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Ref: Date: 06.03.2016

RE-REPLY AGAINST REPLY
(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.
------- Re-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.
---------- Re-reply of Notice Sender.
Md. Khalilur Rahman
Advocate, Supreme Court of Bangladesh.
-------- On behalf of Sender.
Sub: Re-reply of the reply of the legal notice served by you dated16.02.2016 and received on
22.02.2016 being the reference No. 46/16.
Dear Sir,
Being instructed and authorized by my respected client I served a legal notice upon you, the notice
receiver named Md. Khosrul Alam Tushar dated 11.01.2016 in English for and on behalf of my
client named Mausumi Akter specially requesting you to pay the full amount of maintenance, dower
and others as payment Tk. 27,60,001/- (Twenty seven lakh sixty thousand one taka) only within
15 (Fifteen) days of receiving this legal notice. But thereafter the learned Advocate Mr. Nanda Dulal Das
replied this legal notice dated 16.02.2016 in Bengla on your behalf which is received by me as well as
my client dated 22.02.2016 partly admitting the facts and circumstances of the legal notice and agreed to
pay the amount of taka demanded and mentioned in the said legal notice. Since the English version
legal notice replied by the learned Advocate in Bangla, it proves that you, the notice receiver as well as
your learned lawyer could not perceive the meaning of the facts and circumstances of the legal notice. I
hereinafter referred to as ''Notice Sender' I do hereby for and on behalf of my client put you this re-reply
of the reply of the legal notice as follows:
1. That you, Md. Khosrul Alam Tushar, the notice receiver was married with my client
Mousumi Akter, dated 13.11.2009 as per The Muslim Marriage and Divorce Registration
Act-1974 with the dower of Tk.5,00,001/= (Five lakh one taka) only. At the time of the
execution of marriage, you paid nothing as dower. In this case, the full amount of dower Tk.
5,00,001/= (Five lakh one taka) only which should be paid by you to my client whenever it
is demanded. As the husband, you are bound to make the payment of the dower to my
client without delay.
This clause has been entirely admitted by you as stated in the clause No. 2 of the reply of
the legal notice. After that you mentioned in the reply of the legal notice as per the
instruction of your client about the ornaments and others as amount of Tk. 5,00,000/- (Five
lakh taka) are given by the guardian of my client. Because at the time of marriage your
client was entirely jobless and he had no any source of income. So, all the expenses were
borne by the guardian of my client. In that case, the statement made by you is completely
false, fabricated and concocted.
2. That after the execution your marriage, both of you started living together as the legal
husband and wife. During your conjugal life with my client, she conceived and has
subsequently given birth a male baby. But you never maintained your family properly. But
sometimes, you mentally differ yourself from your wife regarding your undisciplined life style
and haphazard thinking. You always like to make anarchism in the family enforcing your wife
to lead her life as per the instruction of your parents. You and your parents demanded dowry
of Tk. 10,00,000/- (Ten lakh taka) only from my client several times for your own business
purpose. Whenever, my client expressed her incapacity to give that handsome amount of
money by bringing that from her parents, you and your parents jointly started torture upon
her physically and mentally. Otherwise, you kept yourself ready to breach the peace of your
family. By making a commotion with a simple issue, you and your parents have jointly
tortured her inhumanly. It is mentionable that, you as well as your parents never good
behaved with my client.

Though as per the instruction of your client you have denied the facts of this clause in
clause No. 3 of the reply made by you. But my client as well as her guardians are able to
prove this facts of giving Tk. 10,00,000/- (Ten lakh taka) only to your client. So, your client
has not disclosed the real fact to you. Thereafter you have stated in this clause about
“Happy Living Developers Limited”. But you have not mentioned here about the identity and
position of your client relating to this developers company. So, this statement is false and
fabricated. It is also mentionable that my client is enough matured, major and qualified to
take any better decision regarding herself. She needs not persuaded by her elder sister and
her brother in law. So, such false and fabricated statement is denied by my client. You have
also used in your writing as ‘Black mailing your client by my client”. It seems to me that your
client is nothing but a vagabond and baseless. Actually your client has expressed it just to
protect himself.
3. That after this marriage the guardian of my client has given living things to you; (1)
Gold/ornaments Tk. 5,50,000/- (Five lakh fifty thousand taka only), (2) Sofa-Tk. 75,000/-
(thirty five thousand taka), (3) Wood Coat Tk. 50,000/-(Forty thousand taka), (4) Dressing
Table Tk. 35,000/- (Twenty five taka), (5) Ware Drop Tk. 40,000/- (Thirty thousand taka), (6)
Wood Almirah Tk. 40,000/- (Thirty thousand taka), (7) Refrigerator Singer Tk. 60,000/- (Sixty
thousand taka) and others Tk. 50,000/- (Fifty thousand taka), Total Tk. 9,00,000/- (Nine lakh
taka) only.
In replying this clause and clause 4 of your reply, you have denied but did not explain in
details. I earlier mentioned that your client was never capable to maintain his wife and never
gave a single item to his wife.

4. That after marriage you misbehaved and tortured my client by demanding dowry Tk.
10,00,000/- (Ten lakh taka) only several times for your own business purpose. The guardian
of my client has given you total Tk.10,00,000/- (Ten lakh taka) only several times for your
business purpose with a view to secure the peace and happiness of my client. Yet you and
your parents continued torturing upon my client instead of living with my client happily by
performing your duties and responsibilities as her husband by giving maintenance to your
wife and only son. In this stage, getting no alternative, my client divorced you on 02.08.2015
and has sent the divorce letter on 04.08.2015.
This clause has been entirely admitted by you as well as your client in the clause 5 of the
reply made by you.

5. That my client and her baby are living in the residence of her sister. You have been living in
your residence at Narayangonj by leaving your wife and son. In this sense, you have not
giving maintenance to my client and her baby for about 12 (Twelve months). For this reason,
you have to pay maintenance per month Tk. 30,000X12= total amounted as Tk. 3,60,000/-
(Three lakh sixty thousand taka) only. In this way, you have to pay my client Tk.
9,00,000+10,00,000+5,00,001+3,60,000/-= Total Tk. 27,60,001/- (Twenty seven lakh sixty
thousand one taka) only.
 This clause has been admitted by you without explaining the facts about the living place of
the wife and son of your client. Actually your client was never capable to bear any expense
for his wife and son. Now facing some practical difficulties he makes false statement to
everywhere just to save himself from his evil doings.

From the above of page 8 of the reply made by you of the legal notice you have stated that
my clients has misappropriated the amount of Tk. 25,00,000+38,00,000= Tk. 63,00,000/-
(Sixty three lakh taka) only coming from Malaysia. But you have totally failed to explain the
process of doing this. You and your client jointly like to explain as your mental wish. Actually
you can’t establish the real facts.

In considering the circumstances stated above, through this re-reply of the reply of the legal notice
you are finally requested to pay the full amount of maintenance and dower Tk. 27,60,001/-
(Twenty seven lakh sixty thousand one taka) only to my client within 07 (Seven) days of
receiving this legal notice. In the event of your failure to pay the said amount of money 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 Court of Learned Assistant Judge (Family Court), Dhaka
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)