Plaint of Family Suit

In the Court of Senior Assistant Judge and
Family Court, Chittagong

Family suit No-34\19
Fahima Akther , w\o- Ainul Huda, D\o- Abdus samad

54, college Road, P.s. -Kotwali, Chittagong.
….………. Plaintiff
Versus
1. Ainul Huda , S\O –Jasim Uddin , 69,Natun Bazar, P\S-kotwali, Chittagong.

2. Jasim Uddin,S\O-Late Mirazul Alam,69,Natun Bazar, P\S-kotwali, Chittagong.
….…. Defendants
Suit for Recovery of Dower and Maintenance
Suit valued at TK 7, 40,000/-

The plaintiff named above begs to submit as follows:
1. That the plaintiff is coming from a middle class respectable Muslim

family. She is a simple, polite and amiable lady.
2. That on 20.08.2018 marriage between plaintiff and defendant No-1

was solemnized under Muslim law by registered Nikah Nama (Marriage
deed). Thereafter, marriage ceremony was held on 04.10.2018 as per
consensus amongst relatives of both plaintiff and defendants. Plaintiff’s
father spent a huge amount of money to entertain guests on the side of
bride-groom and other guests. It is to be mentioned that on the day of
marriage ceremony a lot of valuables things like Television, Refrigerator,
full-set household furniture, gold ornaments, dressings of bride-groom
etc. were given as presentations by the relatives of the plaintiff and all
these were taken to defendants’ residence. That 04.10.2018, the day
marriage was held, plaintiff went to defendant No 1’s residence dreaming
of a happy conjugal life.
3. That in nikah nama dower was fixed at Taka 5,00,000(Five Lack) out
of which Tk 1,00,000(One Lack) was shown paid. The rest amount was
divided at Tk 3, 00,000(Three Lack) and 1,00,000(One Lack) as prompt
dower and deferred dower respectively. No fixed amount of monthly
maintenance was specified in the nikah nama. But it was settled that the
amount of monthly maintenance would be fixed in future on the basis of
status of the plaintiff and of market price.
4. That after marriage plaintiff concentrated to start a happy conjugal

life. But the harsh reality is that all dreams do not come true and the
plaintiff becomes the victim of harsh reality. Within a few days plaintiff
discovered that plaintiff No-1 was drug addicted. The defendant No-1
used to return home at dead of night in drunken condition and frequently
tortured the plaintiff physically and mentally. The plaintiff tried her best
to make the defendant No-1 understand about the harmful effect of drugs
and bring him back to normal life; but the defendant No-1 did not pay any
heed to words of plaintiff. Even then the plaintiff did not disclose
anything to anybody about the drug addiction of the defendant No-1 for a
quite reasonable time hoping that the defendant No-1 would understand
his mistakes and be back on the right track in future. But the plaintiff was
compelled to inform her relatives and the relatives of defendant No-1
about this matter when she became sure that defendant No-1 was drug
addicted for a quite a long time and he was associated with bad people
and he was no longer capable to lead a normal life with the plaintiff.
Unfortunately all efforts made by the plaintiff went in vain. Moreover the
degree of physical and mental torture upon the plaintiff increased with the
passage of time.
5. That defendant No-2 concealed the fact of bad character and drug
addiction of defendant No-1 with an ill motive of making fraud upon the
plaintiff.
6. That on 15.03. 2019 the defendant No-1 took away all gold ornaments
of the plaintiff for borrowing money by mortgaging the ornaments in
order to purchase a car. Even after mortgaging the ornaments the
defendant No -1 physically and mentally tortured the plaintiff and created
pressure upon the plaintiff to go to her father’s residence and bring more
money. On 20.03.2019 defendants No-1 and 2 forcibly sent the plaintiff
to her father's residence with her brother Isfath who came to defendants’
residence on the same day to see the plaintiff. On 27.03.2019 defendant
No-2 admitted before the elites of the plaintiff's locality of the facts of
misappropriation of gold ornaments, forcible sending of the plaintiff to
her father's residence and drug addiction of defendant No-1. Defendant
No-1 also admitted the fact of mortgaging the gold ornaments.
7. That 05.04.2019 defendant No-1 went to plaintiff's father's residence in

a drunken condition and he, misused and misbehaved with the plaintiff
and her family members. As the defendant No-1 exceeded the degree of
tolerance a G. D. entry being No-224 was lodged against the defendant in
Chittagong kotwali police station on the same day.
Again on 12.04.2019 coming to neighbouring house of the plaintiff the

defendant No-1 misbehaved and gave open threat of divorce and killing
the plaintiff if she failed to bring money from her father. So another G. D.
being No 525/19 was lodged with kotwali thana against the defendant
No-1.
Subsequently, elites of the plaintiff’s locality informed defendant No -2

and elected ward commissioner of defendants’ locality Mr. Abdur
Rahaman of the matter since the defendant No-1 had been committing the
same sort of misdeeds frequently. On 20.04.2019 defendant No-2
accompanied by ward commissioner Abdur Rahaman came to plaintiff's
neighbouring house and took defendant No-1 along with them from the
said neighbouring house.
8. That the Defendant No-1 has not spent anything for maintenance and
medical treatment of the plaintiff from 20-03-2019 except misusing and
threatening her. The plaintiff demanded her dower money and
maintenance on 20.09.2019 through the local elites. But cunning
Defendant No-1 denied paying dower money and maintenance.
Subsequently on 22-09-2019 the plaintiff sent a legal notice with
registered A.D. to the defendant No-1 giving reminder of payment of the
dower money and maintenance. The defendant No-1 refused to accept the
legal notice and the same was returned to the plaintiff on 25.09.2019.
9. That causes of action arose on 20.03.2019 the day on which the

plaintiff was sent to her father's residence against her will, on 20.09.2019,
the day on which the defendant No-1 denied to pay dower money and
maintenance and 25.09.2019, the date on which the defendant No-1
refused to accept the legal notice and on subsequent dates. The plaintiff is
now residing at her father’s residence which is under the local jurisdiction
of this Honorable court and the court has jurisdiction to try the suit.
10. That this is a family matter and that's why this suit is brought to the
Honorable family Court and fixed court fee of Tk 30/- has been paid.
11. Under the circumstances stated above, the plaintiff humbly prays for
a) Decree of Tk 7, 40,000/-as stated in the schedule mentioned below;
b)An order of maintenance from the defendant No -1 until the suit is
disposed of;
c) Cost of the suit and
d) Other relief or reliefs which this honourable court deems proper and
fit.
SCHEDULE
a) Dower money of Tk 4,00,000(four lack) according to registered Nikah
Nama.
b)Total amount of maintenance of Tk 40,000/-(Fourty thousands)

(Tk.5,000/- per month from 20.03.2019 to 20.10.2019)
c)Tk 3,00,000/- as value of one colour television, one refrigerator, full set
house hold furniture, dressing of bridegroom, gold ornaments presented
by plaintiff's relative's, entertainment costs of the marriage ceremony etc.
Total amount =7, 40,000/-
Verification
Whatever facts, have been stated in the above plaint, are true to my
knowledge and belief and I signed this verification on…………. at 10
a.m. at the court premises, Chittagong.
Signature of the Plaintiff
The deponent is known to me and signed before me.
Signature of the Advocate
Name of the witnesses:

1. Ispath Mia
2. Imam Hossain
3. Md. Sarwar Kamal

Plaint of Family Suit

Uploaded by

Copyright:

Available Formats

Plaint of Family Suit

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Plaint of Family Suit

Uploaded by

Copyright:

Available Formats

In the Court of Senior Assistant Judge and

Family Court, Chittagong

Fahima Akther , w\o- Ainul Huda, D\o- Abdus samad

1. Ainul Huda , S\O –Jasim Uddin , 69,Natun Bazar, P\S-kotwali, Chittagong.

Suit for Recovery of Dower and Maintenance

Suit valued at TK 7, 40,000/-

1. That the plaintiff is coming from a middle class respectable Muslim

2. That on 20.08.2018 marriage between plaintiff and defendant No-1

4. That after marriage plaintiff concentrated to start a happy conjugal

7. That 05.04.2019 defendant No-1 went to plaintiff's father's residence in

Again on 12.04.2019 coming to neighbouring house of the plaintiff the

Subsequently, elites of the plaintiff’s locality informed defendant No -2

9. That causes of action arose on 20.03.2019 the day on which the

b)Total amount of maintenance of Tk 40,000/-(Fourty thousands)

Total amount =7, 40,000/-

Signature of the Plaintiff

The deponent is known to me and signed before me.

Signature of the Advocate

Name of the witnesses:

You might also like