LCI Learning

Share on Facebook

Share on Twitter

Share on LinkedIn

Share on Email

Share More

stanley (Freedom)     15 October 2012

Purshis in visitation

 

Tackling IA of visitation vide purshis in order to end the the agitating nature of the opp counsel  . Your most valuable suggestions and criticism would be highly acknowledged  and taken sportingly 

 

BEFORE THE HON’BLE                  AT……       

                                                   Purshis     Cr. M.A. No. X/XXXX

----------------                                                         ---Applicant

       V/S

---------------                                                         --- Respondent

 

Purshis  in the matter of Interim visitation

1.       The respondent has submitted his application 2 months back asking for visitation U/S 21 of the act  for visitation under supervision .

2.       The respondent has submitted child access and custody guidelines approved by the Bombay high court and the convention of child rights 1989 which has been ratified and adopted by india.

3.       The respondent has submitted the attendance sheet of the child wherein welfare of the child is neglected on moral and religious grounds .

4.       The respondent has produced  a supreme court judgement where visitation has been  granted under DV act .

5.       The applicants counsel has only been agitating for the past few hearings not to grant Interim visitation till the pendency of the trial .

6.       The respondent has submitted his written argument and  has argued orally on the mentioned subject of visitation that even criminals are granted visitation under supervision and that this respondent is not even a criminal .

7.       The applicants counsel hs been dictating rather than pleading that visitation should not be granted due to various allegations which has not yet been proved till date or else the  very purpose of the PWDV Act if granted than the entire purpose of the PWDVACT would be nullified .

8.       The respondent hereby seeks leave of this hon’ ble court and request the  applicants counsel to sumbit an affidivat in the above matter of Interim visitation that there exists a law in the Indian judicial system which  states that interim visitation under supervision cannot be granted during pendency of the trial .

 

Respondent

Date :-



Learning

 3 Replies

Tajobsindia (Senior Partner )     15 October 2012

he he

- it is a good one brother. You are making full use of .......

Also "close" the Purshis at the end by a sentence. It is mentioned in my THAT post itself.

stanley (Freedom)     15 October 2012

off course Mr Tajobs i have been making full use of your posts  wherein you have explained how to file a Purshis in detail for lay people like us . I would apperciate if the close of the Purshis can come from your end . I am determined to go for the kill :)

Never Give Up (Fighter)     16 October 2012

Stanley...

 

I appreciate your fighting spirit and level headed legal approach to fight back ..After this purshis even judge would have to think legaly on your visitation requests..probably he will refer some of the journals and bare law :-)


Leave a reply

Your are not logged in . Please login to post replies

Click here to Login / Register