Sample gw Exparte Proof

IN THE COURT OF XXVTH FAMILY JUDGE AT

KARACHI (EAST)

G & W Application No. 4097/2024

[APPLICANT NAME]

D/o [FATHER NAME]

Muslim, Adult R/o Commercial Area,

[AREA REDACTED], H.no: C-806, Block-02

Karachi……………………………………..Applicant

[MINOR NAME]

S/o [RESPONDENT NAME]

(Currently residing with applicant no.1)………… Minor

VERSUS

[RESPONDENT NAME]

S/o [RESPONDENT FATHER NAME]

R/o House no. 204, St. # 05,

Block-10 [AREA REDACTED],

Karachi……………………………………….... Respondent

EX PARTE PROOF ON BEHALF OF APPLICANT

The plaintiff above named respectfully submits as under:

That I say that the marriage was solemnized between the applicant and respondent on dated: ______________ at Karachi according to Muslim Personal laws, the nikkah was solemnized and duly registered in accordance with the provisions of muslim family laws ordinance 1961 against the dower amount of Rs.____________ /- (Rupees ___________only) further that the applicant sought decree of khula from honorable court vide order dated: 21/04/2016.

That I say that one issue was born out of this wedlock namely:

Mohammad Ibrahim

Son

Age: 11 years 7 months

That I say that both the applicant and respondent had been living separately from a long time. However, the respondent never made any attempt of communication or meeting with the minor.

That I say that the minor is currently residing with the applicant and that the applicant has herself borne all the expenses of the minor from birth till to date since the respondent never made any effort to maintain the minor.

That I say that it is pertinent to mention here that since the applicant is the real mother and natural guardian of the minor. The absence of the Guardianship Certificate has acted as a barrier and handicap in the welfare and well-being of the minor Muhammad Ibraheem. It is further submitted that the importance of the Guardianship certificate has further compounded since the visa/passport of the minor cannot be processed without the production of Guardianship certificate. The respondent being a careless and negligent father has never bothered to look into the serious nature of the problem and has flatly refused