Banned from traveling

Mr. Professor / President of the Court ………… for temporary matters

After Greetings ,,

Introduction to your Excellency Mr. ………………………… and resident in ………………………. His place is the Mukhtar, the Dar Al Qanoon Group for Law Firm, Arbitration and Training, represented by Professors / Rami Saeed Tawfiq and his fame (Rami Al-Sejiny) - Tamer Adel Mahmoud Al-Sharshaby (and famously Tamer Al-Sharshaby) - Hani Adel Mahmoud Al-Sharhaby (known as Hani Al-Sharhaby) - Muhammad Ali Hassan - Ibrahim Sayed Nair And his fame is (Ibrahim Nair) - Mahmoud Ali Radwan and his fame (Mahmoud Al Batouri) - Ibrahim Abdel Rahman Al Feki - Wadyan Numan Mustafa - Muhammad Khaled Mahmoud - Mahmoud Abdel Wahab Abdel Halim Al Mahamoun, located in 3 A Hob El Din Street - Al Sefarat Neighborhood - Nasr City - Cairo .

Against

First: - Mrs. / ………………………. And the Resident …………………… - Cairo

Second: - Mr. / Minister of Interior in his capacity

Third: - Mr. / Head of Passports, Travel and Immigration Authority in his capacity.

Subject

The student was a husband to the first announcer with a valid legal marriage contract, and he entered into with her and cohabitated with her husbands and gave birth to her on the marital bed of the child (.......) born ....... / ..... / .. but it is on date ............................................................................................................................................................................................................................................................................................................................................................................................... who is the first person announced a divorce, a divorce, due to the large number of marital disputes and the impossibility of ten between them.

And as the student learned that the first advertiser had taken the procedures for her to travel abroad, she and the young one (.........), without the prior consent of the student (the father of the child), which could affect the student with material and moral damages because he did not see the young, as the student always seeks To preserve, correct and educate the child in accordance with good customs, values ​​and morals, and when the child is (.........) his age does not exceed ............... years, any child who is not discerning and aware and was The student is the natural guardian over his minor son, in money and soul, and what was meant by guardianship over the soul was that it “is an authority that the guardian possesses over the guardian over him, enabling him to marry him, discipline him, teach him, treat him, and take care of him in all that he himself needs as long as he is under guardianship. 3/55 and beyond "and the first declared denial of the student to seeing the young child after traveling abroad to a place that the student does not know may result in preventing the student from exercising his tutelage over his minor son, which is a matter that will result in severe harm to both the student and the youngster. The first advertised to the young person outside the country without the knowledge or prior approval of the applicant is a matter that contravenes the Sharia To God then what the law settled on, which led the student to submit a request to prevent the child (........) from traveling outside the country based on the following:

The first article of Law No. (1) of 2000 stipulated the issuance of the Law Regulating Certain Situations and Procedures for Litigation in Personal Status Matters, the second paragraph in the fifth clause thereof that “the judge of temporary matters shall have jurisdiction in the court of first instance without any jealousy to issue an order on a petition in disputes about travel abroad After hearing the statements of those concerned. "

Article 3 also states in its last paragraph of Law No. 10 of 2004 “It is also competent, exclusively, to issue an order on a petition in the matters stipulated in Article 1 of the articles of issuance of Law No. 1 of 2000, in his capacity as a judge of temporary matters.

Article 7 of Child Law No. 12 of 1996 and amended by Law No. 126 of 2008 also stipulated that “every child enjoys all legal rights, and in particular his right to breastfeeding, custody, food, clothing, housing, seeing his parents and taking care of his money, in accordance with the laws on personal status.”

Therefore

We ask you, after reviewing the application and the attached documents, to issue an order prohibiting the youngster (...........) from traveling outside the country except after the approval of the student, in fear of him and in order to preserve his future

And Yours sincerely