May It Please your honor.

This is an application under Or. 7 R. 11 and Sec.151 of the CPC for rejection of the plaint.

This Suit is for Declaration and permanent injunction.

The plaintiff is Naim Habib, and the defendant is the Bangladesh Doctors Association and Others.

I’m here for the Defendant Applicant.

The Schedule of the suit property is Holding No:5/2 Topkhana Road.

Your Honor, the fact is that.

The plaintiff is a respected politician whose father used to be a minister in the government. The plaintiff's
father owned the property under dispute, but it was later acquired by the government and transferred to the
Doctors Association of Bangladesh. The plaintiff hopes to achieve a fair and just resolution for all parties
involved by pursuing legal action and raising awareness of the issue.

The plaintiff requested a permanent injunction against the defendant's illegal actions, but the defendant
contested the request by entering an appearance.

"Your Honor, I would like to draw your attention to the relevant case of M.P. Shipping Services Pvt. Ltd. v.
World Tanker Carrier Corporation. This case supports the Defendant's claim that a complaint can only be
valid if it provides adequate information about the harm caused to the plaintiff by the defendant. It is
imperative for the court to consider this precedent when rendering its verdict in this case."

So, my humble submission is that your honor would be kind enough to pass an order of rejection of the
petition.

It is imperative to understand that the plaintiff has no direct or personal interest, rights, or title with the
association. Consequently, any lawsuit they file claiming public interest is entirely invalid and falls under
the writ jurisdiction of the Supreme Court of Bangladesh. Additionally, the plaintiff has no personal
grievance to file suit, and they have no rights to the property in question since the previous owner had
already relinquished all interests in it. Before taking any legal action, it is crucial to carefully consider these
facts and take appropriate action accordingly.

Unfortunately, this lawsuit cannot proceed as it does not have the necessary grounds or cause of action and
is also barred by law. Let's explore other options to address the issue at hand.