BEFORE THE HONBLE COURT OF PRINCIPAL DISTRICT JUDGE ANANTNAG
IN THE CASE OF :
Sajad Ahmad Nengroo S/o Bashir Ahmad Nengroo
R/O Darigund Srigufwara Anantnag
( Applicant )
V/S
Fareeda Akher W/O Sajad Ahmad Nangroo
D/o Gh Rasool Padder R/O Sallar Anantnag
( Non applicant )
IN THE MATER OF ‘ Application with the prayer that applicant be allowed
to saw her minor daughter aged 3 years under the relevant provisions of
Guardian and wards act for the reasons appearing herein below .
MAY IT PLEASE YOUR HONOUR
The application is most humbly submitted as under :
1. That the applicant has been married with Non applicant/respondent
way back in 2016 in accordance to the injunctions of Holy Quran and
as per shariat , out of the said wedlock one child namely Mayira Jan
( MINOR ) has taken birth. The parties were living jointly in the
accommodation at Srigufwara Anantnag separate from the parents
of applicant .
2. That the behavior of the non applicant has not remained good
towards the applicant . The non applicant left the company of
applicant on the ground that she has to attend a marriage function
and took the minor with her and thereby till date has refused to
return back in the company of the applicant .
3. That the applicant tried his level best with the help of some senior
members of the society to persuade the non applicant but all in
vain.
4. That the non applicant and her relatives are not allowing the
applicant to meet the minor child . The non applicant is not taking
proper care of the child thereby spilling the carrier of the minor .
5. That the applicant being the father is worried about the welfare of
the minor.
6. That the applicant undertake that he will take proper care of the
child and on the eve of Eid wants to buy some clothes for minor .
7. That the paramount is to be given to the welfare of the child.
8. That the applicant tried so many times to visit the place of non
applicant and to see the minor as well as non applicant and was
harassed.
9. That this application is supported by an affidavit.
It is therefore prayed before this Hon’ble court that the
application of the applicant be allowed and non applicant be
directed to allow the applicant on the eve of Eid to see her minor
child and to have first hand information regarding the welfare of the
child . Further it is prayed that order be implemented through SHO
Srigufwara as the applicant has been time and again harassed and
twice beaten by the relatives of non applicant.
Dated; 27/7/2020
Applicant
Verification : Verified today on 27/7/2020 at Anantnag that the averments
made in the application are true and correct to the best of my knowledge
and belief and nothing has been concealed therein.
Applicant