and

Himanshi

. The

responde

nt is

unable to
 provide

the good

education

al

facilities

and social

culture to

the said

minors.

(v) That if

the minor

children

will be

allowed

to live

further
 with the

responde

nt then

their

future

would be

ruined

and he

will

become

criminal

in future.

(vi) That the

petitione

r is

educated
person

and he is

presently

posted as

JBT

Teacher

and he

can give

the

proper

education

to the

minor

children.

The

petitione

r is
having

the line

of

teaching

to the

minor

children

and the

petitione

r will

provide

proper

education

, cultural

education

, moral

education
, social

education

, and

general

knowledg

e. The

petitione

r also

provide

the

faculties

of picnic

tours in

the yearly

and half

yearly

holidays
 and will

develop

the

children

mentally

and

physically

strong.

(vii) That the

petitione

r is

keenly

intereste

d to

support,

welfare,
provide

good

health,

extreme

good

education

and

proper

upbringin

g of

minor

children

namely

Deepak

and

Himanshi

.
(viii) That the

petitione

r is able

to look

after the

minor in

better

way with

full love

and

affection.

The

petitione

r is only

persons

being the

father of
 the minor

who can

make the

bright

future of

minor

children

namely

Deepak

and

Himanshi

(ix) That after

completi

ng his

duty the
petitione

r will give

sufficient

time to

minor

children

namely

Deepak

and

Himanshi

for their

developm

ent and

growth.

Besides

this the

parents
of the

petitione

r will also

take

proper

care of

minor

children

namely

Deepak

and

Himanshi

in the

absence

of the

petitione

r
(x) The

petitione

r is fully

able to

give a

good

atmosphe

re to the

minor

children.

The

petitione

r is also

able to

give best

education

al
 opportun

ities to

minor

children

namely

Deepak

and

Himanshi

(xi) That the

responde

nt is not

proper

person to

retain the

custody
 of minor

children

namely

Deepak

and

Himanshi

(xii) That now

the age of

minor

children

namely

Deepak

and

Himanshi

is more
than 12

years and

7 years

and as

per the

law the

father –

petitione

r is

entitled

to take

custody

of minor

children

namely

Deepak
 and

Himanshi

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

10- That the

petitioner

requested her

respondent

number of

times to

handover the

custody of

minor children

namely Deepak

and Himanshi

to him but

every time the

respondent
avoided to the

legitimate

requests of the

petitioner on

one pretext or

the other and

finally on 20-

05-2014 the

respondent

flatly refused

to handover the

custody of the

minor daughter

and son. Hence

this petition.
11- 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 Deepak

and Himanshi.

The cause of

action finally
 arose on 20-

05-2014 when

the respondent

finally refused

to handover

the custody of

minor children

namely Deepak

and Himanshi

to the

petitioners.

12- That both the

parties are

Hindus by

religion.
13- That no other

petition on the

same subject

matter has

previously been

filed, pending

or has been

decided by any

court of

competed

jurisdiction.

14- 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 got

the jurisdiction

to entertain,

try and decide

the present

petition.

15- That a fixed

court fee has

been paid on

the present

petition.

PRAYER
 It is, therefore,

prayed that the

petition of the

petitioner may

kindly be accepted

and the respondent

may kindly be

directed to handover

the custody of minor

children namely

Deepak aged about 12

years and Himanshi

minor aged about 7

years to the

petitioner-father

permanently, a

decree to this effect

may kindly be passed

in favour of the

petitioner and

against the

respondent
alongwith the cost of

the present petition.

Or any other

relief which this

Hon’ble court deems

fit and proper be also

granted in favour of

the petitioner and

against the

respondent.

PETITIONE
R

THROUGH
COUNSEL
VERIFICATI
ON:Verified
that the
contents of
Paras No.1
to 10 of the
petition are
true and
correct to
the best of
my
knowledge
and paras
No. 11 to 13
of the
petition are
true to best
of my belief.
Last Para is
the
prayer. Verif
ied at

PETITIONER
 Affidavit in support

of petition

IN THE COURT OF

HON’BLE CIVIL

JUDGE (SR. DIVN.)

.......

Vijay Kumar

VERSUS

Mrs. Pooja

PETITION

UNDER

SECTION 25

OF THE

GUARDIAN
 AND WARDS

ACT 1890 FOR

THE CUSTODY

OF MINOR

DEEPAK AGED

ABOUT 12

YEARS AND

DAUGHTER

NAMELY

HIMANSHI

AGED ABOUT 7

YEARS TO THE

PETITIONER –

FATHER

AFFI
DAVIT
I, Vijay
Kumar
…………………
………. do
hereby
solemnly
affirm and
declare as
under:-

1- That the

deponent is the

father of minor

children

namely Deepak

aged about 12

years and
 Himanshi

minor aged

about 7 years

2- That the

deponent this

day 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 in

Hindi which

are true to best

of my

knowledge and

belief.
 Deponent

VERIFICATION

Verified
that the
contents of
my affidavit
are true and
correct to
best of my
knowledge
and belief
and nothing
has been
concealed
therein.
Verified at

Deponent

Also read this :

What is section 323

of IPC

Suit for recovery of

money | Bank
recovery suit

stay against finance

vehicle | suit for

permanent

injunction against a

finance company

blank format of

mortgage deed for

Bank of Baroda

Mortgage Deed for

Bank of Baroda

Affidavit for caste

certificate,

Character

certificate,
correction in name,

Ration card,

scholarship etc.

Petition Under

Section 8 of

guardian and wards

act for permission

for permission to

sale the property of

minors

What is Khewat

Khatoni Khasra

number | Revenue

Terminology of land
Experience

certificate from Bar

Association for

advocate

Resume for

empanelment of

advocate in bank

legal notice for

recovery of money

for goods supplied |

Legal notice for non

payment of dues |

legal notice for non

payment of bill.
Legal notice to

insurance company

for claim of stolen

vehicle | claim

stolen vehicle |

notice to insurance

company

Also
read
this :
FORMAT OF

BAIL BOND

U/S 437 A

CR.P.C. OR

PERSONAL

BAIL BOND

Format of

Legal notice

to a telecom

company on

account of

deactivating

the mobile

services

DEED OF

DIVORCE
Application

Under

Section 25

and 27 of the

Consumer

Protection

Act 1986 for

execution of

the Order

dated 10-06-

2010

passed by

the Hon’ble

Forum

Format of

complaint
under

section 12 of

the

consumer

protection

act, 1986

What is

section 307

of IPC

FORMAT OF

ELECTION

PETITION

FOR GRAM

PANCHAYAT
Reply of

election

petition for

Gram

Panchayat |

Written

statement in

election

petition

What is the

difference

between 147

148 149 IPC

MOST

IMPORTANT
SECTIONS

OF CRPC?

What are the

important

sections of

CPC ?

What is

Vakalatnama

Vakalatnama

format

download in

PDF

How to

compute
court fee to

be paid on

plaint ?

WHAT IS AN

INTERIM

BAIL ?

WHAT IS

ANTICIPATO

RY BAIL ?

What are the

different

types of bails

What is

limitation of
time to send

legal notice

Us 138 of NI

Act ?

Jurisdiction

of court

under 138 NI

Act Case

What are the different stages

in a Criminal Case ?

What is a

Civil Suit and

stages in a

Court ?

What are the

Different

Types of

Courts in

India ?

What is the

difference

between an

Advocate

Lawyer and

Counsel ?
What is order

7 rule 11 of

CPC ?

WHAT IS 332

OF IPC ?

WHAT IS 331

OF IPC ?

WHAT IS 330

OF IPC ?

WHAT IS 329

OF IPC ?
WHAT IS

328 OF IPC ?

WHAT IS

327 OF IPC ?

WHAT IS 326

OF IPC ?

WHAT IS 324

OF IPC ?

What is

section 323

of IPC

WHAT IS 325

OF IPC ?
Difference

between 325

& 326 IPC |

325 IPC Vs

326 IPC

Draft of

affidavit for

Military

Deceased

Pension |

Affidavit for

getting

pension of

deceased

army man
Most

important

sections and

Orders &

Rules of the

Civil

Procedure

Code- CPC

orders and

Rules

Declaration

of lien under

section 4(I)

of Haryana

Credit
Operations &

Misc.

Provisions

(Banks) Act

1973

Format of

suit against

bank loan

defaulter |

Civil suit

against

borrower |

KCC loan

Civil Suit
APPLICATIO

N UNDER

SECTION

156(3)

CR.P.C. FOR

LODGING

CASE/FIR

UNDER

SECTION

379/408/420

/120-B I.P.C. |

HOW TO

REGISTER

FIR U/S

156(3) OF

CRPC.
Application

for valuation

of property

National Lok

Adalat Bill

performa

format | bill

format for

counsel fee

Written

statement in

suit for

permanent

injunction

and

declaration
Application

under

section 24 of

the Hindu

Marriage Act,

for grant of

ad-interim

maintenance

pendentelite

allowances

to the

applicant-

respondent.

MODEL

MEMORAND

UM OF
ASSOCIATIO

N OF THE

SOCIETY

WRITTEN

STATEMENT

ON BEHALF

OF

DEFENDANT

IN

DECLARATIO

N SUIT

REPOSSESSI

ON AGENCY

AGREEMENT
Suit for

declaration

for

cancellation

of agreement

to sale

Affidavit of

military

deceased

pension |

affidavit

pension

army

How to write

agreement

for sale of
house/flat |

agreement to

sale

Special

Power of

Attorney for

a house/flat |

How to write

an SPA

PETITION

UNDER

SECTION 25

OF THE

GUARDIAN

AND WARDS

ACT 1890
FOR THE

CUSTODY OF

MINORS

legal notice

format to a

hospital for

medical

negligence

What is

complaint

under

section 97

CrPC |

Format of

complaint

U/s 97 Cr.Pc
| search

warrant

What is an

affidavit in

lieu of

evidence in a

divorce

case?

Draft of

contempt

petition |

Application

for court of

contempt

Under Order
39 Rule 2-A

C.P.C

Summary

Suit U/o 37

of CPC |

Provision for

summary

suit | Suit for

Recovery

under order

37 of CPC.

FORMAT OF

SEARCH

REPORT OF

BANKS |

WHAT IS
TITLE SEARH

REPORT |

LEGAL

SCRUTINY

REPORT FOR

BANK LOAN

What are the

remedies

available to a

person to

whom bail is

refused by

the court?

All Sections

of IPC |
Indian Penal

Code

written

statement in

domestic

violence act

suit | reply of

dv act | Ws

125 Crpc

Suit for

recovery of

money | Bank

recovery suit

Format of

restoration
application

after ex parte

proceeding

regarding

125 CRPC |

Exparte

Application

Legal Notice

to replace

the Mobile

Phone with a

New one or

refund the

Bill amount

Talaqnama

format |
divorce deed

format |

TALAQNAM

A | TALAQ

Legal notice

for

cancellation

of agreement

to sale |

Notice for

cancellation

of agreement

to sale

format

Petition

under
section 166

of Motor

Vehicle Act

for grant of

compensatio

n of Rs.

10,00,000/- |

Claim

Petition

Injury

Modal draft

of criminal

complaint

filed under

section 323,

325, 506, 34
of IPC |

Criminal

Complaint

Format

stay against

finance

vehicle | suit

for

permanent

injunction

against a

finance

company

CLAIM

PETITION US

166 OF THE
MOTOR

VEHICLE

ACT | Claim

petition

under motor

vehicle act,

1988

Suit for

permanent

injunction

against co-

parcenary

property |

stay against

alienation of

property by
Karta of

Family.

Suit for

declaration

for

dissolution

of marriage |

Divorce by

muslim man

to muslim

woman

Suit by a

Muslim

woman for

Decree of

Dissolution
of Marriage

under

Dissolution

of Muslim

Marriage Act,

1939

blank format

of mortgage

deed for

Bank of

Baroda

Mortgage

Deed for

Bank of

Baroda
Affidavit for

caste

certificate,

Character

certificate,

correction in

name, Ration

card,

scholarship

etc.

Suit for

permanent

injunction

against

stranger

person
Petition

Under

section

13(1)a of

hindu

marriage act

| Divorce

under Hindu

Marriage Act

Petition

Under

Section 31 of

Guardians &

Wards Act

1890 for

grant of
permission

to sell the

Property of

Minor

Petition

under

section 13 b

of hindu

marriage act

Petition

Under

Section 8 of

guardian and

wards act for

permission

for
permission

to sale the

property of

minors

What is

Khewat

Khatoni

Khasra

number |

Revenue

Terminology

of land

Experience

certificate

from Bar
Association

for advocate

Resume for

empanelmen

t of advocate

in bank

legal notice

for recovery

of money for

goods

supplied |

Legal notice

for non

payment of

dues | legal

notice for
non payment

of bill.

Legal notice

to insurance

company for

claim of

stolen

vehicle |

claim stolen

vehicle |

notice to

insurance

company

complaint

under

section 12 of
the

consumer

protection

act 1986

Format of

Superdarina

ma |

Supardagina

ma

Modal Draft

of Simple

Bail

Application

Experience

certificate
from Bar

Association

for advocate

Resume for

empanelmen

t of advocate

in bank

Legal notice

format U/s

138 of N.I

Act

125 crpc

petition

format | 125

सीआरपीसी
याचिका हिन्दी

मे |

LABELS: PETITIONS

SHARE
Comments

To leave a
comment, click the
button below to
sign in with
G l

Popular posts from this blog

हिन्दी
मे दहेज
की
दरखा
स्त
कै से
लिखे |
May 11, 2021
आइये

दोस्तो

आज मैं

आपको…

SHARE
POST A
COMMENT
READ MORE

Applic
ation
for
settin
g
aside
expar
te
order
| set
aside
expar
te
order
May 11, 2021

Format
of
Applica
tion for
…

SHARE
POST A
COMMENT
READ MORE

Exper
ience
certifi
cate
from
Bar
Assoc
iation
 for
advoc
ate
May 18, 2021

Experie
nce
certific
ate …

SHARE

2 COMMENTS
READ MORE

Archive

Labels

Report Abuse

Powered by Blogger