OBJECTIVE: intend to have the custody of the illegitimate child(girl), through unwedlock. Child age: 19 months.
1. met at dance bar 7 years ago-2002
2. formerly she has worked around 4 years, before she met me.
3. initially mere telephonic conversation for 2-3 months.
4. comes from a tribe known as BEDIA from M.P. at present her step brothers(3nos) having a licenced wine shop, running a matka/lottery, milk co-operative dairy even a grocery shop in the village and income is quite sufficient for their survival.
5. closeness developed, met every night after she finish her work at the hotel, and drop her at the place where she stayed as a paying guest along with native places girls who had their own house, which gradually led to the common decision to led a life together and I shall take all the responsibility of her and she would sent her earnings to her family members; and she would not indulge in going out with customer as other girls of her native places used to.
6. though engaged in prostitution, mere passed her last 4 years by sweet talks and false promises to customer, but never fulfilled it. And the loss of that customer led to a new one, and this continued.
7. till then whatever she had earned, every penny was sent to clear the huge debt incurred by her step-brother’gambling habits, father expired 2 years prior to arrival to Bombay, and she undertook and fulfilled the responsibility of the expenses for the marriage of a step brother(1).
8. after a passage of one year, I came to my knowledge that she is the daughter of a women who was brought by her father and her mother was in the same profession, stay in meerut brothels, who also had earned and sent to her father.
9. she was brought up by step-mother and stayed alongwith step brothers(3nos) in a village in Morena M.P.
10. prostitution is a tradition among this particular tribes and pursued as a familial occupation, daughter remain unmarried, this is going on since generation, clusters of houses in a particular village are full of families whose daughters are in mumbai.
11. around after 10 months, we started staying on rent together, were joined by her step mother alongwith us.
12. the relation moved ahead on basis of faith upon each other. Her mindset was pure, and kept her promise to refrain from going out with customer, but this was always opposed by her eldest step-brothers(half-blood) and step-mother. But it was embossed in her mind that should earn and give them and should believe that this step-brother and their wives would take care of her.
13. a prostitute attitude to stay and rely upon one man was hurting the intents of her family members and occasionally they would hammer that one day she would repent, and to rely upon one person would led her into a miserable life after the charm and attraction is over, instead she should go out with all and create a more economically stable conditions before she may become untradeable; or else such girls has to sent her daughter to the field of prostitution, since she did not saved money or did not think of economic dependency of her future.
14. as said and well known not a single male members works, and rely upon the girls who work in mumbai- it could be said that it is a society of CHASTE WIVES AND PROSTITUTE SISTERS
15. initially, we had mutually decided among each other that for the sake of economic security, a house would be brought in her name, but gradually looking at mine eco-social pattern, the step-brother started pressuring her that the house should be brought in their name, this was totally opposed by me for next 3 yrs. Instead I agreed to save 10000/- in the name of the girl till then I do not buy a house in her name, but unfortunately the family members chucked the saving which was done for 12 months, then I stop the savings.
16. but the good intent of the girl brought her all good, she attained all that wordly gains, good shelter, clothing and other stuffs, instead she did not possessed anything worth, before she met me. But the greed factors increased in the minds of the members of her family, she had been exploited since she came to mumbai for their personal needs, not a single penny was saved for her, but with me, she had the first opporutunity to have all that a girl instinct wishes, I have opened account in her name, demat account, a life insurance policy, a fixed deposit in her as well as in the name of the new-born of ours. Now even her own mother was brought back by us from meerut to the village, where other family stayed.
17. mine intent were clear, to make her happy and free her from the clutches of prostitution, twice her life was at verge of death, medically, when I saved her life with utmost medical treatment, one due to feminine problems in 2003, and secondly when we lost our twins in the 9th month of pregnancy.
18. saying clearly, since the day one of staying together, all that expenses incurred for staying together or her responsibility are performed by me
19. after the completion of 3 years, her own biological brother got married, all the expenses were borne by me, now I firmly decided to buy a house, at this junction , the family members the eldest step brother opposed and instead of buying a house; they preferred to fixed amount of 10000/- to be given to him for their household expenses.
20. but I was quite stubborn, to buy a house in the name of the girl only, then in sept2006, I brought a house in mumbai through a bank auction with 50:50 loan and cash.
21. within next 6 months, after the house was brought, here leftover step brother’s marriage was fixed up, and pressure was mounting upon her to contribute with a emotional blackmail that it was her responsibility, and they are the one who have brought her up since childhood, when her mother was working in meerut, somehow for the stability of the relationship, I contributed 50% of the expenses.
22. after that around aug 2007, after intense medical examination and treatment followed by renowned gynaecologist, she conceived for the second time, a child of mine and a baby daughter was born on 10.04.2008
23. one point to be noted, since beginning, wherever medical reports, treatments, procedure followed, everywhere she used my name and surname.
24. before the birth of the child, a plot of worth 6 lacs was brought, even prepayment of the loan amount was done for the house which was brought in her name; within 8-9 months of the possession of the flat, Ornaments once brought by me were sold and it were re-brought by me.
25. everthing a girl wishes, or her family members expects from her life partner, everything was done.
26. since the bar closed done 4yrs ago, girls do work but now in cheaper mode or in more quantity mode. One point that during the medical examination of the second time pregnancy, it was found that she suffers from syphilis(found through VDRL TEST), its deep investigation could be traced 5 years back which she had contacted from the first forceful customer, this disease could be said as veneral disease,or a stepping stone towards HIV if left untreated. So I took care that this problems should be solved, and she also underwent treatment. And this was the reason of the death of twins of first pregnancy. In such case too, I did not abandoned her, nor the family members do not have knowledge about it.
27. now , my background, myself a forensic expert in govt hospital, having a travel agency too, whereas late father was a manager in financial institution for 30 years, and brother a well recognized network manager in MNC, brother’s wife a solicitor till date, previous marriage broke down before I met her, have two daughters one studying clinical research and the other journalism, ex-wife settled in SOUTH AFRICA.
28. now since greed is intense among such tribes, after the birth of the child, interference in matters of child’s religion, and they starting forceful steps asking for financial support, they forced the girl to mortage the house which was loan-free, this was done with a promise that the instalment of the loan shall be borne by them, but within one month they betrayed the girl’s faith and asked her to pay the instalment for the loan from the money we save every month; or else she should go to hotel and work as a waitress- which is in disguise soliciting with the customer in a cheaper mode.
29. This was totally opposed by me openly; by writing a letter addressing her step brother expressing my opposition and raised voice against them that they were exploiting her for their ulterior motives of gaining money, thereafter sarcastically they used to torture the girl that she has betrayed them, although they were the one who brought her up since childhood. On the other hand been with me and regular exposure from my side regarding my ex-marriage’daughters academic records; always made her think that even our daughter would also grow with a academic father. Since they knew that I cared about the new-baby. Some how they made her feel guilty that I am not supporting them and ask her to come to the village in diwali season, she left on16.10.2009.
30. thereafter steps have been taken that there should be no communication between us, I have come to know from a close guys from the village itself, now everything is clear that they want the child to be left back in the village and she should earn for them in delhi-calcutta-and if at all in mumbai then by deserting me, OR else apply for a passport and go to dubai as other girls of the village are going.
31. for visiting my daughter and look upon their conditions I intended to visit the native place on 4th nov 2009, and I had been there, from this visit it could be gathered that they intend the mother to leave behind the our daughter and proceed to the new place for prostitution, with a ulterior motives that history repeats again, same equally as her mother had done.
In support of above written, I have the below following things to be shown and produced; as and when required. In all circumstances, I intend to live happily for them (the mother and daughter). But if any pressure or under some duress or may be mind hammering process by her step brothers, if she goes back on her stand. Then I would like to seek the custody of the child, being the biological father of the daughter. With the above objective to obtain the custody of the baby-child from such people. Looking at the above social structure of the girl, one can easily guess the future of the baby child. Everything said is true, and for its support I have all the documentary evidence, photos and lot other things.
Photographs since the beginning (incl family members while in mumbai)
Bank account in her name and the money send to her owners since beginning
Gold ornaments bills and receipt
All medical reports
Income tax file and returns for last 7 years( made for acquiring home loan)
Life insurance policy
Fixed deposit in the name of the daughter
Daughter birth certificate in my name
Hospital authorization during emergency signed by me
New daughter photographs (even along with my former daughters)
Child medical report( paediatrician prescription)
Former daughter all academic reports( top ranker in her college and school-days)
Photographs of religious ceremony conducted at their native place during pregnancy
Some of the factors that are considered when the court makes a custody determination are: (1) emotional and physical environment; (2) the personal safety of the child; (3) moral atmosphere of the household; (4) the mental and physical health of the parents; (5) the age of the children; (6) the age of the children; (7) preference of the child; (8) the prior behavior of the parents, including any history of abuse; (9) the ability of each parent to care for the child; (10) and the importance of religious upbringing within the family, and whatever is the best for the future of the child.
I need your say, thanking for the support I have received from your side