CASE PLANNING CHART

RAJ MALHOTRA V. SHIVANI MALHOTRA

Client goals/Objectives: Raj Malhotra (the Petitioner) seeks to get a restraint order,
forbidding Shivani Malhotra (the Respondent) from removing the children from the custody
of Petitioner, till the guardianship suit is sub-judice.

Legal Claim ● Interlocutory Application has been filed to forbid the Respondent
to remove the two children from the custody of the Petitioner.

Elements of ● Best interest of children to be raised, under the care of their

the claim Paternal Grandparents.
● It is ideal for the children to grow in the country of their origin.
● The mother, Shivani Malhotra, not only is in a live-in-relationship
with Mr Ajay Khanna, but has also started moved in Ajay
Khanna’s house. This may cause emotional and psychological
damage to the children.

Facts to ● The children have adapted to their new surroundings amongst their
support claim relatives in India.
● They have made friends at school and like them.
● Shivani Malhotra has started living in the house of Mr Ajay
Khanna.

Source of ● Statement of Master Rohan, son of Raj Malhotra, aged 8,

Proof  recorded in Chambers.
● Statement of Baby Muskan, daughter if Raj Malhotra, aged 6,
recorded in Chambers.

Informal ● Shivani Malhotra, being a busy career oriented woman, finds no

Discovery time to contest the custody and guardianship case of her two
children, as she has to report back to London for her job.

Formal ● Shivani Malhotra has moved in the same house with live-in partner
Discovery My Ajay Khanna along with her two children.

Opponents ● Being in a Live in relationship is a common norm in London and

Defence Respondent would ensure children do not witness any
inappropriate or embarrassing situation.
● Daughter Muskaan is a growing up girl and needs constant
attention of the mother i.e. respondent.
● As both Rohan and Muskaan are each other’s best friends, it would
be cruel to separate them at such a tender age.