IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT
INDEX

S.NO. PARTICULARS PG. NO.

1. Memo of Parties 1-2

2. Petition under Section 7, 10 & 25 of The Guardian

and Wards Act, 1890 read with Section 6 of the
Hindu Minority and Guardianship Act, 1956 for 3-22
Declaration and Permanent Custody of the minor
children along with affidavit in support.

3. Application under Section 12 of The Guardian

and Wards Act, 1890 for the production of minor
23-29
children and for seeking interim custody of minor
children along with affidavit in support.

Place: New Delhi

Dated:
AMIT CHOUDHARY
ADVOCATE FOR PETITIONER
A-363, DEFENCE COLONY,
NEW DELHI-110024
MOB: -9717464364
D/2474/2013
amandhyaniadv@gmail.com
 1

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT

MEMO OF PARTIES

VINITA ARYA

R/o: - F-57, Kalyani Farms,

Jaunapur Village, Fifth Avenue,

Radhe Mohan Drive, New Delhi-110074 …PETITIONER

VERSUS

VICKEY CHAURASIA

(Petitioner’s Husband)

S/o: Jagat Kishore Chaurasia

R/o: 38, Kusum Marg,

DLF Phase-I, Gurugram,

 2

Haryana-122002 …RESPONDENT

P.S. Fatehpur Beri

Place: New Delhi

Dated:
AMIT CHOUDHARY
ADVOCATE FOR PETITIONER
A-363, DEFENCE COLONY,
NEW DELHI-110024
MOB: -9717464364
D/2474/2013
amandhyaniadv@gmail.com
 3

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT

PETITION UNDER SECTION 7, 10 & 25 OF THE GUARDIAN AND

WARDS ACT, 1890 READ WITH SECTION 6 OF THE HINDU

MINORITY AND GUARDIANSHIP ACT, 1956 FOR DECLARATION

AND PERMANENT CUSTODY OF THE MINOR CHILDREN

MOST RESPECTFULLY SHOWETH:

1. That the present petition is being filed for declaring the

petitioner as a guardian and for claiming the custody of the

minor children Miss Twinkle Chaurasia and Master Daivik

Chaurasia. The minor children and the daughter and son of the

petitioner having born out of the wedlock of the parties above

mentioned. The said minor children are Hindu by religion and

are ordinarily residing in the custody of their father, the

 4

respondent, at the house owned by the Petitioner & Respondent

at 38, Kusum Marg, DLF Phase-I, Gurugram, Haryana-122002.

2. That the brief facts which led to the filing of the present petition

are that marriage between the Petitioner and Respondent got

solemnized on 20.11.2003 at Noida in accordance with Hindu

Rites and customs and they cohabited as husband and wife

since then till 06.11.2020. Further, out of the said wedlock two

children namely Ms. Twinkle Chaurasia (16 years) and Master

Daivik Chaurasia (10 years) were born on 31.08.2005 and

08.03.2011 respectively.

3. That prior to her marriage, the Petitioner was living with her

parents in J-16, Sector-11, Noida, Uttar Pradesh and is now

staying at F-57, Kalyani Farms, Jaunapur Village, Fifth Avenue,

Radhe Mohan Drive, New Delhi-110074. After solemnization of

their marriage, Petitioner along with Respondent and his family

started living together in a joint family being their matrimonial

home in house bearing no. B-61, Sector-39, Noida, Uttar

Pradesh-201301 from 20.11.2003 i.e., from the date of marriage

till the year 2012 and thereafter, till the year 2018, Petitioner

and Respondent shifted to the house bearing no. B-180, Sector

 5

44, Noida, Uttar Pradesh-201301 where her in-laws used to

regularly visit them. At the time of separation in the year 2020,

Petitioner was living together with Respondent at 38, Kusum

Marg, DLF Phase-I, Gurugram, Haryana-122002, which as

mentioned herein-above, jointly owned by both Petitioner and

Respondent.

4. That the marriage between the Petitioner and the Respondent

was an arranged marriage and the ceremonies/functions were

performed with great pageantry in which huge amounts of

money were spent by the Petitioner’s father as wished for by the

Respondent and their family members.

5. That soon after the marriage, the petitioner had to weather the

storm in the matrimonial home since the respondent was a man

of aggressive and violent nature and he along with his family

members used to be quite habitual in picking up quarrel with

the petitioner and her family members at the slightest pretext.

The respondent had a very bad habit of losing his temperament

more often than not during which time he used to get very

aggressive, rude and violent. It is also not out of place to

mention here that the respondent in a fit of rage even used to

 6

physically assault the petitioner mercilessly and the petitioner

used to receive bruises needing medical attention. However, the

petitioner did not complain about the said behaviour of the

respondent since she always thought that wisdom might prevail

on the respondent some day. Suffice it to mention that being

possessed of an aggressive and provocative nature, the

respondent did not even stop short of even seeking assistance of

whatever objects that came his way in causing beatings to the

petitioner. He used to so rude and cruel towards the petitioner

that he did not even bother to take care of his bare minimum

family responsibilities. Moreover, the respondent did not even

hesitate to openly abuse the petitioner in front of her family

members which also went to the extent of inflicting beatings

upon the petitioner. Therefore, the behaviour of the respondent

left much to be desired as he continued to shower and inflict

cruelties in various ways upon the petitioner. On the contrary,

the petitioner continued to relent the indignities and atrocities

of the respondent with a faint hope that by the passage of time,

the respondent might improve upon his behaviour. Moreover,

with the birth of the elder child namely Miss Twinkle Chaurasia
 7

on 31.08.2005, the petitioner was quite hopeful about the

relations between the two improving. However, unfortunately

that was not to be and the petitioner being a family person,

continued to bear the brunt from the respondent. Rather, the

behaviour of the respondent also led to unpleasantness

amongst the family members of the petitioner including his

parents and brother qua the respondent as a result of which the

petitioner had to shift in 2018 along with the respondent and

their children Miss Twinkle Chaurasia and Master Daivik

Chaurasia to their house in Gurgaon.

6. Further, it is pertinent to mention herein that sister of the

Petitioner namely Mrs. Vinti Arya was married to the

Respondent’s brother, i.e., Mr. Sandeep Chaurasia. Both the

Petitioner and her sister were treated with utmost cruelty by the

Respondent and his family members.

7. It is relevant to submit herein that the Petitioner on her

honeymoon became aware as regards the past of the

Respondent, that he before his marriage was in a relationship

with one Ms. Priyanka and after marriage other than her was

also having an extramarital affair with Ms. Sonia, which created

 8

rift between the Petitioner and Respondent. The Respondent at

one point of the marriage, was even involved with and was

having an extramarital affair with the best friend of the

Petitioner, Mrs. Deepika, who was the mother of their son’s

classmate as well and on getting caught, shamelessly admitted

the same. The Petitioner was forced to keep quiet for the sake of

her kids who would have been badly traumatized with the same.

8. The Petitioner gave birth to her daughter, Twinkle Chaurasia

through a C-Section at a local hospital in Banaras where she

stayed for 15 days, during which time three operations were

done on her by the doctors. The Petitioner tried her best to

maintain harmony in her matrimonial home but as her in-1aws

were not at all happy with the birth of a girl child so they used

to create problems for her.

9. That it is relevant to point out herein that on one such occasion

in Banaras the Petitioner’s father-in-law after coming from office

with her brother-in-law, started saying to the daughter of

Petitioner’s sister that "Chalo Chachì Ko Goli Maar Dete Haín"

and he then took out his gun and fired a bullet but
 9

unfortunately the same hit the daughter of Petitioner’s sister in

the eye in turn permanently damaging her eye.

10. That during the year 2008 when the Petitioner was kept on

house arrest at her Noida home, in between which her daughter

suffered an injury for which she had to be hospitalized and as

the Petitioner was not allowed to take her anywhere and there

was no one at home, the injury became more infectious. The

Petitioner’s daughter was only taken to hospital after

Respondent came home due to which her daughter lost large

amount of blood.

11. That when the Petitioner got pregnant for the second time in

2009, her in-laws forced her to get the sex determination test of

the baby done. On her refusal to the same, the Respondent and

his family members badly quarrelled with and abused her with

filthy words. It is pertinent to mention herein that the

Respondent against Petitioner’s wishes then compelled her to

get the sex determination test done at a local hospital and after

the test results confirmed that Petitioner was carrying a girl

child after which she was pressurized to get an abortion done as

a result of which the Petitioner suffered grave mental trauma.

 10

12. That the matrimonial life of the parties went on with such highs

and lows before eventually, the younger minor child namely

Master Ritik was born on March, 2011. Unfortunately, there

was no change in the behaviour and attitude of the respondent

as he continued to torment the matrimonial home and the

petitioner became a submissive and subdued personality only

for the sake of her two children.

13. Further, Master Daivik Chaurasia i.e. the Petitioner’s son was

born with club foot disability, due to which the Petitioner did

not do anything for 3 years except for taking care of him, during

which time the Respondent never helped her take care of their

son. That it is pertinent to mention that due to the sheer

diligence and her unconditional love for her son, the Petitioner

managed to treat his condition of club foot with the help of a

surgery.

14. That eventually, after a lapse of almost 19 years, the marriage of

both the Petitioner and Respondent fell apart due to the

constant harassment and atrocities which was inflicted upon

the Petitioner and thereafter, Petitioner was thrown out of her

 11

matrimonial home. The Respondent did not allow Petitioner to

take the kids along with her which was heavily protested by her.

15. That the Petitioner is not being allowed to meet her children and

as and when she visits them, the guards who have been strictly

instructed by the Respondent, do not allow her to even enter the

house where the kids are residing with the Respondent. Even

during the birthday of her children, the Petitioner is not allowed

to even wish them or see them.

16. That however, the fact remains that the petitioner is deeply and

emotionally attached to her children and has put in every

possible effort to provide proper nurturing and caressing care

besides making a provision of all the amenities to live, even

though suffering continuously and having had enough of the

miseries caused by an irresponsible, uncouth and utterly cruel

behaviour of the Respondent. It is submitted that the

respondent has caused untold miseries to the petitioner which

cannot be expressed by any stretch of imagination and he has

left no stone unturned in ruining the petitioner both socially

and financially. Constant humiliation and torture at the hands

of the respondent continued unabated as his standard of

 12

behaviour fell from bad to worse. The petitioner was abused, ill-

treated and all types of unimaginable cruelties were showered

upon her during her stay at the matrimonial home. The

petitioner, on the contrary, has always endeavored to fulfill all

her matrimonial obligations by providing love, warmth and care

to the respondent but unfortunately the respondent has been

hopelessly amiss in performing any of his obligations towards

his wife as well as the minor children.

Both the children had immense love and affection for their

mother i.e. the petitioner because the petitioner used to devote

and spend maximum amount of time playing with them as well

as attending to each and every need of theirs.

17. Furthermore, Petitioner received a Section 9 petition under the

Hindu Marriage Act from the Gurugram court which was filed

by Respondent for restitution of conjugal rights, the same was

filed by him in order to further harass and with the sole

intention of painting a negative image of Petitioner in front of

her children. The Section 9 petition was however withdrawn by

the Respondent for reasons best known to the Respondent.

Furthermore, even during the time when Petitioner and

 13

Respondent cohabited together words like mobile mother, Chor,

Gavaar aurat, Characterless, Self centered, greedy etc. for

Petitioner were used on a daily basis in front of the kids by

Respondent, with the sole intention of painting Petitioner’s

negative image in front of them.

18. The Respondent is further also trying to manipulate both of the

kids against Petitioner, whenever she tries to call them, she is

not allowed to talk to them. The Respondent is trying to

distance the kids from Complainant by saying that she is a bad

and worthless mother who does not care about them. It is

pertinent to mention herein that in fact it is the Respondent

who is a careless dad as the Complainant on various instances

have received complaints from the school teachers of her son

that he is not interested in his studies, he tries to self-harm

himself and his father, i.e., the Respondent is not a good

influence upon him.

19. That towards the end of April 2018, Petitioner found out from

her son’s teachers that he was not coming to school as he was

not interested in his studies after which the Petitioner used to

take him to his school daily and used to stay with him ti1l the
 14

end. That one day around October, 2018 at night after

Respondent came home drunk, he started fighting and hitting

the guard when the Petitioner tried to save the guard, he started

accusing the Petitioner, in front of the children of having an

affair with him and in the wee hours of morning at around 2:30

AM, the Petitioner was thrown out of the house. When she tried

booking a cab for her mother’s home, he also broke the

Petitioner’s phone and continued fighting with her at the street

in front of the kids where he again hit the Petitioner and when

he realized that she would go to the police, he stopped her,

booked an uber and sent the Petitioner back to her mother’s

house

20. That further it is pertinent to mention that the Respondent is a

drunkard and also consumes prohibited substances on a

regular basis. He is in a habit of consuming alcohol on a daily

basis and is associated with the bad elements of the society.

Further, on numerous occasions the Respondent has consumed

alcohol and has passed out in the public as well as at his home.

It is evident that the said behaviour and habits have already

cast a bad influence upon the children and in order to protect

 15

the children from such evils and for their development and

upbringing the Petitioner has filed the present petition.

21. That the Respondent after separation is further also trying to

manipulate both of the kids against Petitioner and whenever she

tries to call them, she is not allowed to talk to them. The

Respondent is trying to distance the kids from Petitioner by

saying that she is a bad and worthless mother who does not

care about them. It is pertinent to mention herein that in fact it

is the Respondent who is a careless dad as the Petitioner on

various instances have received complaints from the school

teachers of her son that he is not interested in his studies, he

tries to self-harm himself and his father, i.e., the Respondent is

not a good influence upon him. In fact, the respondent is in a

habit of beating the minor children at the slightest excuse as a

result of which without the Petitioner their condition has gone

from bad to worse as they experience a lot of stress, insecurity

and trauma at the instance of their father i.e. the respondent.

22. That the Petitioner is employed in the company of her mother

and is residing at F-57, Kalyani Farms, Jaunapur Village, Fifth

Avenue, Radhe Mohan Drive, New Delhi-110074 i.e. the house

 16

provided by her mother. Further it is pertinent to mention that

the Respondent has not paid a single penny to the Petitioner till

date and despite the Petitioner being the joint owner of property

bearing no. 38, Kusum Marg, DLF Phase-I, Gurugram,

Haryana-122002 and property bearing No. B-21, Sector-85,

Noida, Uttar Pradesh-201301 which is owned by M/s. Ganpati

Clothings Private Limited of which the Petitioner is the 52%

shareholder and the Respondent is the 48% shareholder the

Respondent has filed to pay any money to the Petitioner.

Moreover, the Petitioner has a job wherein she leaves at 10AM

in the morning and is back home by 5PM thus, she can very

well take care of the children. It is apposite to mention that the

Respondent is usually out of the home till late for his work and

usually returns home drunk. Thus, the petitioner has the

requisite infrastructure to take care of all the needs of the minor

children in question besides providing the emotional security,

love and affection which is what the welfare of the minor child

requires.

23. That the composition of the family of the petitioner where she is

residing includes herself and her sister along with her daughter
 17

and her mother who is devoted to religious mindset. The

portion of the house where the petitioner is residing is

reasonably big having sufficient space and accommodation. The

daughter of elder sister of the petitioner as aforesaid, enjoys a

very good bonding with both the children of the Petitioner who

always look forward to meet and play with her. Besides this,

the petitioner has four more sisters. All the members of the

family of the petitioner as aforesaid enjoy a very good chemistry

with each other and keep on meeting over social gatherings and

get-togethers. Therefore, whenever there is a family get-together,

there is a lot of bonhomie and camaraderie amongst themselves.

On the contrary, the respondent is residing alone with the

children and is a habitual drunkard and a drug addict. It is

therefore submitted that keeping in view the status and the

environment of the family of the petitioner as well as other

attending facts and circumstances, the custody of the minor

children are liable to be transferred forthwith because the

petitioner can provide all the amenities coupled with care,

warmth and caressing love of the mother as well as their

maternal grand-mother.
 18

24. That the petitioner is the mother of the minor children and is

their natural guardian and is, therefore, liable to be declared as

such. The petitioner and her parents have been actively involved

in upbringing of the minor children since they were an infant.

The minor children have always preferred to live with the

petitioner and therefore their removal from the petitioner’s

custody are against their welfare and interests. It is therefore,

in the interest of the minor children Miss Twinkle Chaurasia

and Master Daivik Chaurasia to be returned to the custody of

the petitioner. The petitioner is the mother of children and is

well-educated. It is relevant to mention that the petitioner has

no interest adverse to the interest of the minor children. The

respondent however has a bad temper and he has also abused

and beaten the children like he has done to the Petitioner, on a

number of occasions. The respondent is also poisoning the mind

of the children against the petitioner. The petitioner submits

that it is in the paramount interest and welfare of the children

that custody of the children be delivered to the petitioner as she

is well and better equipped to take care of all the needs of the
 19

minor children. The petitioner would not have any objection to

the reasonable access of the respondent to the children.

25. That the Respondent has all throughout been poisoning the

young minds of the kids and persisted them in keeping them at

a distance from the Petitioner and her family members for fear

of them knowing about his extra marital affairs and violent

truth. Further, the Respondent has been imparting a very bad

lesson of morality and virtuosity of life to the children as day in

and day out both the children are made to hear and witness

loose talks between the Respondent and his girlfriends. That

such shameless acts of depravity and immorality are bound to

resonate on young minds of both the children.

26. That the children have been forced to stay with the Respondent

in an uncaring and hostile environment. The children are facing

complete neglect in their upbringing, cleanliness and education.

The Respondent is least concerned about personal hygiene and

dietary regimen of the children. Further, on one hand, cruel

treatment, gross neglect and hostile conditions constantly

confront the children where their miseries get compounded in

the face of ugly sights of their so-called father i.e., the

 20

Respondent leading an adulterous lifestyle whereas on the other

hand a healthy environment embellished with love, affection

and care with requisite conditions for fulfilment of their

educational aspirations/pursuits which is vitally essential for

their overall personality growth is with the Petitioner.

27. That the Petitioner is residing with the jurisdiction of the P.S.

Fatehpur Beri, Delhi which falls with the jurisdiction of this

Hon’ble court.

PRAYER

In view of the above enumerated facts and circumstances mentioned

hereinabove, it is most respectfully prayed that this Hon’ble Court be

pleased to;

a. allow the captioned petition; and

b. grant permanent custody of the minor children i.e. Miss Twinkle

Chaurasia and Master Daivik Chaurasia to the Petitioner; and

 21

c. Pass Such other and further order(s) as this Hon’ble Court

deems fit and just for proper adjudication of the captioned case

in favour of the Petitioner.

New Delhi

Dated:

PETITIONER

THROUGH

ADVOCATE

VERIFICATION:

I, the above named deponent do hereby verify that the contents of the

present petition are true to my knowledge and no part of it is false and

nothing material has been concealed thereon.

Verified in Delhi on __ day of ___________, 2021.

PETITIONER
 22

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT
AFFIDAVIT

Of, Mrs. Vinita Arya, aged about 38 years, Daughter of Mrs Chhaya
Devi, Resident of F-57, Kalyani Farms, Jaunapur Village, Fifth
Avenue, Radhe Mohan Drive, New Delhi-110074, do hereby solemnly
affirm and declare as under;
1. That I am Petitioner in the captioned case and being fully conversant
with the facts and circumstances of this case, I am competent to
depose this affidavit.
2. That the accompanying petition has been drafted under my
instructions and contents of the same are true and correct to my
knowledge and no part of the same is false.

DEPONENT
VERIFICATION:
Verified at New Delhi this _____ day of October, 2021 that the contents
of the above affidavit are true and correct to my knowledge and
nothing material has been concealed therefrom.

DEPONENT
 23

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT

APPLICATION UNDER SECTION 12 OF GUARDIAN AND WARDS

ACT, 1890 FOR THE PRODUCTION OF MINOR CHILDREN AND

FOR SEEKING INTERIM CUSTODY OF MINORS CHILDREN.

MOST RESPECTFULLY SHOWETH:

1. That the applicant has filed the accompanying petition for the

custody of the minor children to the petitioner, who is the

mother and the natural guardian of the minor children. The

detailed facts and submissions made in the accompanying

petition may kindly be read as part and parcel of this

application as the same are not being repeated for the sake of

brevity.
 24

2. That the minor child Ms. Twinkle Chaurasia (16 years) and

Master Daivik Chaurasia (10 years) were born on 31.08.2005

and 08.03.2011 respectively from the wedlock of the parties.

The said minor children are Hindu by religion and are

ordinarily residing in the custody of their father, the

Respondent.

3. That the said minor children are about 16 years and 10 years

old and do not own any moveable or immoveable property.

4. That it is in the interest of the children to be returned to the

custody of the applicant pending the disposal of the main

petition. The applicant is the mother of the children and is well

educated. Further, the Respondent is living an adulterous

lifestyle and is also a drunkard and habitually consumes drugs

and other illegal substances.

5. That at present the minor kids of Petitioner and Respondent

are in the custody of Respondent. That the Petitioner wants to

take custody of the minor children for their welfare and

upbringing.

6. That further, the Petitioner has received several complaints

from the teachers of Master Daivik Chaurasia that he has not

 25

been focussing on his studies and has been deviating his

attention from studies. That it is evident that the Respondent

has not been taking care of the children as he is at his own

zone and is involved in consuming alcohol on a regular basis.

7. Further time and again the children have received beating on

the slightest of issues in the hands of the Respondent which

has casted a serious dent on the upbringing and overall

development of the children. Moreover, the minor children have

been repeatedly and consistently requesting the petitioner to

allow them to reside with her as they do not wish to go to their

father’s house i.e. the respondent. In fact, as mentioned herein

above the respondent is in a habit of beating the minor

children at the slightest excuse as a result of which they

experience a lot of stress, insecurity and trauma at the

instance of their father i.e. the respondent. The welfare of the

minor children namely Miss Twinkle Chaurasia and Master

Daivik Chaurasia urgently requires that their custody be

handed over forthwith to the petitioner.

8. That the applicant submits that the interest and welfare of the

children lies in the custody of the petitioner and thus the minor
 26

children be delivered to the applicant pending the disposal of

the case. The applicant would not have any objection to the

reasonable access of the respondent to the children.

9. That since the minor children are studying in a school, their

academic requirements are not taken care of by the respondent

who does not devote any time either on the studies of the

children or spent time with them on their activities or any kind

of recreation. It is submitted that there is nobody to look after

the children except the respondent and thus the children are

utterly neglected and left on their own self thus exposing them

to the bitter uncertainties of future life. On the contrary, the

petitioner is an educated person who is residing where her

sisters and her mother regularly visit her at the address

mentioned above thus, is better suited to meet the

requirements of the minor children. The ambience and the

family environment of the petitioner is most conducive for the

upbringing of the minor children Miss Twinkle Chaurasia and

Master Daivik Chaurasia. It is therefore considered imperative

for the welfare and well-being of the minor children that the

interim custody may kindly be handed over to the applicant in

 27

view of the detailed facts and submissions mentioned in the

main petition which may kindly be taken into consideration for

the purposes of disposal of the present application.

10. That it is submitted that if the children are not immediately

produced and returned to the custody of the applicant, their

welfare and interest will be irreparably harmed.

11. That the applicant has a strong prima facie case and hopes to

succeed in the same and therefore in case necessary directions

for handing over interim custody of the minor children to the

applicant is not granted, the minor children shall suffer

irreparable loss and injury without any restitution therefrom.

PRAYER

In view of the above enumerated facts and circumstances mentioned

hereinabove:

A. It is, therefore, most respectfully prayed that this Hon’ble Court

may be pleased to direct the respondent to produce the minor

children in the Court and allow the petitioner to meet the child.

B. It is further most respectfully prayed that the children may be

delivered to the petitioner who is their mother and natural

guardian pending the disposal of the accompanying main

 28

petition, in the light of the facts and circumstances explained

hereinabove.

C. Any other relief, which this Hon’ble Court may deem fit and

proper in the facts and circumstances of the present case, be

also passed in favour of the applicant and against the

Respondent.

New Delhi

Dated:

APPLICANT / PETITIONER

THROUGH

RESPONDENT
 29

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURTS, SOUTH,

SAKET COURT
GUARDIANSHIP CASE NO. ______________ OF 2021
IN THE MATTER OF:
VINITA ARYA …PETITIONER
VERSUS
VICKEY CHAURASIA …RESPONDENT
AFFIDAVIT

Of, Mrs. Vinita Arya, aged about 38 years, Daughter of Mrs Chhaya
Devi, Resident of F-57, Kalyani Farms, Jaunapur Village, Fifth
Avenue, Radhe Mohan Drive, New Delhi-110074, do hereby solemnly
affirm and declare as under;
3. That I am Petitioner in the captioned case and being fully conversant
with the facts and circumstances of this case, I am competent to
depose this affidavit.
4. That the accompanying petition has been drafted under my
instructions and contents of the same are true and correct to my
knowledge and no part of the same is false.

DEPONENT
VERIFICATION:
Verified at New Delhi this _____ day of October, 2021 that the contents
of the above affidavit are true and correct to my knowledge and
nothing material has been concealed therefrom.

DEPONENT