The court reserved its order till November 25.
The woman from Goa and her Italian husband, who were appointed guardians of the child, had been fighting for the custody of the minor, who is currently living with the husband for past two-and-half years in Pune.
On June 11, 2010, the couple was granted guardianship of the girl by a family court in Pune.
However, they separated within a year and the wife continued to stay in her ancestral home at Goa, whereas the husband shifted to Pune.
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Rohan Cama, counsel for the wife, argued that in June 2011, the husband got an ex-parte (without hearing the other side) sole custody of the child.
"The wife was served with the notice but she could not visit Pune as her mother was ill and bed-ridden," argued Cama.
Only in July 2012, she learnt about the court order when he did not return with the child, the lawyer said.
The court was further informed that the husband had tried to take the child to Italy through Italian consulate. However, the consulate denied granting visa to the child saying that the mother has joint guardianship and her consent too would be required.