sample of plaint

Topics: Civil procedure, Pleading, Jurisdiction Pages: 3 (374 words) Published: October 13, 2013
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In the Court of Assistant Judge at Dhaka

Suit No.../…

Azizul Islam, Son of Delwar Hossain and Razia Khatun
House-2, Road-7, Middle Badda, Dhaka-1212.                            …………Plaintiff

Vs.

Mohammad Habibur Rahman, Son of Amir Hossen and Sakina Begum House-31/4, Road-1, Mohakhali, Dhaka-1212.                        ........  Respondent

Statement of Jurisdiction:

1. The land property is located under the P.S: Gulshan, Dhaka-1212, Bangladesh, which is within this court's territorial jurisdiction.

2. The value of the suit 1, 90,000/- which is within this court's pecuniary jurisdiction.

Suit for Recovery of Possession

Statement of Facts:

1. The plaintiff has purchased the following property from Imran Rashid under title deed no. 1278, Registered with Sub-Registrar of Mohakhali, Dhaka-1212, and Dated on 5.5.2005. Then immediately the possession of the following land property has been delivered to the plaintiff by one Imran Rashid, seller of the land property.

2. Then the plaintiff has been in possession without any interruption since 5.5.2005 on the said property. However, for the personal affairs the plaintiff left Bangladesh on 23.6.2013 to Canada. Meanwhile he has been unlawfully dispossessed by the respondent, and instantly the respondent built a house on the land.

3. The location of the property is as under:

East:  Road
 West: Plot number 124
  North: Road
South: Colony wall

Cause of Action:

The cause of action for the present suit first arose on 3.07.2013, when the respondent illegally took the possession of the land property.

Valuation:

The suit is valued for the purpose of jurisdiction Tk 1, 90,000/- and thus the Court fees of the suit is Tk 500/- which is paid respectively.

Relief Claimed:

The plaintiff, therefore prays that
1. The court...
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