IN THE
COURT OF ………………CIVIL AND FAMILY JUDGE AT KARACHI
GUARDIAN
& WARD APP. NO /2017
,
V/S
The Public At
large……………………………………Respondent
APPLICATION U/ S 7 & 10 OF GR
& WARD ACT
The
applicant above named most respectfully submits as under;
1.
That the applicant was married with Muhammad Khalid Zafar s/o Muhammad
Mustaqeem on 27.05.2004 according to Sunni Muslim Law at Karachi. Out of this
wedlock two minors were born namely Anusha Khalid and Muhammad Reyaan on 18.04.2007
& 22.05.2008 respectively.
Copies of birth certificates are filed as Annexure A
and B.
2.
That the applicant is the widow of Muhammad Khalid
Zafar s/o Muhammad Mustaqeem. Her Husband died on 24.09.2015.
Copy
of the death certificate is filed as Annexure-C
3.
That thereafter the applicant got second marriage with
Rashid Zafar s/o Muhammad Mustaqeem on 24-04-2017. Who is brother of deceased’s
Husband namely Muhammad Khalid Zaraf.
Copy of Nikah Nama is filed as
Annexure-D
4.
That the Applicant wants to go abroad with her
children who are in her custody. It is submitted that no property is in the
name of the minors.
5.
That No application has been moved prior to this
application in respect of the appointment of guardian in respect of the minor.
6.
That the there is no laches on part of applicant in
moving the said application. It is pertinent to state that the this Hon’ble
court has the jurisdiction to appoint the guardian of the minor which is in the
welfare of the minor.
7.
That the cause of action accrued to the applicant when
the minors were born, it again arose when the Applicant wanted to go abroad and
the same is continuing one.
8.
That this
PRAYER
The
applicant humbly prays that this Hon’ble court may please to;
a)
appoint the applicant Mst Mehwish Khalid wd/o Muhammad
Khalid Zafar as guardian of her minors Anusha
Zafar and Muhammad Reyaan.
b)
Declare that the welfare of the minor children Anusha
Zafar and Muhammad Reyaan lies with the
custody and guardianship of the applicant/petitioner and the guardian/
petitioner is entitled to apply for passport and thereafter take them to abroad.
c)
Any other relief which this
Dated: 10.2017 APPLICANT
ADVOCATE
FOR THE APPLICANT
VERIFICATION
I, .................................., Muslim, adult, r/o Karachi, do
hereby state and verify on oath that whatever is stated above is true and
correct to the best of my knowledge and belief.
DEPONENT
The deponent is identified by me.
ADVOCATE
Stated on oath before me this day of 20.The deponent is identified by
Mr. Ghulam Abbas, Advocate, who is personally known to me.
COMMISSIONER FOR TAKING
AFFIDAVITS
Documents filed;
Documents relief upon; Originals of the above and other relevant
Documents.
Address of the Applicant As in the title:
Address of the Advocate
Applicant
IN THE
COURT OF ………………CIVIL AND FAMILY JUDGE AT KARACHI
GUARDIAN
& WARD APP. NO /2017
Mst
Mehwish Khalid ………………………………….Applicant
V/S
The Public At
large……………………………………Respondent
AFFIDAVIT
OF WITNESS
I, ………………….son of……………….., Muslim,
adult, r/o
1.
That I am witness /deponent in the above matter and
am fully conversant with the facts of
the case.
2.
That I am uncle of Anusha Zafar and Muhammad Reyaan and I know her and her
family.
3.
That the applicant was
married with Muhammad Khalid Zafar s/o Muhammad Mustaqeem on 27.05.2004
according to Sunni Muslim Law at Karachi. Out of this wedlock two minors were born namely Anusha Khalid and Muhammad Reyaan on
18.04.2007 & 22.05.2008 respectively.
4.
That the minors are in custody of their mother i-e the
applicant.
5.
That whatever stated above is true and correct to the
best of my knowledge and belief.
Dated: 10.2017 DEPONENT
The deponent is identified by me.
ADVOCATE
IN THE
COURT OF ………………CIVIL AND FAMILY JUDGE AT KARACHI
GUARDIAN
& WARD APP. NO /2017
Mst
Mehwish Khalid ………………………………….Applicant
V/S
The Public At
large……………………………………Respondent
AFFIDAVIT
OF WITNESS
I, ………………….son of……………….., Muslim,
adult, r/o
6.
That I am witness /deponent in the above matter and
am fully conversant with the facts of
the case.
7.
That I am uncle of Anusha Zafar and Muhammad Reyaan and I know her and her
family.
8.
That the applicant was
married with Muhammad Khalid Zafar s/o Muhammad Mustaqeem on 27.05.2004
according to Sunni Muslim Law at Karachi. Out of this wedlock two minors were born namely Anusha Khalid and Muhammad Reyaan on
18.04.2007 & 22.05.2008 respectively.
9.
That the minors are in custody of their mother i-e the
applicant.
10.
That whatever stated above is true and correct to the
best of my knowledge and belief.
Dated: 10.2017 DEPONENT
The deponent is identified by me.
ADVOCATE
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