Reply of - Notice

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Ref: Date: 14.02.2016

REPLY OF LEGAL NOTICE
(By Registered Post with A/D)
1. Md. Khosrul Alam Tushar
S/O- Md. Abdus Salam & Morsheda Begum.
Village- Rupgonj, Post Office- Rupgonj,
Police Station- Rupgonj, District- Narayangonj.
2. Nanda Dulal Das

Advocate, Supreme Court of Bangladesh.
Chamber: Hall Room No. 2,
Supreme Court Bar Association Bhaban,
Shahbag, Dhaka-1000. Mobile: 01834-895680.
------- Reply of the Notice Receivers.
Mausumi Akter
D/O: Late M.A Kuddus & Khaleda Begum
Village- Dighulia, Post Office- Dighulia,
Police Station- Tangail, District- Tangail.
Present Address: Khan Tower, Level-5,
51, Sonargaon Janopath, Sector-7,
Uttara, Dhaka-1230.
---------- Reply of Notice Sender.
Md. Khalilur Rahman
Advocate, Supreme Court of Bangladesh.
-------- On behalf of Sender.
Sub: Reply of the Legal Notice served by you dated 07.02.2016 and received on
11.02.2016 being the reference No. 44/16.
Dear Sir,
Being instructed and authorized by my client hereinafter referred to as ''Reply of the Legal Notice' I do
hereby for and on behalf of my client put you this reply of your legal notice as follows:
1.That you Nanda Dulal Das Advocate, Supreme Court of Bangladesh have served a legal notice for
and on behalf of your client named Md. Khosrul Alam Tushar to my client named Mausumi Akter
dated 07.02.2016 being the reference No. 44/16 which is received by her dated 11.02.2016.
2.That in the legal notice served by you upon my client, in Para No. 1 you have stated that as
per the provision of Islami Shara Shariate, a marriage has been executed between my client
named Mausumi Akter and your client named Md. Khosrul Islam Alam Tushar dated
13.11.2009 in the presence of the close relatives of the both parties with the dower Tk.
5,00,001/- (Five lakh one taka) only without dowry. In that case both of them have started
their conjugal life. It is entirely admitted by my client. But the true fact is that after the
execution of marriage and at the time of living together as husband and wife, your client
himself changed his personal character by demanding dowry while having one after another.
3.That in Para No. 2 of your legal notice, you have stated that after marriage your client has
given some ornaments of gold of Tk. 3,00,000/- (Three lakh) and saree and others which
amounts equally Tk. 5,00,000/- (Five lakh taka) only. It is quite denied by my client. Actually
the guardian of my client gave those things after marriage.
4.That in Para No. 3, what you have stated that you have given the maintenance of the son
and your wife is denied by my client. Actually my client herself bears all maintenance of the
family. Your client was never capable to bear the maintenance of my client.
5.That in Para No. 4 what you have stated is denied by my client. Actually it is easy to explain in writing.
The statement what you have mentioned in this Para is entirely false and fabricated. It is mentionable
that in sub Para 4(cha) that your client went to Malaysia thinking about the future of my client and their
only son Monajat Alam Mugdho with the Director visa Factory-1 and started business there dated
13.09.2013 having the passport No. AF-6747980. It is quite denied by my client. Thereafter your client
brought my client and their only son to Malaysia with the own cost of your client. Whereas my client
misappropriated Tk. 48,00,000/- (Forty eight lakh taka) only. It is denied by my client.
6.That in Para No. 5 you have stated is denied by my client. This statement is completely false and
fabricated.
7.That in Para No. No. 6 what you have stated is denied by my client. This statement is completely
false and fabricated.
8.That the statement of Para No. 7, 8, 9, 10 and 11 are entirely denied by my client. Because these are
the statements are falsie, fabricated and concocted.
9.That the statements what you have made in the legal notice and served upon my client is not
authentic at all. These are quite false and fabricated.
In considering the circumstances stated above as the reply of your legal notice, you have the legal
obligation to prove the allegation against my client by producing the relevant documents within 15
(Fifteen) days of receiving this legal notice. In the event of your failure to do so in the nick of time or
within the stipulated period, I have very strict instruction from my client to initiate the legal action by
filing the case against you in the competent Court of the original jurisdiction and criminal cases in
other forums under the law of the land.
The risk, responsibility and consequence as to the costs of such legal action shall lie solely upon you.
A copy of this legal notice is retained in our office for future reference.
Thanking you
--------------------------------
(Md. Khalilur Rahman)

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Ref: Date: 14.02.2016

2. Nanda Dulal Das

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