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  • Written Statement - Draft Sample

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    Rao
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    This written statement is filed by the defendant, Salina Akther, in response to a title suit brought by the plaintiff, Shakur Mahamud. The defendant argues that [1] the plaintiff has no cause of action or right to the disputed land, [2] the suit is not maintainable, and [3] the suit is barred by legal principles such as estoppel and limitations. The defendant further claims that [4] she has possessed the land for over 12 years through tenants and a servant, [5] the land was properly transferred to her by the recorded tenant in 1991, and [6] the land is now recorded under her name. She requests the court to dismiss the suit against her with

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    Written Statement - Draft Sample

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    This written statement is filed by the defendant, Salina Akther, in response to a title suit brought by the plaintiff, Shakur Mahamud. The defendant argues that [1] the plaintiff has no cause of action or right to the disputed land, [2] the suit is not maintainable, and [3] the suit is barred by legal principles such as estoppel and limitations. The defendant further claims that [4] she has possessed the land for over 12 years through tenants and a servant, [5] the land was properly transferred to her by the recorded tenant in 1991, and [6] the land is now recorded under her name. She requests the court to dismiss the suit against her with

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    184 views2 pages

    Written Statement - Draft Sample

    Uploaded by

    Rao
    This written statement is filed by the defendant, Salina Akther, in response to a title suit brought by the plaintiff, Shakur Mahamud. The defendant argues that [1] the plaintiff has no cause of action or right to the disputed land, [2] the suit is not maintainable, and [3] the suit is barred by legal principles such as estoppel and limitations. The defendant further claims that [4] she has possessed the land for over 12 years through tenants and a servant, [5] the land was properly transferred to her by the recorded tenant in 1991, and [6] the land is now recorded under her name. She requests the court to dismiss the suit against her with

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    of 2

    Written Statement

    IN THE COURT OF JOINT DISTRICT JUDGE, GAZIPUR


    Title Suit No. 206/1010
    Shakur Mahamud…………….Plaintiff

    Versus

    Salina Akther…………...…Defendant

    Written Statement on behalf of the defendant .

    The defendant most respectfully-

    Sheweth:

    1. That there is no cause of action for the suit & the suit is liable to set aside.

    2. That the suit is not maintainable in the present form & manner.

    3. That the suit is barred by the principles of estoppels, waiver &


    acquiescence.

    4. That the suit is barred by law of limitation.

    5. That the suit is not maintainable according to section 8 of the Specific Relief
    Act.

    6. That the plaintiff is not the owner & and has no possession as well neither
    the plaintiff has ever possession of the suit land.

    7. That the statements made in paragraph 2, 4 & 5 are the subject of records
    so the burden of proof lies upon the plaintiff.

    8. That the statements made from paragraph 2-10 are false, frivolous &
    vicious & denied by this defendant.

    9. That the facts on behalf of this defendant are as follows:


    a) That Mr. Abdul Awal was the C.S recorded no. 1066 tenant of 63 decimals
    area of land of dag no. 152. Mr. Abdul Awal alienated 33 decimals of land of
    dag no. 152 to the defendant by a deed of exchange dated 16 December,
    1991 bearing no. 8245. The defendant was also inducted into the possession
    of 33 decimals of land of dag no. 152.

    b) That the defendant mutated the said 33 decimals of land in his own name
    and also paid rent to the Govt. in respect of the land in dispute.

    c) That the defendant has been possession of the suit land for more than 12
    years through his barghadar Aziul Islam & his servant Ferzena Sultana. Azizul
    Islam cultivates 27 decimals of land out of 33 decimals of the suit land and
    Ferzena Sultana care taking a pond in 6 decimals of land out of 33 decimals
    of suit land.

    d) That the suit land has been recorded in the name of the defendant in the
    recent field R.S record bearing dag no. 160.

    e) That the plaintiff has no right, title and interest over the suit land but filed
    this suit on false, frivolous and vexatious ground just to harass the defendant.

    Wherefore it is prayed that your honour would be pleased to dismiss the suit
    with explanatory cost against the plaintiff.

    Verification

    Verified at Dhaka this 01 of January, 2011 that


    th contents of para 1-9 are true to the best of my
    knowledge & belief.

    ……………………

    Signature

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