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