IN THE COURT OF ______
______ Vs. _______
PETITION U/S __ OF THE ____
Application under section __ of the ____ for grant of custody of the children to the applicant /petitioner
RESPECTFULLY SHOWETH:
1- That the above noted petition is pending before this Hon’ble court and is fixed for ____.
2- That the petitioner was married with the respondent on ____ and out of the said wedlock ____ sons namely ____aged about ____years and ____aged about ____ years were born.
3- That on ____ the father of the respondent came to the house of the respondent with him alongwith both the minor children to her parental house and since then the respondent alongwith the minor children is living at her parental house. Then after a petition U/s ____ C.P.C. was filed by the respondent herself and on behalf of both the minor children and she is getting maintenance for herself and for the minor children from the applicant /petitioner. However the respondent alongwith both the minor children came to the house of the petitioner on ____ and started living with the petitioner. On ____ both the children got admission for their education in ____ and the petitioner was providing all the facilities to the respondent and both the children of their livelihood, education etc. but after some the respondent again left her matrimonial house in the month of ____. Inspite of that the respondent charged the amount of maintenance of herself and for both the children from the petitioner and she is still getting the maintenance allowances from the petitioner/applicant.
4- That the atmosphere of family of the petitioner is better than the family of the respondent and the petitioner has good reputation in the society. The applicant /petitioner is fully competent person who can provide the proper higher education, can properly take care and look after both the children, manage to provide good atmosphere and to provide the good atmosphere to their minor children.
5- That in these circumstances the custody of the children is liable to be given to the petitioner /applicant who is the natural guardian, next friend and father of both the minor children.
PRAYER
It is therefore, prayed that the application of the applicant/petitioner may kindly be accepted and the respondent may kindly be directed to handover both the minors children namely ____ to the applicant /petitioner in the interest of justice.
Dated : ____ APPLICANT/PETITIONER
Through counsel