IN THE COURT OF 1

st
SENIOR ASSISTANT JUDGE AND FAMILY COURT,
CHITTAGONG.
Family suit n. 1!"!#1$
San%i&a Sultana Ta'in,
("O. ) A&nan Hssain
D"O. ) Say**&)Ul)Islam
Ra+,an, -.S. Hat.a%a'i, C.itta/n/.
.....................................................-lainti00.
1*'sus
A&nan Hssain
S"O. ) Humayun 2a3i'
C.+&.u'y Hat, -"O. Hat.a%a'i, C.itta/n/.
.......................................................D*0*n&ant.
Suit 0' R*45*'y 0 D+*', Maint*nan4* t.*' D*man&s
Suit 5alu*& at T6. 7,87,###.##
T.* a35* nam*& 9lainti00 3*//*& t stat* as 0ll+s.
1. That the plaintiff is coming from a middle class respectable Muslim family. She is
simple, polite & amiable Lady.
2. That the plaintiff lawfully married the defendant on 10
th
Noember !01!. "ith a
fi#ed amount of t$. 10,000,00 %ten la$hs& as dower, of which t$. !,000,00 %two
la$hs& is shown paid & The rest is diided at t$. ',000,00 %si# la$hs& & !,000,00 %!
La$hs& as prompt dower and deferred dower respectiely.
3. That at the ceremony no fi#ed amount of monthly maintenance was specified
but it was settled that the amount would be fi#ed in the future on the basis of
plaintiff(s social status.
4. That the plaintiff concentrated to start a happy con)ugal life with the defendant
as well wished so. *ut unfortunately the situation turn into far more bad than the
plaintiff(s wish.
5. "ithin a few days the plaintiff discoered that the defendant Mr. +dnan ,ossain
was not a good person. ,e was also a drug addict as well spend money to
arious $inds of gambling. Need to mention the defendant was also addicted
and obsessed with pornography. +nd the plaintiff became the ictim of
defendant(s ill se#ual obsession.
6. That with the intention to continue a happy con)ugal life the plaintiff tried her
best to ma$e the defendant understand about how such bad things effect their
newly married lies. *ut without giing heed to the plaintiff(s words, the
defendant threaten to hit the plaintiff if there was another word about it.
7. That the plaintiff did not disclose those facts to anybody hoping that the
defendant would understand the mista$es and be bac$ on right trac$ in future.
*ut after seeral times of failure to ma$e the defendant understand the plaintiff
was compelled to inform her relaties & relaties of the defendants about the
aboe mentioned facts.
8. That the present cause of action arose at -.00 pm, !-
th
/anuary !010. 1n that
eening the defendant after returning home demanded & tortured the plaintiff
for bringing dowry money from her father(s house amounting to ta$a 1,000,00
%one la$h&. 2laintiff refused to bring dowry and at once the defendant forced the
plaintiff to leae his house. The plaintiff left the house with one clothed. +fter
that the defendant neer communicate with the plaintiff and didn(t gie any
maintenance.
9. That the family of plaintiff tried to sole the matter with the consultation of
elders from both sides. *ut the family of defendant didn(t respond well.
10. That after there is no way open to resole the problem for the plaintiff(s family,
howeer, the plaintiff put an application for diorce to resole this marriage, as
well sent a legal notice with registered +.3 to the defendant giing reminder of
paying the rest of the dower money and the maintenance which is dated on 1'
th
May !010. That the defendant refuse to accept the legal notice and the same
was sent to the plaintiff on !0
th
May !010.
11. That the plaintiff is now residing at her father(s residence which is under the local
)urisdiction of this ,onorable 4ourt.
12. That this is the family matter that is why this suit has been brought to the
,onorable 4ourt and fi#ed court fees has been duly paid.
13. "herefore, it is most humbly prayed that your honor would be pleased to.
14. 2ass a decree of T$. -,5-,000 as mentioned in the schedule below6
15. 7ie an order of maintenance from the defendant until the suit is disposed of6
16. 4ost of the suit and
17. 1ther reliefs which this ,onorable 4ourt may thin$ proper & fit.
,onorable 4ourt deems proper and fit.
SCHEDULE
8 3ower money of t$ -,00,000 according to registered Ni$ahnama.
8 +mount of maintenance for plaintiff t$. 5-,000 %t$. -,000 per month from
!-901910 to !090'910&
Total amount : T$. -,5-,000
Nam* 0 t.* +itn*ss*s
18. Mr. Masudul ;slam
19. Mr. Saiful ;slam
1ERIFICATION
That the statements made here in aboe are true to the best of my $nowledge
and belief and ; sign this erification on !<
th
May !010
3eponent
IN THE COURT OF 1
st
SENIOR ASSISTANT JUDGE AND FAMILY COURT,
CHITTAGONG.
Family suit n. 1!"!#1$
San%i&a Sultana Ta'in,
("O. ) A&nan Hssain
D"O. ) A3&u' Ra.man
Ra+,an, -.S. Hat.a%a'i, C.itta/n/.
.....................................................-lainti00.
1*'sus
A&nan Hssain
S"O. ) Humayun 2a3i'
C.+&.u'y Hat, -" Hat.a%a'i, C.itta/n/.
.......................................................D*0*n&ant.
Suit 0' R*45*'y 0 D+*', Maint*nan4*, t.*' D*man&s
Suit 5alu*& at T6. 7,87,###.##
('itt*n Stat*m*nt n :*.al0 0 t.* D*0*n&ants
20. That the suit is not maintainable in law, either in the present form or in any
other form.
21. That the plaint does not disclose any cause of action and as such the suit is
liable to be dismissed.
22. That the suit is liable to be dismissed for mis=)oinder and non=)oinder of
parties.
23. That the suit is absolutely barred by the principles of estoppels, waier and
ac>uiescence.
24. That the statements and allegations made in the plaint, so far specifically
and categorically not admitted, shall be deemed to hae been denied by
the defendants and the burden of proof shall lie upon the plaintiffs.
25. That the statements made in para=1 of the plaint are not true and denied by
the defendant. ;t is not true that the plaintiff no.1 is a soft, simple, polite,
religious and amiable lady, rather she is proud, arrogant, disobedient,
unfaithful and characterless.
26. That all the statements made in para=! of the plaint are not true and hence
denied by the defendant. Though the actual money to be fi#ed was t$.
!,00,000 which the plaintiff(s father dishonestly fi#ed 10,00,000 out of which
t$. !,00,000 been paid.
27. That the statement made in para=0 of the plaint is not true and strongly
denied by the defendant. ;t is not a fact that the maintenance would be
fi#ed in future on the basis of plaintiff(s social status.
28. That the statements made in para=5 of the plaint is not true that the plaintiff
neer tried to start a happy life.
29. That the statements made in para=< of the plaint being absolutely false, are
strongly denied by the defendant. ;t is not a fact that the defendant was
drug addict6 or spend money to arious $inds of gambling. +s well, the
defendant had no obsession for pornography or something icious ali$e to
that accusation.
30. That all the statements made in para=' of the plaint being absolutely false
and hence strongly denied by the defendant. ;t is not a fact that the plaintiff
had the intention to start a happy con)ugal life6 or that the plaintiff ma$e
the defendant understand about effects of bad things in their newly married
life6 or the defendant paying heed to plaintiff(s words6 or that the defendant
threaten to hit the plaintiff.
31. That all the statements made in para=? of the plaint are absolutely false. ;t
is not a fact that the plaintiff did not disclose those facts to anybody hoping
the defendant would bac$ on right trac$ in future6 or that the plaintiff
compelled to inform her relaties and relaties of the defendant.
32. That the statements made in para=- of the plaint being absolutely false, are
strongly denied by the defendant. ;t is not a fact that the present cause of
action arose at -.00 pm, !-
th
/anuary !0106 or that on that eening the
defendant after returning home tortured the plaintiff for bringing dowry
money from her father(s residence amounting to ta$a 100000 %one la$h&6 or
that the defendant did not force the plaintiff to leae the house at once6 or
that the plaintiff leae the house with only one cloth.
33. That the statements made in para=@ of the plaint being absolutely false, are
strongly denied by the defendant.
34. That the statements made in para=10 of the plaint being totally false and
denied by the defendant. ;t is not a fact that the defendant refused to
accept the legal notice6 or that the same was sent to the plaintiff.
35. That the plaintiff is not entitled to get the decree prayed for or any other
relief against the defendant.
T.* R*al Fa4ts O0 T.* Cas* A'*;
8 That the plaintiff is a proud, arrogant, disobedient, unfaithful and
characterless. She had affair with many guys before her marriage and she
continue it after her marriage.
8 That the defendant is a well=educated man with high moral character and
his family is well reputed in the locality because of their simplicity,
modesty and gentleness. The family members of the plaintiff concealed
the real character of the plaintiff and they gae false and motiated
information to the defendant about her. The defendant mista$enly
belieed the information to be true and married the plaintiff on 10
th
Noember !01! by registered Nikahnama. At the time of marriage, the
defendant gae 150 gins, gold ornaments, aluable clothing(s and
cosmetics worth t$. 1,<0,000 to the plaintiff. The defendant married the
plaintiff with a great hope of happy con)ugal life. *ut within a few days of
marriage the real nature of the plaintiff reealed. She used to go out of
the house fre>uently without saying a word to the defendant, or in the
absence of defendant. "hen the defendant as$ed her anything about that
she used to answer that she was going out to meet her friend from
college or school life. The defendant one day inspected that she was
meeting another person, who is used to be the boyfriend of the plaintiff
for a long time een before the marriage with defendant and it is clear
that the plaintiff could not forget the said loe affair. The defendant and
his family tried a lot to ma$e her understand but all attempts went in ain
as the degree of arrogance and disobedience increased with the passage
of time. Ainding no other way the defendant brought the matter in the
$nowledge of the plaintiff no.l(s family member. *ut they told the
defendant to cope with that.
8 That on !-
th
/anuary !010 the plaintiff went out of the house without
letting anyone the fact that they were leaing the house. The neighbor of
the defendant saw them going with another man. 2laintiff too$ with her all
gold ornaments, aluable clothing(s etc. The defendant tried to contact
with her and bring them bac$ to his residence. *ut she refused to come
bac$ and decided to lie together with her loer. 4onsidering the social
status the defendant restrained himself from see$ing any legal remedy
against the plaintiff
8 That while the defendant and his family members were waiting with the
hope that the plaintiff no.1 would be able to understand her faults and
come bac$ under defendant(s con)ugal domain, then unfortunately this
suit has been filed against the innocent defendant. The defendant made
attempts to reconcile the matter despite the fact that the filing of the suit
against them was a big blow to their hopes. *ut all hopes anished when
the defendant came to $now that the plaintiff no.1 decided to get with her
loer and as preparation of that marriage this groundless suit had been
filed.
8 That after few days the plaintiff send diorce letter to the defendant. The
defendant tried to sae her marriage but he couldn(t.
"herefore, it is prayed that the ,onorable 4ourt would be pleased to dismiss
the suit with cost.
1ERIFICATION
"hateer stated aboe are true to my $nowledge and ; sign this erification today
...........................+t 10.00 a.m. in 4ourt premises, 4hittagong.