IN THE COURT OF xx
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PLAINT FILED U/s. 25 OF GUARDIANSHIP & WARDS ACT
R/w.6 OF HINDU MINIORITY & GUARDIANSHIP ACT.
I. Description of the Petitioner:
The address for service of summons, notices and processes of the
above named petitioner is that of the same as mentioned in the
Cause Title.
II. Description of the Respondent:
The address for service of summons, notices and processes of the
above named respondent is that of the same as mentioned in the
Cause Title.
III. Petitioner above named humbly submits as follows:
a) Petitioner submits that the petitioner got married with the
respondent on _______ at _____________
b) Petitioner submits that since the respondent and the
petitioner are employees as such their marriage is one of
convenience and there is no exchange of any amount,, articles,
jewellery between both the parties in connection of their marriage
except some customary gifts of clothes and gold rings and the
marriage expenses are shared by both the parties though initially
the expenditure is incurred by the petitioner but the same was
reimbursed by the respondent.
c) Petitioner submits that after the marriage the respondent
joined the petitioner in the joint family of petitioner for matrimonial
life and their marriage was duly consummated.
d) Petitioner submits that the petitioner lived with the
respondent happily but after some time the respondent at the
instigation of her relatives started pestering the petitioner to stay
separately and since the petitioner did not concerto her demand the
respondent left the company of the petitioner in the month of
___________ and stayed at her ________ house at _______________.
e) Petitioner submits that after some time there was a mediation
held at the house of the petitioner and at the instance of the
parents of the petitioner and on the demand of the respondent,
petitioner started living with the respondent separately at
___________ and petitioner further submits that in the month of
__________ respondent concede and the petitioner has taken all care
by providing her good medical care and petitioner also looked after
the respondent with love and affection.
f) Petitioner submits that the respondent somehow is not happy
for the reasons best known to her and used to pick up quarrels with
the petitioner for silly and petty causes and the respondent also
insisted the petitioner to totally abandon petitioner’s parents and
seek share in the ancestral property of the petitioner but the
petitioner did not yield to the demands of the respondent.
g) Petitioner submits that the respondent left with the house of
the petitioner on _________ by taking along with ____ tolas of gold
and Rs.___________ cash without intimating the petitioner and the
petitioner contacted the respondent and to come back but the
respondent did not show any interest as such the petitioner issued a
legal notice to the respondent on _______ which was received by the
respondent.
h) Petitioner submits that after receiving the legal notice
respondent’s family members arranged a meeting to resolve the
issue and wherein it was agreed by both the parties live happily and
as such respondent joined the petitioner in the month of __________
and after the respondent joined the petitioner the petitioner
enquired about the cash which was taken away by the respondent
immediately the respondent got provoke and abused the petitioner
in filthy language and left the house of the petitioner and lodged a
complaint against the petitioner U/s.498-A IPC., before WPS.,
__________ and the same was charge sheeted which is pending
before the Hon’ble _____________, vide [Link]._____________.
i) Petitioner submits that the respondent gave birth to a male
child on _____________ and there was no intimation to the petitioner
and petitioner is very much longing to see his first child and in fact
he conveyed message both personally and mediators that he is
ready to take back the respondent and the child even by loosing the
amounts taken by the respondent belonging to the petitioner.
j) Petitioner submits that the petitioner made all efforts to have
glimpse of the child that the petitioner is denied to see his child by
the respondent and her family members. Petitioner further submits
that the petitioner is having all rights to see his child and show his
love and affection towards the child and the respondent have no
right to deny the access of the child for the petitioner.
k) Petitioner submits that the petitioner is the natural guardian
and petitioner is in a position to engage people for proper welfare of
the child and petitioner undertakes that the petitioner will make all
efforts for the proper upbringing of the child and the petitioner’s
paramount consideration is the welfare of the child.
IV. Petitioner submits that the Cause of action for filing this
application arose in the month of __________ and which month the
respondent gave birth of a male child belonging to the petitioner.
V. Petitioner submits that the respondent is presently residing at
_____________ which falls within the territorial jurisdiction of this
Hon’ble Court and as such this Hon’ble Court is vested with powers
to try the petition.
VI. A Fixed Court Fee of Rs. _____ is paid under A.P.C.F.,& Suits
and Valuation Act.,
Petitioner therefore prays that this Hon’ble Court may be
pleased to grant a Decree of Custody of child to the petitioner and
the petitioner is a natural guardian of child, on such terms and
conditions, as this Hon’ble Court deems fit and proper, in the
interest of Justice.
Place: Hyderabad
Date: zz Petitioner
VERIFICATION
I xxx do hereby declare that the contents of this petition
are true and correct to the best of my knowledge, belief and
information after being understood and hence verified the same on
this day of zz at Hyderabad.
Place: Hyderabad.
Date:zz Petitioner
IN THE COURT OF HON’BLE
xx
[Link]. of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PLAINT FILED U/s. 25 OF
GUARDIANSHIP & WARDS ACT
R/w.6 OF HINDU MINIORITY &
GUARDIANSHIP ACT.
Filed on: zz
Filed by:
Radhical Global Attorneys,
P. Radhika Sharma,
Advocates & Associates,
#7, 2-16, Uppal X Road,
Uppal, Medchal-Malkajgiri
(D), Telangana-500039,
Cell: 8019600006
COUNSEL FOR PETITIONER
IN THE COURT OF xx
[Link]. OF 2025
IN
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
AFFIDAVIT
I, xxx do hereby sincerely and solemnly affirm and state on
oath as follows:
1. I am the petitioner herein as such I am well acquainted with the
facts of the case.
2. I stated that the contents of the main OP., may be read as
part and parcel of my affidavit in the Interim Application for visiting
rights to see my child.
3.
4.
I, therefore prays that this Hon’ble Court may be pleased to grant
visiting rights to see my child born on ___________, at the house of
the respondent, on such terms and conditions as this Hon’ble Court
deems fit and proper, in the interest of Justice.
Sworn and singed before me on
Deponent
this the zz
at Hyderabad.
Advocate :: Hyderabad
IN THE COURT OF xx
[Link]. OF 2025
IN
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED U/s.12 of GUARDIANSHIP & WARDS ACT
R/W. Sec. 151 of CPC.,
For the reasons stated in the accompanying affidavit, the
petitioner prays that this Hon’ble Court may be pleased to grant the
visiting rights to the petitioner to see his child who is in the custody
of respondent, on such terms and conditions as this Hon’ble Court
deems fit and proper, in the circumstances of the case, in the
interest of Justice.
Place: Hyderabad PETITIONER
Date: zz
COUNSEL FOR PETITIONER
IN THE COURT OF HON’BLE
xx
[Link]. OF 2025
IN
O.P No. of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED U/s.12 of
GUARDIANSHIP & WARDS ACT
R/W. Sec. 151 of CPC.,
Filed on: zz
Filed by:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X
Road, Uppal, Medchal-Malkajgiri
(D), Telangana-500039, Cell:
8019600006
COUNSEL FOR PETITIONER
IN THE COURT OF xx
[Link]. OF 2025
IN
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED UNDER ORDER-VI RULE-15(4) OF CPC.
I, xxx do hereby sincerely and solemnly affirm and state on
oath as follows:
That, I am the petitioner herein and I filed the above OP., for
the custody of minor child that the contents mentioned in the main
OP., and the Paras 1 to III (a) are true and correct to the best of my
knowledge and belief, hence verified.
Place: Hyderabad DEPONENT
Date: zz
COUNSEL FOR PETITIONER
IN THE COURT OF HON’BLE
xx
[Link]. OF 2025
IN
O.P No. of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED UNDER
ORDER-VI RULE-15(4) OF
CPC.
Filed on: zz
Filed by:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X
Road, Uppal, Medchal-Malkajgiri
(D), Telangana-500039, Cell:
8019600006
COUNSEL FOR PETITIONER
IN THE COURT OF xx
[Link]. OF 2025
IN
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
AFFIDAVIT
I, xxx, do hereby sincerely and solemnly affirm and state on
oath as follows:-
1. I am the petitioner herein as such I am well-acquainted
facts of the case.
2. I state that I am the petitioner in the above-mentioned OP., as
such I have no legal knowledge to conduct the case, as such I am
intending to take assistance of an Advocate to conduct my case
before this Hon’ble Court.
3. It is therefore prayed that this Hon'ble Court may be pleased
to permit me to appointing the counsel M/s Radhical Global
Attorneys, P. Radhika Sharma, Advocates & Associates, #7, 2-16,
Uppal X Road, Uppal, Medchal-Malkajgiri (D), Telangana-500039,
Cell: 8019600006 to defend and represent the above said case and
pass such other order or orders as this Hon'ble Court may deem fit
and proper in the interest of justice.
Sworn and signed before me
Deponent
On zz
At Hyderabad
Advocate: : Hyderabad
IN THE COURT OF xx
O.P No. Of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED UNDER SEC. 13 OF FAMILY COURT ACT
R/[Link].151 OF CPC
For the reasons stated in the accompanying affidavit, it is
prayed that this Hon'ble Court may be pleased to permit the
petitioner to appoint advocate M/s Radhical Global Attorneys, P.
Radhika Sharma, Advocates & Associates, #7, 2-16, Uppal X Road,
Uppal, Medchal-Malkajgiri (D), Telangana-500039, Cell: 8019600006
to defend and represent the above case on behalf of petitioner and
pass such other order or orders as this Hon'ble Court may deem fit
and proper in the interest of justice.
Place: Hyderabad Petitioner
Date: zz
Counsel for Petitioner
IN THE COURT OF HON’BLE
xx
[Link]. OF 2025
IN
O.P No. of 2025
BETWEEN:
xx
…PETITIONER
AND
yy
…RESPONDENT
PETITION FILED UNDER SEC. 13 OF
FAMILY COURT ACT, R/[Link].151 OF CPC.
Filed on: zz
Filed by:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X
Road, Uppal, Medchal-Malkajgiri
(D), Telangana-500039, Cell:
8019600006
COUNSEL FOR PETITIONER
FORM NO.10
(under Guardians and Wards Act,1890)
APPLICATION FOR THE APPOINTMENT OF MINOR GUARDIAN
Name, Sex, religion, date of birth and
1
ordinary residence of the minor
Nature, Situation and Approximate
2 value of The property if any of the
Minor
The name and residence of the person
3 having the custody of the possession
of the person or property of minor
What near relations the minor has
4
and where they live
Whether a guardian of the person or
property or both of the minor has been
5
appointed by any person entitled or
claiming to be entitled by the low
Whether an application has at any
time been made to this court or to any
6 other court with respect to the
guardianship of the person or property
of the minor.
Whether the application is for the
appointment or declaration of a
7
guardian of the person of the minor or
of his property or of both
Whether the application is for the
appointment or declaration of a
8
guardian of the person of the minor or
of his property or of both
Where the application is to declare a
9 person to be a guardian, the grounds
on which that person claims.
1 The cause which have led to the
0 making of the application
Such other particulars if any as may
1 be prescribed or as the nature of the
1 application renders it necessary to
state.
DECLARATION OF THE PERSON WILLING TO BE
GUARDIAN
I, xxx, do hereby declare as below:
I am the mother of the ____ year old child ________
I declare that I am willing and happy to be the guardian of my minor
child whose date of Birth is _________
I may kindly be appointed as the Guardian of my minor son.
Sworn and signed before me
Deponent
On zz
At Hyderabad
Advocate: : Hyderabad
yy
xx
Nature of process to
be issued for purpose
for which money is
deposited and order if
Date:zz
AND
any under which
deposit made.
BETWEEN:
Hyderabad
Name and Description
yy
of Person on whom or
on whose property the
process is to be
executed.
[Link].
purpose above mentioned.
FORM No.61
Village, Taluq, District,
Munsiff where process
is to be executed.
IN THE COURT OF THE xx
Distance in miles from
the court house
OF 2025
Travelling allowance to
and fro the Court House.
Advocate for Petitioner
Class of Allowance
(171 Payment into the Court of Cash/Process Fee Deposit)
AMOUNT
..Respondent/s
..Petitioner/s
It is requested that the sum of Rs.______ may be received from the
Allowance
Process
Subsistence
Fees
Expenses of Sale or
Commission
IN THE COURT OF THE
xx
[Link]. OF 2025
BETWEEN:
xx
….PETITIONER
AND
yy
RESPONDENT
PROCESS FORM
FILED ON: zz
FILED BY:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X
Road, Uppal, Medchal-Malkajgiri
(D), Telangana-500039, Cell:
8019600006
Advocate
ADVOCATE FOR PETITIONER
Form No.7 List of Document (Rule 9,10 &
62)
(Under Order VII, R.14 or Order XIII, R.1 of Code of Civil Procedure)
IN THE COURT OF THE xx
[Link]. of 2025
Between:
xx
…Petitioner
AND
yy
…Respondent
List of Documents filed by- Petitioner
Date if any
of
Description of
[Link] documents Parties to the Document
Document
vernacular in
English
1.
2.
3.
4.
5.
Date zz P. Radhika Sharma
Hyderabad Advocate for Petitioner/Petitioner
IN THE COURT OF THE
xx
[Link]. OF 2025
BETWEEN:
xx
….Petitioner
AND
yy
…Respondent
LIST OF DOCUMENTS
FILED ON: zz
FILED BY:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X
Road, Uppal, Medchal-Malkajgiri
(D), Telangana-500039, Cell:
8019600006
Advocate
Counsel for Petitioner
IN THE COURT OF THE xx
[Link]. OF 2025
BETWEEN:
xx
…. PETITIONER
AND
yy
…..RESPONDENT
I, xxx, do hereby appoint and retain
P. Radhika Sharma
Advocate
Advocate/s to appear for me/us in the above Suit/Appeal/Petition/Case and to
conduct and prosecute or defend the same and all proceedings that may be taken
in respect of any application for execution of any decree or order passed therein.
I/We empower my/our Advocate/s to appear in all miscellaneous proceedings in
the above suit or matter till all decrees or order are fully satisfied, or adjusted, to
compromise and obtain the return of documents and draw any money that might
be payable to me/us in the said suit or matter and I/We do further empower
my/our Advocate/s to accept on my/our behalf service of notice of all or any
appeal or petition filed in any court or appeal Reference or Revision with regard to
the said suit or matter before disposal of the same in Honourable Court.
I certified that the executant who is well acquainted with English, read this
Vakalatnama that the contents of this Vakalatnama were read out and explained
in Urdu/Hindi/Telugu to the executant he/she/they being unacquainted with
English, who appeared perfectly to understand the same and signed or put
his/her/their name or mark in my presence.
Identified by Sri _______________________________
Executed on zz ADVOCATE
At Hyderabad
IN THE COURT OF THE
xx
[Link]. OF 2025
BETWEEN:
xx
….PETITIONER
AND
yy
RESPONDENT
VAKALAT
ACCEPTED
FILED ON: zz
FILED BY:
Radhical Global Attorneys, P.
Radhika Sharma, Advocates &
Associates, #7, 2-16, Uppal X Road,
Uppal, Medchal-Malkajgiri (D),
Telangana-500039, Cell:
8019600006
Advocate
ADVOCATE FOR PETITIONER
