Sample gw Objection Visitation

IN THE COURT OF CIVIL AND FAMILY JUDGE AT KARACHI

SOUTH

G&W: 291/2022

[APPLICANT NAME] ………………………………………… Applicant

Versus

[RESPONDENT NAME] ……………………………………….. Respondent

OBJECTION TO APPLICATION FOR CANCELLATION OF VISITATION RIGHTS OF APPLICANT

It is respectfully submitted on behalf of the Applicant, named above, that this Hon’ble Court may be pleased to hold that the Application for cancellation of visitation rights of applicant, filed by the Respondent, is not maintainable, and dismiss the same in limine, on considering the following legal points:-

That the contents of para 1 are only admitted to the extent of the filing of application under section 12 of guardian and wards act. Rest is patently false, hence it is vehemently denied.

That the contents of para no.2 of the application are procedural and need no comment.

That the contents of para 3 are reiterated and reaffirmed that the meetings of the applicant with the minor were held inside the court premises. That the applicant also filed an application for the grant of virtual meeting of the minor with the applicant. However, respondent has miserably failed to do so and has deprived off the minor from the fatherly affection and care.

That the contents of para no.4 and para.5 are false, fabricated and vehemently denied. That the applicant had always been attending the meeting with the minor inside court premises. However, the respondent out of hatred did not let the minor meet with the applicant.

That the contents of para no.6 are applicant is the real and biological father of the ward namely ([MINOR NAME]). Hence, it is a recognizing principle that the question of custody of the visitation schedule cannot be determined solely by deduction from the rule of law rather it exercise of judicial discretion dependent upon relevant facts and circumstances. It is further submitted that to deprive the father from the meeting with the minor is not only harsh and cruel but against the welfare and interest of the minor. That since from such ill-act by the respondent may further be influenced and brain washed against her father which might cause the relationship of a father and a daughter a