IN THE HON’BLE COURT OF ___________________

In the Matter of :-
XXXXXX … Applicant/Respondent
Versus
XXXXXXXX … Respondents/Applicant
Application u/s 25 of guardian and wards act 1890 for
the custody of minor child XXXXX to the applicant
who is now the custody of the Respondents.
******
Application for strike off the name in application u/s
25 as array of the parties as Respondent no. 2 &
3/Applicants in the Interest of justice.

MOST RESPECTFULLY SHOWETH:-

1. That the above mentioned matter is pending and fixed for today and

Respondent No. 2 &3 /Applicants are senior citizen and having aged

about 70 years and respondent no. 2 is suffering from diabetes due to

that he is facing retinopathy problem and damaged their eye sight. So

they are too week as he never walked without any support/help and

respondent No. 3 is facing heart diseases and their treatment is going

on PGI Chandigarh.

2. That the applicant/answering respondent and her father namely

XXXXXXX have grabbed the property of Respondent no. 2 &

3/Applicants and applicant has planted false purported FIR no.

 XXXX Dated XXXX u/s XXXX IPC section 12 PW DV act 2005 as

the applicant is a radio jokey cum practicing advocate at Bathinda

3. That the Respondent N. 2 &3/Applicants are wondering here and

there for the last 2 years in their relatives and applicant/answering

respondent has illegally grabbed the house of Respondent No. 2 &3 /

Applicant.

4. That the Respondent no. 2 & 3/Applicants have no concern regarding

the custody of minor ABC, because they are not residing with

Respondent no. 1 as the behavior of applicant towards Respondent no.

2 & 3 is not good, after the few days of marriage of applicant and she

beaten the Respondent No.2 & 3, but Respondent no. 2 & 3/Applicants

was kept mum due to the save of matrimonial life of Respondent no. 1

and Applicant.

5. That the cruel behavior of the Applicant has day to day increased

toward the Respondent no. 2 & 3/Applicants. Thereafter the

Respondent no. 2 & 3/Applicants has done separation and given the

old house i.e. "xxxxxxxxxxxxxxxxxxx" to Respondent no. 1 &

Applicant.

6. That the applicant is a greedy lady and she is an advocate so, she

openly stated as she knows the law and tools of law, manipulation

which is required to obtain good orders and she is stating openly that

she will sell the property to any third party only on the basis of

possession as by disclosing that her father is grabber and facing

various FIR’s regarding the grabbing of the land. The FIR(s) details

are reproduced here below:-

 Sr. FIR(s) No. Dated Particulars
No.
I. Xxx Xxxxxx Xxxx
II. Xxx Xxxxx Xxxx
III. Xxx Xxxx Xxxxx
7. That the Applicant/answering respondent has forcible grabbed the

property of Respondent no 2 & 3/Applicants and she is high handed

due to radio jokey and she did domestic violence with Respondent no

2 & 3/Applicants.

PRAYER

It is therefore Most Respectfully Prayed for Petitioners before this

Hon'ble Court may graciously be pleased to:-

a) To allow the Application for strike off the name in application

u/s 25 as array of the parties as Respondent no. 2 &

3/Applicants in the Interest of justice.

b) To any other directions to which this Hon’ble Court may be

deemed fit and proper in the facts and circumstances of the

present case

Dated :- 02.03.2021 Submitted by:-

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.

….Respondent no 2

xxxxxxxxxxxxxxxxxxxxxxxxxxx.

….Respondent no 3

Through Counsel
IN THE HON’BLE COURT OF xxxxxxxxxxxxxxxxxxxxxxx
GW/xxx/xxxx

Affidavit
Xxxxxxxxxxx … Applicant
Versus
Xxxxxxxxxx … Respondents

I, xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx signing the

affidavit on the behalf of Respondent no 2 & 3 and Manmohan Kaur do hereby
solemnly affirm and declare as under:-

1. That the contents of the Application are drafted by my counsel as per

my instructions and the same true and correct as per my best
knowledge whereas rest of the para true as per information received
and believed to be true.
2. That all the contents of the Application and documents attached may
kindly be read as part of this affidavit.

Date:-02.03.2021 Deponent

Verification:-

I, the above named deponent, do hereby solemnly affirm and

declare that the above statement of mine is true and correct to the best of my

knowledge and belief. Nothing has been concealed therein.

Date:-02.03.2021 Deponent