IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT

GAUTAM BUDDH NAGAR.

GWA Case No. /2021
In the matter of :-

Petitioner Sharma Petitioner

Vs
Respondent Mittal Respondent

Most respectfully Showth:

1. That the marriage between Petitioner Petitioner Sharma and

Respondent Respondent Mittal was solemnized on date 15-06-
2012 as per Hindu Customs, rites and religions at Precious
Moments Banquet,B-1/627, Janakpuri, New Delhi,110058. It is
the second marriage of the petitioner.
2. That the petitioner is biological loving father of his minor loving
son namely Arjun and natural guardian as mandated u/s 6 of
the THE HINDU MINORITY AND GUARDIANSHIP ACT,
1956and is more concerned for the welfare, wellbeing, well
nourishing of his son Arjun. Arjun is the Sole Lifeline of the
petitioner and petitioner’s old aged sick parents. The respondent
is employed and a working woman in office and remains away
from home and all the care of their minor son Arjun (including
preparing food, assisting in studies, sports, extra activities,
personality development, emotional/ physical/ mental support,
outings, entertainment, mimickry, acting & singing etc.) has been
taken care of throughout by the Petitioner while working from
home. The petitioner being father and natural guardian of the
minor child Arjun is having the legal right to claim
the custody of the child who is now aged about 7 years 9
months. The petitioner has never abandoned or neglected his
minor beloved son Arjun on any occasion. On other hand the
respondent has no time to provide him nourished food and
instead she would provide all sort of junk foods which are either
easily cooked / prepared or brought from local shops/ food
delivery vendors and as such it is highly objected by the appellant
because of the health concern of minor son Arjun, especially
during Covid-19 pandemic. Respondent would not cook food for
 Arjun & petitioner, instead would ask Arjun to eat apple. During
Navratri period, the respondent asked Respondent to order a
Navratri thali from outside, as she is busy in recording Ramlila
performance of her sister Nidhi Jain at her residence and would
come late by 12:30 am.
3. The appellant is fit from all the aspects to take care of the minor
son Arjun and as far as welfare of Arjun, it can be best looked
after and taken care of by the respondent for his education, food,
health, nourishment, education, and all-round personality trait
and physical development
4. The Petitioner is fit from all the aspects to take care of the minor
son Arjun and as far as welfare of Arjun, it can be best looked
after and taken care of by the respondent for his education, food,
health, nourishment, education, and all-round personality trait
and physical development.

5. That by detaining minor male child Arjun, the petitioner has

been violating the basic human rights of minor Child Arjun.
Minor child Arjun‟s mind is being poisoned by tutoring against
the respondent by the sisters and mother of the petitioner. One
such instance of year 2020 is recorded as Annexure 6 MP 3 of
the voice recording of minor son Arjun saying to the respondent
that “Anu Massi Keh Rahi Thi Na Papa Ki Mummy Ko Papa Se
Shaadi Nahi Kerni Chahiye Thi Kyunki Papa Gande Hai” the
same can be heard by clicking on the Google Drive Link in the
folder named as “Petition”, “A child, especially a child of tender
years requires the love, affection, company, protection of both
parents. This is not only the requirement of the child but is
his/her basic human right.”
6. That the Petitioner was employed at Times Business Solutions
Ltd, whereas Petitioner was also employed at Times Business
Solutions Ltd. The petitioner was the Top Performer in Times
Group in Sales that fetched him the prestigious Chairman
Award as recognition of the petitioner‟s contribution in growing
business multifold. The petitioner was managing a team of
over 400 sales people and vendors in order to generate
revenues for the company and earned 357% growth in
business during his tenure with the company. Both of us
came in touch with each other and during our mutual
conversations respondent also came to know that Petitioner was
a Worldwide Director of Sales at a US based Multinational
Company at an early age. Respondent, the respondent being
impressed with respondent’s high-profile career and
achievements beginning since early age, started making
advancements with the petitioner during tea and lunch breaks
and so she started getting friendly with petitioner, shared her
personal and family information via emails, messages, and phone
calls expressing her love and reasons to like petitioner the day
she saw me for the first time. The Petitioner for the sake of
preserving the sanctity of his relationship/ marriage is
constrained/ restrained to bring any personal emails/
chats/ messages in Public Domain. The respondent got
fascinated, attracted and impressed towards the petitioner
because of his high-profile job, his exceptional success in his job,
personality traits and behavior and started meeting very
frequently. During the conversations, the petitioner clearly
informed respondent that the petitioner is divorcee with a
daughter out of previous wedlock. The petitioner also disclosed to
the respondent that his court case has been already disposed off
by the court as per the court decree. During the courtship, not
only she expressed her love, feelings etc. but also manifested all
her positive traits of being religious, family driven, cultured,
social, etc. She also mentioned that her family is looking for a
groom and every weekend she has to meet a prospective
husband. She was disappointed as none of them suit to her with
respect of age, competence, education, employment, etc. The
respondent continuously came closer with petitioner wherein the
petitioner disclosed about his past personal life, i.e previous
marriage, a female child born from previous marriage and then
divorce by mutual consent. Both of them fell in love. Since being
from different caste, and the petitioner being divorcee, parental
family members of the respondent i.e her mother, sisters, brother
Ajay and brothers-in-law, all were against their marriage but
the respondent being adamant and openly said that she will
marry only the petitioner and none else what so ever may be,
 therefore the family members and relatives of the respondent,
consequently had to succumb to the will and desire of the
respondent and thus their love culminated in solemnization their
marriage on 15.06.2012 according to Hindu religion, rites,
ceremonies, customs at Precious Moments Banquet, B- 1/627,
Janakpuri, Delhi, Near Metro Pillar No. 571 in a very simple
manner with a small gathering ( Only 9 people attended the
ceremony from groom side). The marriage was solemnized in
a very simple manner as it was a love marriage performed
against the wishes of all her family members. Since it was a
love marriage, therefore, obviously no precious gifts, and other
household items were gifted to Respondent Mittal at the time of
the marriage. In view of the simple marriage being held,
Petitioner’s father therefore got arranged a reception function at
Double Tree, Hilton hotel, Mayur Vihar where approximately 100
guests were invited by both of us and petitioner paid the then a
huge bill of Rs. 125000/- in cash.
7. That After about 5-6 weeks of marriage (inclusive of 2 weeks of
honeymoon period), on insistence of the respondent, as
respondent proposed that we shall not stay into the matrimonial
home at Preet Vihar in a joint family since she has been living all
alone at Mohali, Chandigarh and other places from the beginning
itself. The petitioner made earnest appeals with folded hands to
her to stay at Preet Vihar since the petitioner is the only son to
look after his aged parents who are chronically sick, father
being a cardiac patient and mother a hypertension patient but
she did not pay any heed to the requests. Ultimately just to
buy peace with Respondent, both of us decided to move to a
separate house far away from Preet Vihar at a rented
accommodation, at Grand Omaxe, Alpine-C 505, sector-93B
NOIDA, which was also near to our workplace. It is pertinent to
mention that all her sisters are also living separately from their
in-laws leaving them in lurch when they require them more and
more in their advance old age which shows their family mindset
of believing in the concept of nuclear family. Her brother Ajay
Mittal also had altercation with his family and therefore he along
with his wife preferred to buy family peace by shifting to Dwarka
 near to her parent‟s home and subsequently as Ajay Mittal got
employment at Bangalore, he took a sigh of relief and both
husband wife shifted to Bangalore where they are leaving as of
date. It is pertinent to mention here that the petitioner is only
son to his elderly parents to look after as both are retired and are
cardiac/ neuro sufferings.
8. That Out of celestial pious wedlock, both petitioner and
respondent blessed with a male child named as Arjun on 12 Sep
2013, in a hospital from where both straight away came to Grand
Omaxe. The respondent tried to reason with petitoner that the
respondent should call his mother to look after her post delivery
period of 40 days. But she refused and instead proposed that her
mother would come to Grand Omaxe and take care which the
petitioner swallowed as a bitter pill just to have a cordial
relationship with the respondent and her family. Ever since her
mother took a leverage to stay with us during post delivery
period for a long time, her interference gradually started in our
family life leading to the respondent changed outlook towards me
and my family resulting into frequent arguments on trivial issues
which have no relevance in one‟s life. Subsequently, we shifted to
Grand Omaxe, Alpine B 606, Sector 93B, Noida in July 2019
(Same Society) i.e shared household. There was a minor
altercation on phone on a very trivial issue in night of
10.03.2021, thereafter the petitioner reached home in the night
and then we went to sleep. Next day morning on 11.03.2021 at
about 8:00-8:30 am Arvind Jain (brother-in-law of petitioner)
and Nidhi Jain (sister of petitioner) came to our shared
household, stayed for about two hours, made ruckus and
thereafter they took away the petitioner along with minor son
Arjun to their house at Gulshan Ikebana, O Tower, Flat # 121,
Sector 143, Noida, Uttar Pradesh. In the evening, the petitioner
mother called the respondent on her mobile, to return to her
shared household which she was willing to at that moment, but
said that Nidhi (her eldest sister, may not allow her to return
without having a dinner. Despite promising to either return by
late evening or on the next day morning without fail and
ensuring she would manage cleaning, mopping etc. with the
 maid, the respondent did not return to shared household till
date. She also requested to the petitioner’s mother, not to wait at
Grand Omaxe as she was already late for Preet Vihar.
9. That the respondent since then shifted to and has been residing
along with minor son Arjun in her mother‟s house at Gulshan
Ikebana, O Tower, Flat # 151, Sector 143, Noida, Uttar
Pradesh. The respondent also filed an afterthought contemplated
typed police complaint to SHO, Police Station, Sector 93,
Noida, UP, under the instigation and influence of Arvind Jain
and Nidhi Jain as she has been presently residing with Arjun at
Gulshan Ikebana, O Tower, Flat # 151, Sector 143, Noida,
Uttar Pradesh that fall under the jurisdiction of Noida, UP. It
is pertinent to mention that the respondet is employed in
Sector16A Noida, UP.
10. That ever since the respondent left the Grand Omaxe shared
house hold, on 11-03-21 along with minor Arjun, the petitioner
tried his best to connect with respondent & Arjun via as many as
68 emails & umpteen numbers of messages on whatsapp,
telegram and phone calls so as to carry on their married life
happily. The petitoner also made numerous requests to speak to
his minor beloved Son Arjun as both of them were not in touch
since 11.03.2021 and his educational desired development is also
hampered. The petitioner was allowed to talk to Arjun only once
(1) on whatsapp call hardly for 90 seconds and then the
respondent family member abruptly disconnected the call by
snatching mobile phone from Arjun. Thereafter all the sincere
efforts of the petitioner to connect with the respondent and Arjun
were stoned to the wall by the respondent, her sister Nidhi Jain,
Nidhi‟s husband Arvind Jain, Respondent‟s brother Ajay Mittal,
and Respondent‟s mother by blocking th e petitioner on the
mobile phone and whatsapp.

11.That in April 2021, the petitioner fell sick because of CORONA.

During his Covid -19 ailment also, the petitioner tried to connect
to respondent and Arjun on umpteen number of times through
emails, phone calls and whatsapp calls when he wanted his
family the most. The respondent never bothered to
connect her minor Son Arjun to the petitioner except on
 one occasion for 90 second phone call duration, as stated
above and abruptly disconnected call causing a lot of
embarrassment, mental agony and mental torture to both,
Arjun. Minor Arjun was very sad to see his father in such a
condition after such a long interval but found himself
helpless screaming, weeping and crying “Papa Main Aapko
Bahut Miss Kerta Hoon”. The entire episode clearly manifests
the evil designs of the respondent and her family members to
damage and destroy the bonding of father and son by all possible
means at their command without having any consideration for
human and social values attached to the 10 years-long
matrimonial relationship.

12.That the petitioner is biological loving father and natural

guardian of his minor loving son namely Arjun as mandated
u/s 6 of THE HINDU MINORITY AND GUARDIANSHIP ACT,
1956. The petitioner is essentially more concerned for the
welfare, academic, cultural and social development, wellbeing,
well nourishing of his son Arjun. Arjun is the Sole Lifeline of the
respondent and his old aged sick parents. The respondent is
employed and a working woman in office and remains away
from home and all the care of their minor son Arjun
(including preparing food, assisting in studies, sports, extra
activities, personality development, emotional/social
/cultural/academically/ physical/ mental support, outings,
entertainment, mimicry, acting & singing etc.) has been
taken care of throughout by the petitioner while working
from home and it can be manifestly adjudged from the call
recording during of the period when the respondent left and
abandoned minor Arjun for about 15 days in year 2020. The
petitioner being father and natural guardian of the minor child
Arjun took all the care of their minor son Arjun (including
preparing food, assisting in studies, sports, extra activities,
personality development
emotional/social/cultural/academically/ physical/ mental
support, outings, entertainment, mimicry, acting & singing etc.)
in better manner with optimum focus on Arjun‟s all round
development, thus entitled and having the legal right to claim the
 custody of the child who is now aged about 7 years 9 months.
The petitioner has never abandoned or neglected his minor
beloved son Arjun on any occasion whereas the Petitioner has
abandoned and neglected Arjun once in the year 2020 as

mentioned above. Further on other hand the respondent has no time to

provide him nourished food and instead she would provide all
sort of junk foods which are either easily cooked / prepared or
brought from local shops/ food delivery vendors and as such it is
highly objected by the petitioner because of the health concern of
minor son Arjun, especially during Covid-19 pandemic. She
would not cook food for Arjun & the respondent, instead would
ask Arjun to eat apple. During Navratri period, the respondent told

petitioner to order a Navratri thali from outside, as she is busy in

recording Ramlila performance of her sister Nidhi Jain at her
residence and would come late by 12:30 am.

13.That the petitioner is fit from all the aspects to take best
care and welfare of the minor son Arjun. The petitioner only
can best look after welfare of minor Arjun for his education, food,
health, nourishment, educational, social, cultural and all- round
personality trait and physical development. Respondent happily
missed PTM and FOAM sessions during the beginning of
academic year 2021, whereas the petitioner attended both
the events without Arjun.

14.The respondent, her sisters particular namely Nidhi Jain and

Archana Mittal@ Anu, have been continuously poisoning the

tender mind of the innocent Arjun against the petitioner and his

family and leaving no stone unturned to infuse hatred in tender

mind of Arjun. On one such recorded conversation, Arjun said

to the respondent that “ Anu (Archana) Mausi Keh rahi thi

papa ki na… Mummy ko papa se shaadi nahi kerni chahiye

thi kyunki Papa Gande Hai”, at this petitioner said “Aise kyun

bola” to which innocent Arjun Replied “Pata Nahi”. (Annexure

6 - Call Recording of such conversation).

15.It is most humbly reiterated that the marriage of the respondent

with petitioner is love marriage against the wishes, will and

desire of the respondent‟s mother, sisters, brother and brothers-

in-law. The respondent at that point of time took the bold

decision of the marriage by revolting against all her family

members. Ever since our marriage, the sisters and other

members of the respondent family, namely Nidhi Jain, Archana

Mittal (Alias Anu), Preeti Mittal, Ajay Mittal, Arvind Jain and her

mother are poisoning the mind of the respondent & Arjun with

hatred against the petitioner. These persons namely Nidhi

Jain, Archana Mittal, Preeti Mittal, Ajay Mittal, Arvind Jain

and her mother always interfere in our happy married life

and keep provoking, infusing and persuading the respondent

to follow their parental family’s customs, usages and

religious ceremonies as against that of petitioner’s family

customs and religious ceremonies.

16. That as a concerned father of the only child Arjun, the

petitioner is more concerned about his studies, sports,

social and cultural activities, food, nourishment, health and

other wellbeing. The respondent is self- centered & profession

oriented and as such having the least interest in the all-round

development of Arjun. The respondent is more concerned about

her professional career even at the peril of our son Arjun. Most

of the time she would be open to her laptop right from early

morning to late night and at times she would be in the office on

weekends also as late as 1:00 am (night).

17. That she is never bothered about the feedback given by the

teachers and never has a plan of action for Arjun‟s

 improvement. She never speaks with Arjun in English language

as directed by the teacher and therefore, the petitioners‟s and

Arjun‟s efforts get derailed. She would say “Ab Main Iske Liye

Ghar Mein English Bolu” The respondent rather encourages

Arjun for free access to her mobile (despite repeated requests by

the petitioner, she has not changed her mobile password so as

minor Arjun be not able to operate it), watching TV all the time

which may not only hamper his studies but also adversely affect

his health. As the respondent is a profession oriented and as

such no time for Arjun, she would ask Arjun to learn from

Google and Alexa instead of referring to the books/

dictionary, which hampers his mental development,

knowledge & learning skills. Just to keep family peace, the

petitioner used to perform all the household activities like

preparation of breakfast, lunch, dinner, assisting in Arjun‟s

online class, his studies, his evening outdoor/ indoor sports,

make him take bath, brush teeth, etc. as the petitioner is

working most of the time from home. The petitoner performed all

these tasks, as he is extremely concerned about Arjun‟s welfare,

his health and his educational learning.

18.The respondent would never offer milk, almonds, walnut,

body massage and head massage to little Arjun since birth,

which are very essential for his health and physical and mental

development. Surprisingly, she would give Arjun oranges

from the refrigerator during the month of December when

the entire north India is shivering with extreme cold saying

“Show me where it is written on google that we should not

give oranges in the evening during winters”. The respondent

 has become so adamant that at times she would be ready to

break the matrimonial relationship, leave Arjun at his peril but

will not change her mindset as she claims to be always “RIGHT”.

The respondent would always have her plan of things even after

office hours at the cost of the petitioner and their minor son

Arjun.

19. That during a PTM meeting, Son Arjun himself happily

admitted to teacher that the entire credit goes to my father
for my exceptional improvement in reading, writing, English
speaking skills, framing of sentences and mathematics. The
Teacher also appreciated Arjun‟s habit of raising questions,
which were developed by the petitioner.

20. That the respondent is very loving and caring father and
Arjun has so much intimacy with the respondent that Arjun
made a handcrafted Birthday card for respondent.

21.That initially it was the petitioner who initially noticed the

hair fall of Arjun on 7th Dec 2017, while giving him a
head/oil massage. When petitioner discussed it with the
respondent, she took it casually and said “Kuch nahi hai,
tumko veham hai”. But as a concerned father, on 8th Dec
2017, the petitioner took Arjun immediately to Dr. Sanjiv Jain
(Dermatologist of national repute) at Daryaganj for check up and
got him medicated. On petitioners return to home, the
respondent became a bit serious and discussed the prescription
with her sister (Preeti Mittal) who is herself a doctor, who
suggested Dr. Vohra, skin specialist having clinic at Vasant
Vihar. Thereafter both of us took Arjun to Dr. Vohra Skin Clinic
who diagnosed Alopecia, which is an autoimmune disease in
which body‟s immune system attacks healthy cells. It is a genetic
disorder that can come from either of the parents, grandparents
of either family‟s medical conditions/ history like Asthma and
Eczema etc. In this disease suddenly hair start falling and
baldness starts in patches. It is pertinent to mention here that
Arjun‟s maternal grandfather (respondent’s late father) was a
 high-grade asthmatic patient, which is so mentioned in the
prescription of Dr Vohra, which is annexed, with the annexure of
the petition. This fact has been mentioned in the Vohra S kin
clinic‟s prescription also.

22.That the petitioner is most caring and most loving to his minor
son Arjun and always fulfills all his needs whether it is his
studies, sport, food, health, swimming or other co-curricular
activities.

23.That during the Covid Pandemic, on 23 June 2020 the

respondent abruptly left shared household on flimsy and
irrelevant grounds and went to her parental home at Hari Nagar
Delhi, abandoning minor child Arjun with the petitioner. The
respondent returned to share household after 15 days.
During this period the petitioner inculcated good habits and
improvement in all round development of Arjun, including
cooking breakfast/lunch/dinner of his choice, to keep him
physically fit in the absence of his mother who has no
regards for the sentiments of the innocent child. During this
period Arjun developed the habit of drinking milk, eating
almonds/ walnuts, studying, playing, etc.

24.That Arjun is also very friendly and intimate with the

petitioner and his grandparents. The petitioner’s paramount
consideration and interest has been always for the welfare
and well-being of his minor son Arjun to whom he loves from
the core of his heart. The photograph and videos while
playing football, swimming, cricket, tennis, mimicry, food,
cycling, movie acts, public speaking, American accent,
annexed here with are self explanatory that Arjun always
remains happy with the respondent.

25.The respondent has never allowed Arjun’s birthday

celebration on grand scale by inviting all close relatives and

friends, as desired & requested by little Arjun at par with his

friends birthday‟s celebrations. Due to the adamant and

whimsical nature of the respondent‟s perception, such as the

expenditure on celebrating birthday on grand scale is merely a

 waste of money and meaningless showbiz by saying “Birthday

celebration karne se humko Kya Milega, Log Ayenge aur

Khaa ker Chale jayenge….Arjun ko Kuch bhi Yaad nahi

Rahega”, without considering the emotions, sentiments, wishes

of the Little Arjun. The only grand celebration till date is the

Kuan Poojan and Sai Sandhya organized & funded by Arjun’s

grandparents at Preet Vihar.

26. THAT it is the general behavior of the respondent and her

parental family members to restrain Arjun to talk to the

petitioner and his parents by abruptly snatching/ disconnecting

his phone whenever the respondent is at her parental home or

with her siblings for the reasons best known to them. Arjun,

the innocent child is left weeping, crying, screaming to talk to his

father or to meet with him at Noida home but the respondent and

her parental family members would never allow Arjun to speak

petitioner, causing a lot of emotional, psychological, mental

harassment, physical, and negative mental and physical growth

of little Arjun. (Refer Annexure with whatsapp chat and (Call

recordings) where he is crying and requesting the respondent to

allow him to talk to his father, which is conveniently ignored &

out rightly rejected. Also, there is call recording in which the

respondent‟s family members snatched phone from Arjun and

disconnected his call while he was talking to petitioner. It is

crystal clear that the petitioner and her family members are

having one point agenda to somehow break/ disturb

bonding’s of father & son duo.

27. The respondent has least & slightest regard and emotional

attachment for the family festivals/rituals like Pitra Pooja on Holi

 and Diwali, and as such she would deliberately take away Arjun

to her parental home in order to disconnect him from the

petitioner and his grand parents.

28. The respondent is totally misguided and misled by her

family and siblings to ignore her husband without analyzing &

realizing the consequences of such an unexpected act in

matrimonial relation.

29. That it is pertinent to mention here that the petitioner has

ensured Arjun‟s safe academic & financial future by purchasing

a LIC Policy “Jeevan Umang” for Rs. 30,00,000 (Thirty Lacs) in

2018 in which Rs.2,50,000 has to be paid

 every year for 15 years (Term 15 Years), In the subject policy the

nominee is the respondent Respondent Mittal Sharma. Under

this policy since she is the nominee, she would be getting a

huge amount at the time of the maturity, which will take care of

the respondent and also take care of higher studies of our Son

Arjun Sharma in case of any mishappening to the petitioner.

This amply shows that the petitioner is attached to the family

i.e. wife and Son Arjun and has left no stone unturned to

safeguard their future by taking this LIC Plan. Rs. 10,00,000

already paid. (Annexure18 in attached pen drive). Needless to

mention that most of the time the petitioner deposits the school

fee and bears other expenses of his minor son Arjun without

seeking any financial assistance from the respondent which

manifests the petitioner's love, care, and concern for his son

Arjun who is his sole lifeline. The fee receipts dated 6th June

2021 is also attached and Annexure in google drive and

attached pen drive. The fee receipts for the past two years

debited to the petitioner's account/ credit card can be shared

with the Hon'ble Court if so desired.

30. That It is to put on record that the respondent on many

occasions has abused the petitioner, his family members. She

has on many occasions threatened petitioner to kill him and

his family by giving poison. She has also threatened petitioner

over phone calls and emails that she will file complaints false

against petitioner and his family.

31.That due to her mindset, unsocial attitude, it is pertinent

to mention here that during last eight years not a single

 birthday of Arjun has been celebrated at a grand scale as she

finds considers social gatherings as waste of money and she

is of the opinion “AAP SABKO TOH BHEED IKATTHA KARNE

KI AADAT HAI, HUMKO KYA MILEGA, BACCHE KO KUCH

BHI YAAD NAHI REHTA”. Arjun has time and again wished his

birthday to be celebrated in a grand way like other children’s

birthday that he attends and therefore feels dejected and

frustrated.

32. That it is pertinent to mention here that the fact was the

petitioner wanted to celebrate Arjun‟s birthday with great pump

and show as Kuan poojan and Sai Sandhya ceremony for which

respondent did not agree and instead preferred to share birthday

platform with her brother‟s daughter birthday as guided by her

mother to humiliate petitioner and his parents in the eyes of

their (Respondent‟s family) guests. It was primarily intended to

give an impression to their guests that petitioners are too poor to

celebrate Arjun‟s birthday. The little Arjun was totally upset and

sad, as all the gifts were offered to respondent’s brother’s

daughter (Ashima) by their guests and it was really shocking that

none of their guests thought of offering gifts to little Arjun. It

were petitioner’s parents who stood up and had a photo shoot

with little Arjun and offered him cash and blessings. The entire

episode goes a long way to show the whimsical/ adamant

attitude of respondent and her family who leave no opportunity

to humiliate petitioners and his parents. The respondent despite

repeated family discussions and conversations, somehow

derailed the birthday celebration plans of Arjun’s from the day

one (1) as envisaged by not only petitioners but also Arjun to

 invite a large gathering with various events, games, dance,

dinner, food stalls, cake, etc in a big banquet hall. In-stead she

brings a cake at home and celebrate the birthday in the presence

of three (3) people (Respondent 1 + Petitioner + Arjun) which is

disgusting and inhuman as it kills the spirit, wishes, desires,

happy moments of little Arjun which would be cherished by

him all through his life. To this her response is as follows:-

 Log Ayenge aur Khaa Ker Chale Jayenge

 Tumko Toh Bheed Ikkathi Karne Ki Aadat Hai, Humko

Kya Milega

 Bacche ko Kuch Nahi Yaad Rahega

33.It is pertinent to mention here that Petitioners ‟s parents even

offered to organize Arjun‟s birthday at their own expense as they

did at the time of Kuaa Pujan and Sai Sandhya for which

respondent declined.

34.That as regards minor son Arjun, as a concerned father of the

only child, the petitioner is more concerned about his studies,

sports, activities, all around social, cultural, physical

development and other well-being. The respondent was self-

centered and having the least interest in the development of

Arjun. She was more concerned about her professional career

even at the peril of her son Arjun. Most of the time she would be

open to her laptop right from early morning to late night. Just to

keep family peace, I use to perform all the household activities

like breakfast, lunch, dinner, Arjun class, his evening outdoor/

indoor sport, make him take bath, brush teeth, etc as I was

most of the time working from home. The respondent would

 never offer milk, body massage and head massage to little Arjun,

all these tasks were performed by the petitioner as he was

extremely concerned about Arjun and his health.

35. That the complainant is a reckless driver who always drives at

high speed even if when Arjun is on- board with her, without

caring that it might cause an accident involving herself and

Arjun, despite my repeated requests, reminders and warnings to

desist from high-speed driving. Her standard response is “Don’t

worry I am an expert driver”.

36.That it is the respondent who advised Petitioner to quit the

high-profile job of Times group and start a business to fulfill her

ambitions of becoming rich overnight in order to compete with

her sisters in terms of economic/ financial growth. Even though,

after quitting the job from Times Group, the Petitioner was

having a job offer in hand from Rozgaar India Pvt. Ltd for the

position of Vice President Sales in 2013 which had to be declined

by the petitioner as per the wishes of the respondent as she was

keen on petitioner starting the business. It was also mutually

discussed and decided by the Respondent and petitioner that

the petitioner would fund the startup apart from providing

technical & design support and the Petitioner to take care of

business development & Sales. The respondent even though

provided financial support in the early years of the business

but later on pulled out her technical support that was necessary

to build the startup website/ platform, despite repeated requests

by the Petitioner. She mishandled and took inordinate time to

complete the website development work that resulted into

financial loss and got delayed by over 2 years. Apparently, the

 website developed under the guidance of the Respondent, did not

work and hence it had to be scrapped. This derailed the complete

planning of the Petitioner and the respondent started taunting

Petitioner by calling him as “JOBLESS, GOOD FOR

NOTHING LIABILITY, NITHALLA, MUFTKHOR, BOASTER”

which not only hurt the Petitioner but shattered him into the

pieces. At the same time the respondent took a U- turn stating

that it is not her project but it is Petitioner project, As per chat

available in Annexure 10, the petitioner was requesting and

pleading her to complete the project since it was a joint

responsibility to launch it successfully. But she was bent upon

to once again derail the project. On way back from Bangalore

(from her brother house) instead of coming to Grand Omaxe and

join the Respondent, she preferred to stay back at Hari Nagar for

over 15 days and was not cooperating with the project and also

was not allowing the respondent to speak to son Arjun on the

phone in spite of 10 reminders (Call recording of Arjun

available).

37. That As usual, the father has to be strict at times when the

mother is careless & fails to realize that the main focus of

the child has to be on the main subjects and other activities

such as painting etc are secondary in nature. The petitoner

was informed by the class teacher about the weakness of

Arjun in the main subjects like Hindi & English sentence

structuring. The respondent was encouraging him to indulge

all the time in painting either or play with tools like Alexa to

answer the homework questions. As the respondent was

always engrossed in her office calls, chats, etc, she would

 hardly had spare time for Arjun to help him answer his

homework questions. She therefore, found an easy route to

encourage Arjun to find answers from Alexa or Google and

finish the homework without any application of mind.

38. That most of the time Arjun use to stay with petitioner at

home who would take care of all his needs such as breakfast,

lunch, dinner, snacks, studies, outdoor sports, fun time with

father, etc. Needless to mention that even after coming from

office, respondent would be busy talking with office colleagues

and relatives till late night and as such Arjun would always

sleep with Petitioner by hugging him tight & listening to the

bedtime stories.

39.That it is pertinent to mention that Respondent overburdened a

little child Arjun by asking him to attend dance class, skating

class, piano class and drawing class alternatively, apart from his

daily school routine. Being a little child, he could not bear the

pressure and started sleeping in the piano class, skipping

skating class and so on. During one of the Parent Teacher

meeting, all teachers raised serious concerns about Arjun’s

distraction from main subjects, sounds, sentence formation, etc.

for which the respondent was solely responsible as she had

distracted his mind from the main subjects to extra-curricular

activities to avoid any disturbance to her as she was mostly not

available to attend his study related issues. Thereafter, as a

concerned father Petitioner took responsibility of investing more

time and efforts in Arjun’s studies and crafted a composite plan

where in Arjun would get some extra time for main subjects and

at the same time won’t miss extra-curricular activities also. As

 such the result astonished all the teachers at the school and

appreciated by one and all. Arjun was very happy and excited

with his performance, development & learning, he openly said

that it was because of his father.

40. That most of time the respondent offers undesirable,

unhealthy food that contains chemicals like MSG, food

additives and other taste enhancers that are cancerous. At

times, even this phrase is used by doctors as “Yeh Junk Food

to Poison hai kyunki Isme Cancerous chemicals and

additives hote hai”, whereas he is my biological son with low

immunity and as a concerned father, I would take all the

liberties to make him understand the harmful consequences

of consuming such poisonous food detrimental to health

especially when the mother is totally carefree, careless

about the health of the minor. She never bothered to provide

Giloy tablet and Juice to Arjun even during the Covid-19

pandemic, which was advised by one and all. The respondent

is in the habit of providing junk & packed food to Arjun

which is detrimental to his health at this tender age. When

confronted by Petitioner, she got furious, started abusing,

throwing vase, cups, and steel water bottle on the floor,

while packing her bag along with Arjun on way to Hari Nagar.

Arjun was utterly shocked by her aggression, screams, etc, he

was frightened & refused to accompany the Respondent to her

parental home at Hari Nagar. Arjun‟s refusal to accompany her

infuriated her the most and she left the home screaming and

shouting saying to Arjun “Tu Bhi Yahin Iske Saath Mar aur

Main Ja Rahi Hoon.

41.That the respondent left Grand Omaxe home on 11-03-21 along

with Arjun as guided by her sister Nidhi Jain and her husband

Arvind Jain, despite requested by the parents of Petitioner to

accompany them and stay at Preet Vihar (Separately from

Petitioner) till such time the tempers of Petitioner and

Respondent cools down. This option was declined out rightly by

respondent and her relatives. Since petitioner are very

possessive to retain Arjun with them, so it was mutually

decided and agreed that Arjun would stay with Petitioner for

first 15 days and thereafter next 15 days with Respondent to

satisfy egos of both. After taking Arjun from Grand Omaxe on

11-3-21, the said promise by the respondent and her family

was never honoured as they detained Arjun at Gulshan

Ikebana even after the completion of 15 days as agreed. This

matter was also raised by Petitioner and his father in the

presence of Police official on 23rd of March with respondent

& her brother Ajay Mittal, who was bluntly refused to send

Arjun back to his father at Grand Omaxe as agreed. Ever since

the respondent left the Grand Omaxe home, on 11-03-21 along

with Arjun, the petitioner tried his best to connect with

respondent & Arjun via 68 emails & umpteen numbers of

messages on whatsapp, telegram and phone calls and sort out

the issues, if any, amicably to carry on the married life smoothly

and also made numerous requests to allow Petitioner to speak to

his Son Arjun as both of them were not in touch since long. But

all the sincere efforts to connect with Arjun were stoned to the

wall by the respondent and her family by blocking the

respondent on phone and whatsapp.

42. That on receiving an email from class teacher on 20-3-21 to

access a video file of Arjun on Microsoft teams. Petitioner

immediately logged in to the Microsoft to desperately have a

glimpse of his son Arjun‟s video. To Petitioners’s dismay and

surprise, the respondent had changed the password of the

Microsoft teams account with an intention to debar/ prohibit

and restrict Petitioner to have access to Arjun’s class

participation, daily progress, etc. The Petitioner frantically and

desperately reached to the class teacher via email on 20-03-21

and 21-03-21 (Annexure attached as communication with

School teacher) that he is unable to access Arjun‟s account as

the password seems to have been changed. The petitioner

requested the IT dept. to reset the password to enable an access

to Arjun‟s account. And accordingly the IT team obliged the

petitioners request and reset the password with which petitioner

could have an access. As a concerned husband with all good

intentions and regard, the petitioner informed the

respondent about the new password via email. It is pertinent

to place on record to the Hon’ble court that as the respondent

neither bothered to attend final PTM on 27-03-21 nor FOAM

Morning on 06-04-21 (First day of Introduction of next session

with new teacher), as a concerned father the petitioner

immediately send an email to the respondent drawing her

attention to this effect which has not been responded till date

(Email attached herewith). Petitioner on the other hand was

extremely concerned about his minor Son Arjun’s final PTM

and FOAM Morning session and he attended it. Again Arjun‟s

homework was not completed and submitted to the teacher on

 08-04-21 and also Arjun missed his dance class on 09-04-21,

and the this fact was communicated to the respondent via email

on 09-04-21. Petitioner was helpless and desperate about his

son‟s studies and other activities as any father would be, as

Arjun was living with the respondent (who never bothers or

focus on his development, instead busy on

laptop/phone/chats) away from the petitioner. The hon’ble

court to take cognizance of the conduct of the Respondent

with regard to Arjun’s welfare & the exceptional and

astounding concern of the respondent for his son, if deemed

fit.

43.That the matter of fact is it that it was the respondent who

had openly threatened to poison petitioner and his entire

family and also implicate them all in false litigations/

police complaints. she threatened that she would implicate

the petitioner in false litigations and police cases and get

petitioner arrested. Also, she would neither allow custody

nor visitation rights for Arjun as the family courts/ law

enforcing agencies would take cognizance of her

complaints.

44. That the petitioner being the biological father of Arjun,

is emotionally, sentimentally, and physically attached to him
and is highly concerned about Arjun’s welfare and well-being.
During second week of April, the petitioner and his family fell prey
to Covid 19 and the petitioner was on oxygen support for a week
and therefore desperately tried to speak to his Son and wife as he
was under tremendous stress, agony, insecurity, uncertainty due
to Covid 19. After umpteen number of emails and phone calls,
finally the complainant made a video call which lasted hardly for
about 90 seconds in which she allowed Son Arjun to speak to
 petitioner. Arjun seemed to be very weak, scared, stressed, to
speak to his ailing father after a long interval of 40 days.
Arjun could hardly utter a few words like “Papa AapKaise Ho”
“Main Aapko Bahut Miss KertaHoon” and when he was asked
by Respondent about his studies he said “Main Acche se Padhai
ker Raha Hoon” and the call seemed to have been deliberately
disconnected to prevent further dialogue of Father-Son.
Petitioner tried to connect again. But the respondent
intentionally did not respond, leaving the petitioner in lurch
even during his Covid ailment, having no human. Even a
stranger for that matter would ask about the health and offer
full support when required. This shows high-headed attitude,
temperament of the respondent imbibed from her family.
45. That Arjun’s class teacher always appreciated the
involvement of petitioner in developing Arjun, his habits and his
social development. Below is the synopsis of the PTM where
teacher discussed Arjun’s exceptional development & Arjun gave
its credit to petitioner.He started reading extremely well and gives
credit to Petitioner. Teacher said that Arjun has done very well not
only for himself but also helping other kids. His reading, writing
and speaking has improved really well. He talks in english, it is
helping him. He loves Maths, but he needs to focus on his writing
and creative writing. His thoughts are very clear as well as he is
framing it very well. Arjun has developed a tendency of curiosity to
ask questions to understand why things happen and what are the
reasons behind it. Petitioner practices multiple commands with him
and the teacher mentioned that Arjun has improved a lot. Teacher
also spoke about Arjun having distractions all the time. Petitioner
told teacher that he practices this with Arjun and that is why there
is such a drastic change in him. Petitioner also told him that i follow
an approach of Focus books where i ask him to pick book from
focus sections and he resolves mathematic problems which are
then his grade. Petitioner works on his hindi, maths, english and
teacher was extremely happy with Arjun's development. Teachers
were very happy with the efforts of the petitioner.
46. That Whenever respondent is counselled by petitioner to
interact with Arjun in English, she would bluntly refuse and plead
 “Ab Kya Main Iske Liye Ghar Main Sara Time English Main
Bolu”where as Arjun & Petitioner interact with each other in
English most of the time(Videos/ calls can be shared). This
negative and whimsical attitude of the respondent not only
derailed the two weeks (2) long efforts which the Petitioner made
(when respondent was away at parental house, Hari Nagar
abandoning Arjun with Petitioner at Grand Omaxe) to promote
his English/Public speaking skills apart from improving his
proficiency in all other main subjects.
47. That it is very important to mention here that During
April 2015, respondent engaged a 24 hours maid servant to look
after Arjun, despite petitoner’s refusal, but on the advice of her
parents/ sisters. The maid was found to be breast feeding Arjun
secretly by me when he was hardly 2.6 years old. To clear any
apprehension and doubts, HIV test was conducted on the maid to
ensure that no infectious disease has been communicated to
Arjun. Respondent also prepared a maid's confession video. This
crystal clear shows her casual and irresponsible attitude towards
the child right from the beginning and her dependency on the
maids to take care of Arjun.
48. That Arjun had lumps on his neck that were spotted by the
petitioner when he was giving him a massage. Petitioner
discussed this with Respondent and she was very casual about it.
After few days there were more lumps spotted around the neck for
which Petitioner took him to Medanta hospital. The doctor advised
him to get further testing done to outrule any dangerous disease
like cancer. Petitioner decided to take him to Medanta in Gurgaon
but Respondent told him that she will go alone as she wanted to
meet her sister there. This shows that she was more interested in
meeting her sister rather than getting Arjun tested. She also
ensured that Petitioner stays back at home at such a crucial event
when his Son is undergoing medical tests to give an impression to
Arjun that his father is least bothered about his wellbeing.
49. That Access to Gadgets & Mobile - Respondent encourages
Arjun for free access to her mobile (despite repeated requests by
the respondent, she has not changed her mobile password so as
minor Arjun be not able to operate it), watching TV all the time
 which may not only hamper his studies but also adversely affect
his health. As Respondent is a profession oriented and as such
no time for Arjun, she would ask Arjun to learn from Google
and Alexa instead of referring to the books/ dictionary, which
hampers his mental development, knowledge & learning
skills. Excess of mobile usage can also hamper Arjun’s brain
development as well as Got Arjun addicted to games and he
downloaded 37 games.
50. That teachers has given feedback to Respondent that she
should encourage Arjun to do his homework in notebook in
order to improve his writing skills. Respondent has no time
for Arjun and continues to make him do his homework on
laptop. This shows that her focus on the child is zero and she
always looks for her convenience. As a parent, we need to give
priority to our child, their development, their learnings and their
strengths which she does not. 
51. That Arjun and Petitioner are very fond of vacations and
family time. Respondent captivates Arjun within four walls of the
home as she does not like to spend money on such activities.
Petitioner is extremely sensitive about Arjun’s requirements &
ensures he takes him to various vacation & family trips like
Jaipur, Shimla, Amritsar, Nainital, Mussorrie, Goa, etc.
52. That Respondent never teaches Arjun family values, never
encourages to respect elders, never tells him to bow head infront
of god, never teaches him table manners, never teaches him
culture values. It is Petitioner who always encourage Arjun to
socialise, respect elders, stay in groups, be a family child, enjoy
his childhood with his cousins and siblings. This shows
Respondent wants to keep him in isolation which is very
dangerous for the mental, social and physical development of a
child.
53. That Respondent has disconnected Arjun from his friends.
She does not respond to the calls and messages sent by Arjun's
friends/ parents for video call, meeting, etc. Arjun has been
captivated and is not even allowed to meet/ talk to his friends
which is again dangerous for his social and mental development.
This is the age when Arjun should be making friends, talking with
 them on the phone and enjoying his childhood by exchanging
stories and notes. This shows that she is very insensitive towards
the social requirements of Arjun which will develop him into an
unsocial person who will always live in isolation and stay
frustrated.
54. That Respondent has no time for Arjun for the activities
which are very important for his mental and physical development
like sports, outing, socialization, etc. She tries to compensate for
it by purchasing him toys, gifts, etc. She tells him that money can
buy all the happiness and because of this Arjun has no value for
money in his mind. This is an extremely dangerous thing for a
small child at this age. This also shows that she is not driving
correct behaviour in Arjun that will further spoil him and create
problems in his life.
55. The only mode of entertainment for Arjun is toys. She never
encourages him to make friends, never takes him out for
recreational activities, never encourage him to participate in social
events like stage performances, dance, singing, etc as she herself
has no interest in it. Her upbringing of the child is on the basis of
her likings, preferences, thoughts and choices. She will not let
Arjun do anything which she does not like, for ex she will never
head massage Arjun as she herself does not like oiling her hair.
This attitude is very dangerous for the development of a child.
56. That Respondent has no time for Arjun and his studies. For
her convenience, she has diverted him to subjects like painting
and arts which needs no attention from the parent. Arjun was
extremely weak in his major subjects and this was reported by his
teachers during PTM. Petitioner told Respondent many times that
we should maintain a balanced approach with his studies and
ensure he is taught main subjects well so that his base is strong.
Despite various efforts by Petitioner, Respondent continues to
encourage Arjun in arts and never teaches him main subjects.
Petitioner has been extremely serious about Arjun's academics
and therefore took charge of Arjun's academics after his meeting
with teacher. Petitioner ensured Arjun becomes very strong in his
academics by working closely with him and this lead to major
 shift in his learnings that was appreciated by teachers and Arjun
gave credit of this transformation to his father in the PTM. 
57. That Respondent is mostly busy with her office and work.
She does not attend PTM or FOAM sessions conducted by School
which is very important for parents to understand the progress of
the child. It is Petitioner who attends all these sessions and also
prepares a plan of action for Arjun's studies based on the
feedback given by the teacher.
58. That Until March 11, 2021, Arjun was highly focused on his
studies, academics, etc as he was under the guidance of Petitioner
who use to spend a lot of time in motivating him, helping him with
his studies, using various methods of mentoring and coaching
and developing his interests in various activities. Arjun has a
potential to become a space scientist. Today, Arjun is dismantled,
defocused, left on the gadgets, he is not given nutritious diet,
hence he confessed to Petitioner of having become weak and low
on energy. Very recently Petitioner got to know from School about
the Olympiad Exam and he encouraged Arjun to appear but Arjun
refused. Petitioner also told Arjun to tell Respondent to prepare
him for his exam but Respondent did not pay any attention. This
shows that she has no focus on his mental, physical and
academic development. She has no time for Arjun which has got
him offtrack, unhealthy, eats food like maggi/bread most of the
time and all the hard work done by Petitioner since 2018 has been
wasted by her within 2-3 months.
59. That Petitioner worked hard on Arjun to ensure he speaks in
English as advised by his teachers during PTM. Petitioner and
Arjun worked really hard for this. Petitioner not only worked hard
on his english speaking skills but also helped him develop an
International accent. Petitioner build a culture of speaking in
English with Arjun all the time and advised Respondent to follow
the same. To this Respondent said "Ab Main IskeLiyeGhar Mein
English Mein Bolu". She paid no attention to the hard work put
my Father-Son and continued speaking with him in Hindi. This
behaviour of her created lot of tension in the home as Arjun was
becoming a victim of her thought process, preferences, etc. Since
March 21, Arjun is with Respondent and he is only talking in
 HIndi. When Petitioner asks him to speak in English then he is
reluctant because his confidence and command of the subject has
gone for a toss. This shows that she is not ready to change for the
sake of her child, this also shows her whimsical attitude, this also
shows that she is not ready to sacrifice her comfort and happiness
for the sake of the child.
60. That Respondent and her family is extremely unsocial
people. She has no friends, relatives, etc. As a result she doesn't
get any opportunity to socialise in the society, meet people, make
new friends, etc. On the other hand, Petitioner and his family are
extremely high on their social life surrounded with loads of
friends, relatives and even acquaintances. Respondent because of
her introvert and unsocial nature is reluctant to attend any social
events in which Petitioner and his family participates. She always
tries that Arjun should be restricted to follow any social events or
participate. She will try to keep Arjun away from Petitioner and
his family, social gatherings, events, functions, etc which is
extremely dangerous for his future. She wants Arjun to be isolated
and stay inhouse all the time. This shows her thought process is
against the social development of a child which will impact his
future. She needs to understand that Man is a Social Animal and
we are part of the society in many ways. According to her there is
nothing called a "SOCIETY".
61. That respondent has even disconnected Arjun from his best
friend DIVYAM whose parents has tried to reach out to
Respondent and Arjun in past few months to make Divyam speak
to Arjun. Today, Arjun is all alone and isolated. He has accepted
that isolation is part of life for him which is extremely dangerous
for his future as he has a long life ahead of him where he will be
required to interact with people and be part of the society. This
conduct of Respondent is a blatant effort of killing his childhood.
62. That Petitioner always helped Arjun with his studies,
presentation, nurture progressive thoughts, stay helpful and
charming. To ensure his confidence in public speaking, Petitioner
created a youtube channel for Arjun, purchased equipments
required to record his videos and made a list of topics as well.
Respondent did not like this idea and discouraged Arjun. As per
 her, public speaking is wastage of time and efforts. She made no
contributions in Arjun's development and learnings. Finally she
was successful in putting the idea of Petitioner for a toss and was
extremely happy about it. This shows that she has no love, care
and does not worry about the development of Arjun because that
needs sacrifice, time, dedication and intent of which she has
none.
63. That Until March 21, Arjun was extremely punctual about
his classes, but these days he does not login to his classes on
time, most of the time his camera is switched off and teacher
keeps calling Petitioner to understand why Arjun is not attending
classes on time. This shows that Respondent is busy with his
work and office and has left a little child Arjun on his own without
bothering about his studies, etc.
64. That during April, 21, Petitioner got infected by Covid 19 and
was on oxygen support. - All these points in WS, please refer.This
shows that she has no value for relationships that includes her
husband and Son. The same value and culture she will give to
Arjun going forward which will not be good for his future
relationships, society etc. She will make Arjun a rough and tough
boy who will have no room for family, emotions, sentiments,
feelings, etc. This will not only damage his future but will also
hamper his family life. This also shows that Respondent is very
practical, does not believe in relationships, and can quit any
relationship for her benefits or if under influence. She can dump
Arjun as well anytime the day he grows up and go against her
wishes. This is dangerous for the life of Arjun as he will never be
able to behave freely and work on his aspirations.
65. That admission - In 2016, We decided to put Arjun in a
formal school. Petitioner decided to put Arjun in the best School
of Noida which is Step by Step. Arjun's name was not shortlisted
for admission in the draw. Petitioner decided to give his best shot
by making all the efforts to get Arjun's admission in the school.
Respondent refused to make any efforts as she was busy with her
office and it involved a lot of run around in the city, outside city,
very strong network of people who could make recommendation to
the school and unfortunately she did not know anyone because of
 her introvert and unsocial attitude. Petitioner did all the run
around, met various ministers, business magnets and other
influential people in the government to get their
recommendations. In total there were 17 recommendations made
by various state ministers, Lok Sabha speaker, education minister
for state, etc but the school authorities refused to give admission
out of turn. Petitioner had to request, beg, run around in the
scorching summer to places like Lucknow, etc. Petitioner being a
concerned father invested all his time and efforts in this
admission drive, whereas, on the other hand Respondent was not
bothered about anything. She never made even a single phone call
to anyone for Arjun's admission. This shows her zero dedication,
zero commitment, zero desire and zero intent to work on Arjun's
life, career and development as a good human being.
66. That Post March 11, 2021, Petitioner made a lot of
observation related to the Arjun's studies, class participation, his
reluctance, laidback attitude, etc. Petitioner approached to the
School authorities for setting up a 30 minute feedback session.
School did not appreciate a parent asking questions to the school
for not focusing on Arjun's studies and involving him in the class.
Petitioner clearly told the school authorities that the development
of his child is not only dependent on school but also on the parent
feedback which school should take very seriously. Petitioner also
spoke about how Arjun can participate in the olympiad exams.
Petitioner has also indirectly told Respondent through Arjun to
devote time on Arjun's studies and prepare him for such
competitive exams which will help him work on the areas of
opportunity. Respondent very conveniently ignored the request
made by Petitioner and did not encourage Arjun to work upon his
prepartions. This shows that she is least interested in Arjun's
development and studies.
67. That Petitioner also made observations around the food habit
of Arjun where he is mostly seen eating bread, loads of chewing
gums, etc. We have always ensured that Arjun is not allowed to
eat candies like "Kinder Joy" as it consist of Cancerous elements,
Wax, Palm Olein Oil (Causes Heart Diseases), Gluten & Lecithin
(causes weight loss, nausea, dizziness & tiredness) etc and is
 completely banned in countries like US. Till the time Arjun was
with his father, he was never allowed to eat Kinder Joy but post
March 21, he has been eating Kinder Joy frequently and has
made collection of toys that comes in it. This shows that
Respondent has no concern left in her for Arjun's health, she is
careless and reluctant to follow certain mandates that are
important for the health of Arjun or else they will impose serious
life threat to him. Respondent is so busy in her office and career
that she is not at all bothered about the child development.
68. That most of the time it is Petitioner who pays Arjun’s
school fee and other expenses related to him.
69. That Arjun roam around in society alone after daycare. Can
be kidnapped - Respondent likes to keep Arjun in daycare for her
convenience & her busy schedule. Daycare leaves Arjun after 6.30
pm and he keeps roaming around in the society all alone.
Respondent finds it convenient and safe for the child to roam
around in the society. A small child of his age can be abducted,
kidnapped even in the society due to the free movement of the
visitors.
70. That the petitioner like to put this on record that once
Respondent took Arjun to swimming pool. She left Arjun on his
own and was busy with his mother on the phone call. Arjun fell in
the water with was 5 feet deep. Thankfully, the lifeguard saw him
and immediately came to his rescue. Arjun was extremely terrified
with this incident. With such an irresponsible attitude, he could
have drowned that day.
71. That Respondent would allow Arjun to make loud noise and
misbehave in a restaurant. He would sit on the tables of other
people where people are eating. If Petitioner tries to correct him or
objects then she will say so what if he is sitting there, he is not
eating their food which becomes very embarrassing and also
inculcates wrong habits in a child.
72. That She would encourage him to even eat without brushing
teeth as she also follow the same lot many times. According to her
if we can drink bed tea without brushing then why can’t we eat.
73. That respondent has no time, no work life balance, she
opens laptop at 8 am and Continues till 8 pm. Her parenting goals
 are of getting controlled instead of controlling. Being parent we
have to be soft, tough, persistent, stubborn for the welfare of
child. She develops wrong habits in him instead of teaching him
and preparing for life. A child should be made tough so that they
are able to handle the social.and academic pressure or else they
will surrender without putting up a fight. Never appreciate culture
of earning rewards, instead give him whatever he wants and as a
result today he says money is not a problem and we will get it
from bank account.
74. That petitioner worries about is that Petitioner has always
escorted Arjun and ensured all his interests are taken care of with
regards to his studies, sports, food, personality development,
social development, values, culture & other areas but ever since
Respondent has forcibly taken him, she has not been taking care
of any of these aspects which will only hamper his development,
social life, family life, health, mental development, etc.
Respondent has detained him within four walls and not allowing
him to see the outside world. It is just like putting a bird in the
cage & cutting its feather.
75. That Today he focus on what he will get without even
bothering about any emotional connect. His requirements are
fulfilled and he doesn’t want to think about how it is fulfilled,
which means no love, affection, care for the people he is with.
76. That respondent has no time, no work life balance, she
opens laptop at 8 am and continues till 8 pm. Her parenting goals
are of getting controlled instead of controlling. Being parent we
have to be soft, tough, persistent, stubborn for the welfare of
child. She develops wrong habits in him instead of teaching him
and preparing for life. A child should be made tough so that they
are able to handle the social.and academic pressure or else they
will surrender without putting up a fight. Never appreciate culture
of earning rewards, instead give him whatever he wants and as a
result today he says money is not a problem and we will get it
from bank account.
77. That is a violation of Arjun’s human & valued rights. He has
been illegally captivated by Respondent, claiming to be her
natural guardian whereas as per section 6 of the Hindu Minority
 & Guardianship Act clearly defines that it is the Father who is the
natural guardian of minor hindu male child.
78.