Shaukat Ali, son of Abdul Gani, residents of…………………. Allahabad…………. Defendants. The above-named plaintiff begs to state as follows: 1.
That the parties to the suit are Sunni Mohammedans. 2. That the plaintiff was married to M. Abdul Gani, now deceased father. 3. That M. Abdul Gani died on January 24, 1955, leaving two sons, Ramzan Ali, defendant No. 1, and Shaukat Ali, defendant No.
2, who are in possession of the assets left by their deceased father. 4. That the amount of dower was not fixed either before or at the time of marriage or after marriage. 5. That in view of the circumstances explained in paragraph 4, the plaintiff is entitled to a proper dower. 6.
That the plaintiff is entitled to a sum of Rs. 50,000/- taking into consideration the status of her deceased husband who was an I.C.S. officer. 7. That the plaintiff has made several demands, but the defendants have paid no heed to them.
8. That the plaintiff is not in possession of any of her deceased husband’s property. 9. That the cause of action arose on January 24, 1955, when M.
Abdul Gani died on March, 15, 1955, when the last demand made by the plaintiff was turned down by the defendants and the court has jurisdiction to try this suit. 10. That the valuation of the suit for the purposes of jurisdiction in Rs. 50,000/- and a court-fee of Rs….
payable on the said sum is being paid. The plaintiff claims Rs. 50,000/- with interest from the date of suit to that of payment from assets of M. Abdul Gani deceased now in the hands of the defendants. (Sd.
) Bibl Fatima. I, Bibi Fatima, do hereby verify that the contents of paragraphs 1 to 10 are true to my personal knowledge and information. Verified at Allahabad on (Sd.) Bibi Fatima (Sd.) Advocate (b) In the Court of Civil Judge, Allahabad Suit No……… of 1955 Bibi Fatima, w/o Abdul Gani, resident of…………….. Plaintiff 1.
Ramzan Ali, son of Abdul Gani, resident of………………. Allahabad………. Defendants. 2. Shaukat Ali, son of Abdul Gani, resident of……………… Allahabad……… Defendants. Defendant No. 1 begs to state as follows: 1.
Paragraphs 1 and 2 of the plaint are admitted. 2. The defendant denies so much of paragraph 3 of the plaint which says that the defendant No. 1 is also in possession of the assets of Abdul Gani deceased, rest of it is admitted. 3. The defendant was living separately before the death of his father, Abdul Gani, and does not know anything about the assets of his father.
Therefore, the suit be dismissed as against him and costs awarded. I, Ramzan Ali, verily that the contents of paragraphs 1 to 3 are true to my personal knowledge and information. (Sd. Ramzan Ali) Defendant No. 1 (Sd.