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IN THE COURT OF 1

ST
SENIOR ASSISTANT JUDGE AND FAMILY COURT,
CHITTAGONG.
Family suit no. 12/2013

Sanzida Sultana Tarin,
W/O. Adnan Hossain
D/O. Sayeed-Ul-Islam
Rawjan, P.S. Hathazari, Chittagong.
.Plaintiff.

Versus

Adnan Hossain
S/O. - Humayun Kabir
Chowdhury Hat, P/O. Hathazari, Chittagong.
Defendant.


Suit for Recovery of Dower, Maintenance other Demands


Suit valued at Tk. 8,48,000.00



The above named plaintiff begged to state as follows.
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
November 2012. With a
fixed amount of tk. 10,000,00 (ten lakhs) as dower, of which tk. 2,000,00 (two
lakhs) is shown paid & The rest is divided at tk. 6,000,00 (six lakhs) & 2,000,00 (2
Lakhs) as prompt dower and deferred dower respectively.
3. That at the ceremony no fixed amount of monthly maintenance was specified
but it was settled that the amount would be fixed in the future on the basis of
plaintiffs social status.
4. That the plaintiff concentrated to start a happy conjugal life with the defendant
as well wished so. But unfortunately the situation turn into far more bad than the
plaintiffs wish.
5. Within a few days the plaintiff discovered that the defendant Mr. Adnan Hossain
was not a good person. He was also a drug addict as well spend money to
various kinds of gambling. Need to mention the defendant was also addicted
and obsessed with pornography. And the plaintiff became the victim of
defendants ill sexual obsession.
6. That with the intention to continue a happy conjugal life the plaintiff tried her
best to make the defendant understand about how such bad things effect their
newly married lives. But without giving heed to the plaintiffs 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 mistakes and be back on right track in future.
But after several times of failure to make the defendant understand the plaintiff
was compelled to inform her relatives & relatives of the defendants about the
above mentioned facts.
8. That the present cause of action arose at 8:00 pm, 28
th
January 2013. On that
evening the defendant after returning home demanded & tortured the plaintiff
for bringing dowry money from her fathers house amounting to taka 1,000,00
(one lakh). Plaintiff refused to bring dowry and at once the defendant forced the
plaintiff to leave his house. The plaintiff left the house with one clothed. After
that the defendant never communicate with the plaintiff and didnt give any
maintenance.
9. That the family of plaintiff tried to solve the matter with the consultation of
elders from both sides. But the family of defendant didn't respond well.
10. That after there is no way open to resolve the problem for the plaintiff's family,
however, the plaintiff put an application for divorce to resolve this marriage, as
well sent a legal notice with registered A.D to the defendant giving reminder of
paying the rest of the dower money and the maintenance which is dated on 16
th

May 2013. That the defendant refuse to accept the legal notice and the same
was sent to the plaintiff on 20
th
May 2013.
11. That the plaintiff is now residing at her fathers residence which is under the local
jurisdiction of this Honorable Court.
12. That this is the family matter that is why this suit has been brought to the
Honorable Court and fixed court fees has been duly paid.
13. Wherefore, it is most humbly prayed that your honor would be pleased to:
a) Pass a decree of Tk. 8,48,000 as mentioned in the schedule below;
b) Give an order of maintenance from the defendant until the suit is disposed of;
c) Cost of the suit and
d) Other reliefs which this Honorable Court may think proper & fit.

Honorable Court deems proper and fit.




SCHEDULE

Dower money of tk 8,00,000 according to registered Nikahnama.
Amount of maintenance for plaintiff tk. 48,000 (tk. 8,000 per month from
28/01/13 to 20/06/13)

Total amount = Tk. 8,48,000

Name of the witnesses
1) Mr. Masudul Islam

2) Mr. Saiful Islam


VERIFICATION
That the statements made here in above are true to the best of my knowledge
and belief and I sign this verification on 25
th
May 2013

Deponent



IN THE COURT OF 1
ST
SENIOR ASSISTANT JUDGE AND FAMILY COURT,
CHITTAGONG.
Family suit no. 12/2013

Sanzida Sultana Tarin,
W/O. Adnan Hossain
D/O. - Abdur Rahman
Rawjan, P.S. Hathazari, Chittagong.
.Plaintiff.

Versus

Adnan Hossain
S/O. - Humayun Kabir
Chowdhury Hat, P/o Hathazari, Chittagong.
Defendant.


Suit for Recovery of Dower, Maintenance, other Demands


Suit valued at Tk. 8,48,000.00


Written Statement on Behalf of the Defendants
1. That the suit is not maintainable in law, either in the present form or in any
other form.
2. That the plaint does not disclose any cause of action and as such the suit is
liable to be dismissed.
3. That the suit is liable to be dismissed for mis-joinder and non-joinder of
parties.
4. That the suit is absolutely barred by the principles of estoppels, waiver and
acquiescence.
5. That the statements and allegations made in the plaint, so far specifically
and categorically not admitted, shall be deemed to have been denied by
the defendants and the burden of proof shall lie upon the plaintiffs.
6. That the statements made in para-1 of the plaint are not true and denied by
the defendant. It 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.
7. That all the statements made in para-2 of the plaint are not true and hence
denied by the defendant. Though the actual money to be fixed was tk.
2,00,000 which the plaintiffs father dishonestly fixed 10,00,000 out of which
tk. 2,00,000 been paid.
8. That the statement made in para-3 of the plaint is not true and strongly
denied by the defendant. It is not a fact that the maintenance would be
fixed in future on the basis of plaintiff's social status.
9. That the statements made in para-4 of the plaint is not true that the plaintiff
never tried to start a happy life.
10. That the statements made in para-5 of the plaint being absolutely false, are
strongly denied by the defendant. It is not a fact that the defendant was
drug addict; or spend money to various kinds of gambling. As well, the
defendant had no obsession for pornography or something vicious alike to
that accusation.
11. That all the statements made in para-6 of the plaint being absolutely false
and hence strongly denied by the defendant. It is not a fact that the plaintiff
had the intention to start a happy conjugal life; or that the plaintiff make
the defendant understand about effects of bad things in their newly married
life; or the defendant paying heed to plaintiff's words; or that the defendant
threaten to hit the plaintiff.
12. That all the statements made in para-7 of the plaint are absolutely false. It
is not a fact that the plaintiff did not disclose those facts to anybody hoping
the defendant would back on right track in future; or that the plaintiff
compelled to inform her relatives and relatives of the defendant.
13. That the statements made in para-8 of the plaint being absolutely false, are
strongly denied by the defendant. It is not a fact that the present cause of
action arose at 8.00 pm, 28
th
January 2013; or that on that evening the
defendant after returning home tortured the plaintiff for bringing dowry
money from her fathers residence amounting to taka 100000 (one lakh); or
that the defendant did not force the plaintiff to leave the house at once; or
that the plaintiff leave the house with only one cloth.
14. That the statements made in para-9 of the plaint being absolutely false, are
strongly denied by the defendant.
15. That the statements made in para-10 of the plaint being totally false and
denied by the defendant. It is not a fact that the defendant refused to
accept the legal notice; or that the same was sent to the plaintiff.
16. That the plaintiff is not entitled to get the decree prayed for or any other
relief against the defendant.


The Real Facts Of The Case Are:
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.
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 gave false and motivated
information to the defendant about her. The defendant mistakenly
believed the information to be true and married the plaintiff on 10
th

November 2012 by registered Nikahnama. At the time of marriage, the
defendant gave 140 gins, gold ornaments, valuable clothings and
cosmetics worth tk. 1,50,000 to the plaintiff. The defendant married the
plaintiff with a great hope of happy conjugal life. But within a few days of
marriage the real nature of the plaintiff revealed. She used to go out of
the house frequently without saying a word to the defendant, or in the
absence of defendant. When the defendant asked 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 even before the marriage with defendant and it is clear
that the plaintiff could not forget the said love affair. The defendant and
his family tried a lot to make her understand but all attempts went in vain
as the degree of arrogance and disobedience increased with the passage
of time. Finding no other way the defendant brought the matter in the
knowledge of the plaintiff no.1s family member. But they told the
defendant to cope with that.
That on 28
th
January 2013 the plaintiff went out of the house without
letting anyone the fact that they were leaving the house. The neighbor of
the defendant saw them going with another man. Plaintiff took with her all
gold ornaments, valuable clothings etc. The defendant tried to contact
with her and bring them back to his residence. But she refused to come
back and decided to live together with her lover. Considering the social
status the defendant restrained himself from seeking any legal remedy
against the plaintiff
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 back under defendants conjugal 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. But all hopes vanished when
the defendant came to know that the plaintiff no.1 decided to get with her
lover and as preparation of that marriage this groundless suit had been
filed.
That after few days the plaintiff send divorce letter to the defendant. The
defendant tried to save her marriage but he couldnt.

Wherefore, it is prayed that the Honorable Court would be pleased to dismiss
the suit with cost.




VERIFICATION
Whatever stated above are true to my knowledge and I sign this verification today
.. At 10.00 a.m. in Court premises, Chittagong.