IN THE COURT OF CIVIL/GUARDIAN JUDGE (FAMILY DIVISION), SADIQABAD

Zahid Hussain S/O Abdul Hayye, Caste Aarain, R/O Jhang Road, House No.
364-P, Street No.2, Mohalla Ali Housing Colony, Faisal Abad, Tehsil and
District Faisal Abad. CNIC No. 33100-5574022-5

…Petitioner
Versus

1. Ammara Nosheen W/O Zahid Hussain,

2. Nazia Zahid D/O Zahid Hussain
3. Muhammad Ahmad S/O Zahid Hussain
Caste Aarain, R/O Chak No.25/NP, P/O Ahmad Pur Lamma, Tehsil
Sadiqabad, District Rahim Yar Khan.
…Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT

FOR THE CUSTODY OF MINORS/ RESPONDENTS NO. 2 TO 3.

Respectfully Sheweth,
1. That the petitioner was married with the Respondent No. 1 on 10.04.2015
in accordance with the Muslim Rites and after marriage the respondent
No. 1 started living with the petitioner as wife at his house in Faisal
Abad.
2. That the petitioner is a Motorcycle Mechanic and having good reputation
in his circle and belongs to a civilized family.
3. That in the beginning the relationship between the petitioner and
respondent No. 1 remained cordial and the petitioner always treated with
the respondent No. 1 with love and affection and provided all type of life
necessities to her. The petitioner was anxious to keep the wedlock intact
and afforded all types of facilities to respondent No. 1.
4. That the petitioner contacted the marriage with the respondent No. 1 in
accordance with the Shariat Muhammadi and always wanted to live his
life according to the teaching of Islam. In this regard, the petitioner time
and time again requested the respondent No. 1 to live her life as the Islam
Teaches and Preaches.
5. That after the marriage, the respondent No. 1 proved herself as an
undaunted lady, selfish, wayward/arrogant and a woman of willfulness,
however, the petitioner tried his level best for the betterment and in this
regard, left no stone unturned but in return, not even a single step is
taken by the respondent No. 1 for the betterment of the situation. The
respondent No. 1 intentionally by her conduct and behavior made the life
of the petitioner miserable, however, the petitioner bothered all this for the
sake of marital abode, for the honor of his family and also for the honor of
the family of the respondent No. 1 but it was the respondent No. 1, who
always proved herself as Disobedient from her conduct and behavior
and ultimately she without any cogent reason left the house of the
petitioner on 05.10.2021 and also took away Rs.100,000/- and 5 Tolas
Gold Ornaments which were given to the respondent No. 1 by the
petitioner.
6. That thereafter, the petitioner tried his level best for the AABADI but due
to the stubborn attitude of the petitioner and her family, in vain.
7. That from the period of GHAIR-AABADI, the minors / respondents No. 2 to
3 were in the custody of the respondent No. 1.
8. That the petitioner number of times tried to meet with the minors which
are in the custody of the respondent No. 1 but due to the stubbornness
and inflexible attitude of the family of the respondent No. 1, in vain.
9. That the petitioner being a father is lurking to embrace his minors and for
that purpose, the petitioner went to the house of the respondent No. 1 but
the respondent No. 1, her mother and other family members extended
threats of dire consequences to the petitioner and other family members
and refused to even allow the petitioner to see the minors. 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.
10. 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 city for slavery of kids and made them beggars.
11. 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 city
and the petitioner can never even see only an eye to his Children /
respondents No. 2 to 3.
12. 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 minors in the prevailing financial circumstances.

2. That the respondent NO. 1 is a lady of extreme emotions and mostly she
behaves like a psycho patient.

3. That the behavior of respondent’s family is disgusting with minors.

4. That the respondents were living with some other family in a house, where
they are dwelling and in that atmosphere the health of the minors were
depreciated.

5. That since the respondent No. 1 has left the house of the petitioner, from
that the petitioner number of times got the news of illness of the minors 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 minors will be
damaged from the environment existing in the house of the respondent No. 1.

7. That the father of the minors is in a position to well maintain them.

8. That father of the minors, in a position to give all the basic necessities of
life to the minors.

9. That it is in the paramount interest of the minors that their custody be

handed over to the petitioner. In short the welfare of the minors lies with the
petitioner.

10. That the cause of action occurred a few days earlier, when the
respondent’s family refused to allow the petitioner to meet his children 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 custody of the Minors/Respondent

No. 2 to 3 may graciously be handed over to the petitioner in the interest of
Justice. 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 minors may graciously be handed over to the petitioner.

Petitioner
Through Counsel

Shaikh Waheed Ahmad

Advocate High Court
VERIFICATION:
Verified on Oath at Sadiqabad on this day of 2023, that the contents of the
above Para’s are true and correct to the best of my knowledge and belief.

Petitioner

IN THE COURT OF CIVIL/GUARDIAN JUDGE (FAMILY DIVISION), SADIQABAD

Zahid Hussain Versus Mst. Ammara Nosheen, etc.

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY OF

MINORS/RESPONDENTS NO. 2 TO 3

APPLICATION UNDER SECTION 12 OF GUARDIAN AND WARDS ACT

Respectfully Sheweth,
1. That the petitioner filed the above captioned petition before this Honorable
Court, the contents of the same may be read as an integral part of this
application.

2. That the petitioner has a strong prime facie case and hopes to succeed in
it.

3. That the balance of convenience also lies in favor of the petitioner because
he is real father of the minors.

4. That if the interim relief is not granted to the petitioner, the petitioner and
wards would have to suffer an irreparable loss.

PRAYER
It is therefore, respectfully prayed that the instant Application u/s 12 of
Guardian and Wards Act 1890 may be accepted and the interim custody of
the minors may kindly be handed over to the petitioner, till the final decision
of the main petition.

It is further prayed that till the decision of the application for interim custody
the petitioner may kindly be allowed to meet the minors outside/inside the
court premises with the proper arrangement in a week.
 Petitioner
Through Counsel

Shaikh Waheed Ahmad

Advocate High Court
IN THE COURT OF CIVIL/GUARDIAN JUDGE (FAMILY DIVISION), SADIQABAD

Zahid Hussain Versus Mst. Ammara Nosheen, etc.

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY OF

MINORS/RESPONDENTS NO. 2 TO 3

AFFIDAVIT
That I, Zahid Hussain S/O Abdul Hayye, Caste Aarain, R/O Jhang Road,
House No. 364-P, Street No.2, Mohalla Ali Housing Colony, Faisal Abad,
Tehsil and District Faisal Abad. CNIC No. 33100-5574022-5 do hereby
solemnly declare as under;

That the deponent has filed above titled application u/s 25 of Guardian and
Wards Act 1890 before this Honorable Court the contents of the same are true
and correct to the best of my knowledge and belief and nothing has been
concealed therein.

Deponent

Verification
Verified on Oath that the above deposition is true and correct to the best of
my knowledge and belief and nothing has been concealed therein.

Deponent
IN THE COURT OF CIVIL/GUARDIAN JUDGE (FAMILY DIVISION), SADIQABAD

Zahid Hussain Versus Mst. Ammara Nosheen, etc.

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY OF

MINORS/RESPONDENTS NO. 2 TO 3

APPLICATION UNDER SECTION 12 OF GUARDIAN AND WARDS ACT

AFFIDAVIT
That I, Zahid Hussain S/O Abdul Hayye, Caste Aarain, R/O Jhang Road,
House No. 364-P, Street No.2, Mohalla Ali Housing Colony, Faisal Abad,
Tehsil and District Faisal Abad. CNIC No. 33100-5574022-5 do hereby
solemnly declare as under;

That the deponent has filed above titled application u/s 12 of Guardian and
Wards Act 1890 before this Honorable Court the contents of the same are true
and correct to the best of my knowledge and belief and nothing has been
concealed therein.

Deponent

Verification
Verified on Oath that the above deposition is true and correct to the best of
my knowledge and belief and nothing has been concealed therein.

Deponent
 IN THE COURT OF GUARDIAN JUDGE/CIVIL JUDGE, SADIQABAD.

Zahid Hussain
…Petitioner
Versus
Mst. Ammara Nosheen, etc
…Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY OF

MINORS/ RESPONDENTS NO. 2 TO 4.

APPLICATION FOR THE GRANT OF STAY.

Respectfully Sheweth,
1. That the petitioner filed the above captioned petition before this Honorable
Court, the contents of the same may be read as an integral part of this
application.
2. That the petitioner has a strong prime facie case and hopes to succeed in
it.
3. That the balance of convenience also lies in favor of the petitioner because
he is real father of the minors.
4. That the respondent No. 1 while making collusion with her other family
members intending to left the country for abroad Dubai and for this
purpose, the respondent No. 1 while changing the name of respondent No.
2 to 4 made passport and then applying for visa for Dubai with the
 respondent No. 2 to 4. Moreover, the respondent No. 1 and her other
family members also extended threats that they will left the country and
the petitioner can never even see only an eye to his daughters/
respondents No. 2 to 4, and in case the respondent NO. 1 succeeded in
her nefarious designs, the petitioner shall suffer irreparable loss.

PRAYER

In view of above, it is most humbly prayed that instant petition may please be
accepted. The respondent No. 1 may kindly be restrained from changing their
residence along with the minor from District Rahim Yar Khan to any other
District, country without prior permission of this Honorable Court, till the final
disposal of the main application u/s 25 of Guardian and Wards Act 1890, in
the interest of justice.

Petitioner
ThroughCounsel:
Shaikh Waheed Ahmad
Advocate
IN THE COURT OF GUARDIAN JUDGE/CIVIL JUDGE, SADIQABAD.

Syed Umair Gillani

…Petitioner
Versus
Mst. Irfana Khan, etc. …
Respondents

APPLICATION U/S 25 OF GUARDIAN AND WARDS ACT FOR THE CUSTODY OF

MINORS/ RESPONDENTS NO. 2 TO 4.

APPLICATION FOR THE GRANT OF STAY.

AFFIDAVIT
That I, Syed Umair Gillani S/O Syed Muhammad Latif Gillani R/O Chak
72/NP, Tehsil & District Rahim Yar Khan do hereby solemnly declare as
under.

That the deponent has filed above titled application u/s 25 of Guardian and
Wards act 1890 before this Honourable Court the contents of the same are
true and correct to the best of my knowledge and belief and nothing has been
concealed therein.

Deponent

Verification
Verified on Oath that the above deposition is true and correct to the best of
my knowledge and belief.

Deponent