IN THE COURT OF THE FIRST ASSISTANT JUDGE AND FAMILY COURT,

SADAR, CHITTAGONG

Family suit no.25/2014

Mosammat Shahanaj Begum, D/O

Muhammad Habibulla, 43/d
Sugandha Residential Area
P.S.:Panchlaish, Chittagong.

......................Plaintiff

Versus

Md. Sohel Shahriar, S/O Md.

Faridul Alam, 12/A Chandgao
Residential Area, Chandgao,
Chittagong.

...................Defendant

Written statement

The above named defendant begs to state that

1. That the suit is not maintainable in its present form.

2. That there is no cause of action of the suit.

3. That the statements made in the plaint shall be deemed to have been denied by the
defendant, which have not been expressly admitted in the written statement.

4. That the statements made in Para-1 of the plaint is true. The defendant married the
plaintiff on 07.01.2013 through registered Nikahnama.

5. That the statement made in Para-2 in the plaint is true. Hence the defendant admits that in
Nikahnama dower was fixed at TK 5,00,000 (five lacs) out of which tk.1,00,000 (one lac)
was shown paid. The rest of the amount was divided equally as prompt and deferred dower.
The Nikahnama also shows that maintenance would be time befitting and status suiting.

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6. That the statements made in Para-3 of the plaint are not true. So the defendant denies the
allegation of the plaintiff that within a few days of marriage the defendant started to demand
dowry from the plaintiff. The defendant never tortured the plaintiff.

7. That the statement made in Para-4 is not true. Hence the defendant denies the statement.
The defendant did not forcibly send the plaintiff on 01.06.2013 to her paternal house. She
went there for a pleasure trip.

8. That the statement made in Para-5 is true. Hence the defendant admits that the plaintiff
divorced him on 28.08.2013.

9. That the statement made in Para-6 is not true. It is true that the plaintiff demanded her
unpaid dower and maintenance on 01.12.2013 through her father and local chairman. But it is
not true that the defendant refused to pay. The defendant asked them to allow him some time
more to pay the dues.

10. That the statement made in Para-7 is not true. The defendant did not receive any letter
dated 15.12.2013 from the plaintiff demanding her dower and maintenance.

11. That the statement made in Para-8 is not true. No cause of action arose on 01.06.2013, on
28.08.2013, on 01.12.2013 and on 15.12.2013 as stated by the plaintiff.

12. That the statements made in Para-9 are not completely true. The fact is that no cause of
action arose within the jurisdiction of the honourable court. But it is true that both the parties
reside within the local jurisdiction of the honourable court.

13. That the statement made in Para-10 is true. The fact that the suit is a family suit and court
fees has been properly paid.

14. That the statement made in Para-11 is not true. The plaintiff is not entitled to get a decree
for dower and maintenance and any other relief as prayed for.

15. That the fact is that the defendant got married with the plaintiff by registered Nikahnama
on 07.01.2013. Immediately after marriage the plaintiff told the defendant that the marriage
was conducted her wish. The plaintiff also threatened the defendant that she would divorce
him at any time and would marry her boy friend. The defendant tried his best to make the
plaintiff understand. But she did not pay any heed to the defendant’s words.

16. That on 01.06.2013 the plaintiff went to her paternal house for a pleasure trip. While the
defendant was waiting for the plaintiff to come back surprisingly he received a notice of
divorce on 28.08.2013.

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17. That on 23.12.2013 the defendant went to the plaintiff’s father’s house and paid tk.
4,15,000 (four lacs and fifteen thousand) as unpaid dower and maintenance for iddat period.
The defendant paid the money in the presence of plaintiff’s father, brother and defendant’s
elder brother.

18. That the plaintiff has already received her dues. Hence there is no reason to proceed with
the suit.

It is therefore hoped and prayed

that the Honourable court be
pleased enough to dismiss the
suit.

Verification

Whatever facts stated above are

true to my knowledge.
I sign this verification this day
of 10th march, 2014 At 10 A.M
in the Court Premises,
Chittagong.

Name and Address of the Witnesses

1.Md. Sohel Shahriar, 12/A Chandgao Residential

Area, Chandgao, Chittagong.

2.Md. Faisal Shahriar, 12/A Chandgao Residential

Area, Chandgao, Chittagong.

Signature of the Defendant

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