Shihab Uddin 20-43605-1

Suit for Realization of Dower, Maintenance & Custody

In The Court of Assistant Judge and Family Court, 1st Court, Dhaka

Family Court Suit No: I of 2014

Plaintiff:
Mrs. B
D/O of Y
 House-09, Road-10, Dhanmondi, Dhaka

Versus

Defendants
Mr. C
S/O X
House-05, Road-06, Banani, Dhaka

The humble petition of the above-named plaintiff most respectfully:

 SHEWETH:

1. That the plaintiff married the defendant lawfully on 10 th January in 2019. The dower was fixed at
tk. 4, 00,000 which was not paid.
2. That after 1 year of marriage, their first son (R), aged 3, was born.
3. That the marriage, gradually, turned into not a happy one. The behavior of Mr. C was not good at
all. He did not give adequate time to his family. The plaintiff was always under mental pressure
as her husband kept her in the fear of divorce. The defendant was asked several times to desist
from his misbehavior by the plaintiff’s parents, but his attitude is uncompromising.
4. That the defendant is hot tempered person. His behavior was bad not only to his family but also
to the neighbors.
5. That the cause of action arose at 7 pm on 1 st Dec 2022. On that evening Mr. C after returning
home engaged in quarrel with the plaintiff and at one stage he pronounced ‘Talaq’ for 3 times to
 the plaintiff and forced her to leave his house. The plaintiff left the house along with the children
to her father’s house.
6. That since the incidence of pronouncing ‘Talaq’, the plaintiff has been residing in her father’s
house and the defendant never communicated with the plaintiff and didn’t provide any
maintenance for his wife and children. He came to take son, Rabin, on 01/01/2023, but son didn’t
want to go with him.
7. That the divorce has become effective by now as three months (01/12/2022 to 01/03/2023) have
been passed since the pronouncement of ‘Talaq’ according to the provisions of Muslim Law. 8.
That the court has jurisdiction to try the suit as the incident occurred within the local jurisdiction
of the court.
9. That the proper court fees for this suit has been duly paid.
 Therefore, it is most humbly prayed that this
Hon’ble Court -
A. To pass a decree to declare the divorce lawful one.
B. Award dower money to the plaintiff from her husband.
C. Pass an order to give tk. 10,000 per month to the plaintiff as maintenance of the plaintiff
and her children.

Shihab Uddin 20-43605-1

D. To declare the plaintiff as the custodian of the children and all other relief which the court
thinks appropriate for the sake of justice.
 Verification:
The statement made in the plaint is true to my knowledge
and belief and I put my signature on this plaint in the
chamber of my learned lawyer on this 31st March 2006.

Signature