visitation rights

1. That such and such main pet. ispending before this court an dis fixed for further hearing on such and such date.

2. That out of wedlock of the parties such and such (gender) child(s) were born on such and such date and now the child(s) is/are of such and such age. (attach birth certificate)

3. That the natural guardian and the child(s) have not meet from such and such date as the custody of the child(s) were forecefully removed by wife on such and such date in connivence of local area police and is not in welfare of the child(s)

4. That, since it is going to take sometime to finally dispose of main petition no. such and such the natural guardian begs before such and such court to allow visitation of the child in paramount welfare of child with his/her natural guardian.

5. That no prejudice would be caused to the mother, if the present Petition for visitation / meeting of natural guardian with parties child(S) is allowed.

6. Add paras related to grand parents here (age / education / females in family) etc..
....

Prayer

It is, therefore, most respectfully prayed that this Hon’ble Court may be please: -

I. The Petition be checked and registered in accordance to Rules.

II   It is humbly prayed before Hon’ble Court to allow issue of PF / RC. Notice, Email, Authorised Courier to mother returnable expeditiously in the interest of justice. In addition to allow Dasti notice as well as Affixation keeping in view visitation rights of minor child with grandparents and natural gauardian as paramount consideration. 

III. To grant access to Child(s) to the nataural guardian / grandparents on-

(a) all the weekends from Saturday 10 AM to Sunday 6 PM calculated door-to-door.

(b) the birthdays of child(s) and natural guardian / grandparents.

(c) the Muslim festivals such as ...........write names here

(d) the National holidays particularly 26th Jan. 15th August and 2nd October etc. to visit National Monuments along with child(s) being the child(s) coming out of illustrious academic family.

(e) the special occasions like marriage, functions, write here Muslim spl. occassions and ....as per the traditions of the Muslim family conducted time to time for welfare of the family and its members.

IV. To order access to child during the child’s school holidays / summer / winter vacations.

V. To allow child on family tours and trip with prior intimation to the Mother.

VI. To get the child medically examined from the child specialist.

VII. To permit applicants to visit the school and support the child in his/her education, sports and cultural activities.

VIII. To visit the child at his/her school functions such as Parent  - Teacher Meeting, School Day, Sports Day etc.

To grant such other relief as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case and in the welfare of the Child and interest of justice.

It is prayed accordingly.                                                                           

Rgds.