IN THE COURT OF CIVIL & FAMILY
JUDGE NO X KARACHI EAST
Guardian & Ward Application No. 574 of 2015
Mst Farah Naz……………………………….................Applicant
VERSUS
Muhammad Asif……………………………….......Respondent
WRITTEN STATEMENT
The Respondent respectfully submit his written statement as
under:-
1. That the contents of Para No 1 of the plaint is admitted.
2. That the contents of Para No 2 of the plaint are partly
admitted and partly denied.
3. That the contents of Para No 3 of the plaint are partly
admitted and partly denied.
4. That the contents of Para No 4 & 5 of the plaint are
vehemently denied.
5. That the contents of Para No 7 of the plaint is vehemently
denied and further stated that the above name respondent already
appoint as guardian by the Court of Family Judge Hyderabad in
Guardian Application No 44/2010 Ex-parte order was passed on 18-03-
2011 in favour of respondent but the Applicant willfully misguided to
this Honourbale Court and filed same application and suppressed the
real facts the above matter has been decided by the Honourbale Family
Judge Hyderabad and the applicant willfully avoided to produced the
minor at Guardian Court/Honourable Family Judge Hyderabad and also
avoiding to handover the custody of minor namely Ashan to the
respondent and the Applicant playing palled tactics with this
Honourbale Court.
6. That the contents of Para No 8 of the plaint are vehemently
denied and further stated that the above matter has already been
decided in Honourable Guardian Court/Family Judge Hyderabad in
Guardian Application No 44/2010.
7. That the contents of Para No 10 of the plaint are denied and
further submitted that respondent is working as labourer in Textile Mill
and earning upto Rs 15000/- per month at residing at rented house at
the rent of Rs 8000/- per month.
8. That the contents of Para No 9 of the plaint are vehemently
denied.
9. That the contents of Para No 10 of the plaint are vehemently
denied.
10. That the contents of Para No 11 of the plaint are vehemently
denied.
11. That the contents of Para No 12 of the plaint are vehemently
denied.
12. That the contents of Para No 13 of the plaint are vehemently
denied.
13. That the contents of Para No 14 of the plaint are vehemently
denied.
14. That the contents of Para No 15 of the plaint is no comments
being legal.
REPLY OF PRAYERS
Applicant is not entitled to claim any relief from the Honourable
Court including prayers A to B due to the above matter already
decided by the Honourable Court of Family Judge Hyderabad on
18-03-2011 in G.A No 44/2010 in favour of respondent Copy of
the above said Ex-Parte Order is attached herewith and the
applicant suppressed the facts in above application and willfully
misguided to this Honorable Court therefore the above
application is liable to be dismissed with cost
Karachi
Dated: -09-2015
VERIFICATION
I, Muhammad Asif S/o Muhammad Shafi, Muslim,
adult, R/o House No 239, Qaid-e-Azam Colony, Unit No 11, Latifabad,
Hyderabad, whatever stated above is all true and correct to the best of
my knowledge and belief.
Karachi
Dated: -09-2015 DEPONENT
The deponent is identified by me to the Commissioner for
taking affidavit.
ADVOCATE
Solemnly affirmed on oath before me on this _____ day of
September 2015, by the deponent above named, who has been
identified by Mr. Muhammad Shafique Khan Advocate, who is
personally known to me.
COMMISSIONER FOR TAKING AFFIDAVIT.
The contents of the affidavit were first truly and audibly
read over and explained to the deponent above named and he seems to
have fully understood the same and signed in my presence.
COMMISSIONER FOR TAKING AFFIDAVIT.
DOCUMENTS FILED:
1. Photo Copy of Ex-Partee Order of G.A No 44/2010 dated 18-03-
2011 passed by the Honourable Family Judge Hyderabad
2. Photo Copy of Receipts of maintenance payment deposited by
the respondent
ADVOCATE
FOR RESPONDENT
