Drafting of a Plaint
Every Civil Suit is started by filling a plaint
IN THE COURT OF JOINT DISTRICT JUDGE, GAZIPUR.
Title Suit No. 463/2002
Shakur Mahamud
S/O Abdul Awal,
Village: Rajendrapur
Post Office: Rajendrapur,
Police Station: Shreepur,
Thana: Shreepur
District: Gazipur.
……………………..Plaintiff
Versus.
Selina Akther
Daughter of ……………..
Village: Rajendrapur
Post Office: Rajendrapur,
Police Station: Shreepur,
Thana: Shreepur
District: Gazipur.
…………………Defendant
Suit for establishment of title & recovery of khas possession
Suit Valued at Tk. 5,00000
The humble petition of the above named plaintiff most respectfully states as follows:
1. That Mr. Abdul Awal was the C.S recorded no. 1066 tenant of 63 decimals land & he being owner in possession of the said land died leaving behind the plaintiff as son in 25 March, 1996.
2. That according to Islamic Sharia Law the plaintiff inherited 63 decimals of land as stated above & he muted the said 63 decimals of land in his own name & pays rent to the Government.
3. That the plaintiff alienated 15 decimals of land of dag no.152 to the Anwar Hossain by a deed of exchange dated 20 December, 2000 bearing no. 6285.
4. That the palintiff has homesteaded in the 15 decimals of land out of his 48 decimals of land and rest 33 decimals of suit land has been used for cultivating by the plaintiff. There is a road also in 3 decimals of land out of 33 decimals of the suit land. The plaintiff has been possession of the suit land for more than 12 years through cultivation.
5. That on 03 October, 2010 the defendant wrongfully & forcibly entered into the possession of the 33 decimals suit land with some 15/20 men without the consent of the plaintiff & dispossessed him denying his title over the said land.
6. That the defendant continues to be in wrongful possession of the suit land & refuses to allow the plaintiff to cultivate the land in dispute.
7. That the cause of action arose on 03, October 2010, when the defendant wrongfully entered into the possession of the suit land & dispossessed the plaintiff therefrom denying his title over the suit land.
8. That the suit land is situated in Dhaka within the jurisdiction of this Court, this Court has jurisdiction to try the suit.
9. That the value of the subject matter of the suit for the purpose of the Court fee & jurisdiction is fixed at Tk. 5,00000 & the plaintiff paid advalorem court fee on the plaint.
10. That the plaintiff, therefore, prays as follows:
a) Possession of the property as stated in Schedule 'A' to the plaint after declaring of the plaintiff's title thereto.
b) Pass such other or further relief as to which the plaintiff maybe found entitled to in law & in equity.
SCHEDULE-A
District- Gazipur, Police Station- Shreepur, Mouza- Razabari,
C.S KHATIAN NO. 1066
S.A KHATIAN NO. 3359
R.S KHATIAN NO. 5463
R.S DAG NO. 152
TYPES OF LAND: Agricultural land
AREA OF LAND: 33 decimals
Verification
Verified at Gazipur this 01 of January, 2011 the contents of Para 1-10 are true to the best of my knowledge & belief.
……………………..
Signature
Title Suit No. 463/2002
Shakur Mahamud
S/O Abdul Awal,
Village: Rajendrapur
Post Office: Rajendrapur,
Police Station: Shreepur,
Thana: Shreepur
District: Gazipur.
……………………..Plaintiff
Versus.
Selina Akther
Daughter of ……………..
Village: Rajendrapur
Post Office: Rajendrapur,
Police Station: Shreepur,
Thana: Shreepur
District: Gazipur.
…………………Defendant
Suit for establishment of title & recovery of khas possession
Suit Valued at Tk. 5,00000
The humble petition of the above named plaintiff most respectfully states as follows:
1. That Mr. Abdul Awal was the C.S recorded no. 1066 tenant of 63 decimals land & he being owner in possession of the said land died leaving behind the plaintiff as son in 25 March, 1996.
2. That according to Islamic Sharia Law the plaintiff inherited 63 decimals of land as stated above & he muted the said 63 decimals of land in his own name & pays rent to the Government.
3. That the plaintiff alienated 15 decimals of land of dag no.152 to the Anwar Hossain by a deed of exchange dated 20 December, 2000 bearing no. 6285.
4. That the palintiff has homesteaded in the 15 decimals of land out of his 48 decimals of land and rest 33 decimals of suit land has been used for cultivating by the plaintiff. There is a road also in 3 decimals of land out of 33 decimals of the suit land. The plaintiff has been possession of the suit land for more than 12 years through cultivation.
5. That on 03 October, 2010 the defendant wrongfully & forcibly entered into the possession of the 33 decimals suit land with some 15/20 men without the consent of the plaintiff & dispossessed him denying his title over the said land.
6. That the defendant continues to be in wrongful possession of the suit land & refuses to allow the plaintiff to cultivate the land in dispute.
7. That the cause of action arose on 03, October 2010, when the defendant wrongfully entered into the possession of the suit land & dispossessed the plaintiff therefrom denying his title over the suit land.
8. That the suit land is situated in Dhaka within the jurisdiction of this Court, this Court has jurisdiction to try the suit.
9. That the value of the subject matter of the suit for the purpose of the Court fee & jurisdiction is fixed at Tk. 5,00000 & the plaintiff paid advalorem court fee on the plaint.
10. That the plaintiff, therefore, prays as follows:
a) Possession of the property as stated in Schedule 'A' to the plaint after declaring of the plaintiff's title thereto.
b) Pass such other or further relief as to which the plaintiff maybe found entitled to in law & in equity.
SCHEDULE-A
District- Gazipur, Police Station- Shreepur, Mouza- Razabari,
C.S KHATIAN NO. 1066
S.A KHATIAN NO. 3359
R.S KHATIAN NO. 5463
R.S DAG NO. 152
TYPES OF LAND: Agricultural land
AREA OF LAND: 33 decimals
Verification
Verified at Gazipur this 01 of January, 2011 the contents of Para 1-10 are true to the best of my knowledge & belief.
……………………..
Signature