Sample gw Written Statement

IN THE COURT OF CIVIL AND FAMILY JUDGE AT KARACHI

(CENTRAL)

G & W Application No: 790 /2021

[APPLICANT NAME]

D/o [FATHER NAME]

Muslim, Adult, R/o Flat No.7-C/3

Ahram Centre, Block G, [AREA REDACTED]

Karachi -------------------------------------------------------- Applicant

Versus

[RESPONDENT NAME]

S/o [RESPONDENT FATHER NAME]

Muslim, Adult, R/o H.no 653/2, Block 2

Mohalla [AREA REDACTED] No.2

Karachi

The Public At Large ------------------------------------ Respondent(s)

Baby Leena Zahid

D/o [RESPONDENT NAME]

[MINOR 2 NAME]

S/o [RESPONDENT NAME] ----------------------------------------- minors/wards

WRITTEN STATEMENT ON BEHALF OF RESPONDENT

The respondent above named most respectfully submits as under:-

That the contents of para 1,2,3,4 and 5 of the plaint are not denied being the part of facts.

That the contents of para 6 are specifically and vehemently denied as the story narrated being concocted by the applicant. It is further submitted that the applicant left the house of respondent on her own will and never let the minors meet with the respondent being the real father of the minors. Further that the respondent had been paying the maintenance to the applicant for herself and for the minors since the day applicant left the house of respondent.

(Photocopies of the receipt of maintenance attached and marked herewith as annexure: )

That the contents of para 7 are specifically and vehemently denied. It is submitted that the applicant and her mother treat the minors in an ill-manner and that both the minors are deprived off father’s care and affection.

That the contents of para 8 are specifically and vehemently denied as the applicant has concealed the real facts from this Honorable Court and that the applicant has approached this Honourable Court with unclean hands.

That the contents of para 9 are specifically denied. It is submitted that due to non serious behaviour of the applicant and her family. The brought up of both the minors is being badly affected and that the welfare of both the minors clearly lies with the respondent. That it is pertinent to mention here that the applicant does not spend the a