Ref: ALS.replyoflegalnotice.2025.9. Dated:
REPLY TO LEGAL NOTICE
BY REGISTERED POST WITH A/D
To,
Muhammad Abdul Karim
Advocate, Supreme court of Bangladesh
For Mohiuddin & Associates.
Paramount Heights, Suit No-5D2, (5th Floor),
65/2/1, Box Culvert Road, Purana Palton, Dhaka.
On behalf of IFIC Bank PLC, Banasree Branch,
House No- 00, Road- 00, Block- C, Banasree, Rampura, Dhaka.
———- Reply Receiver
From,
Muhammad Mohiuddin
Advocate, Dhaka Judge Court
12, Bishwa Sahitto Kendro Road, Banglamotor, Shahbag, Dhaka.
Mobile- 01711-068609
———- Appointed Lawyer.
On behal of
1. Ms. Momotaj Begum
Wife of Kabir Ahmed Talukder
Daughter of Halim Talukder and Morium Begum,
Mobile: 01927-285455
2. Mr. Ali Hossain
Son of Kabir Ahmed Talukder and Nasrin Kabir
Mobile: 01532-260088
Both Address- Flat B-10 (5th floor), House-10, Block- E, Road-5, Banasree, Post-Khilgaon, Thana-Rampura, Dhaka
———- Reply Sender
Subject: Reply to your Legal Notice of 20/08/2025 A.D
Dear Sir,
Our clients have instructed us to serve a reply against your provided legal notice. Upon received your legal notice our client’s reply against your notice as follows:
1. That the description regarding the loan amount of Tk 50,00,000/- on 31/10/2022 A.D mentioned in para 1 in your notice is acknowledged by our clients.
2. That the description regarding the loan amount of Tk 50,00,000/- on 18/06/2023 A.D mentioned in para 2 in your notice is acknowledged by our clients.
3. That the description regarding the Deed of Mortgage being No. 13443 dated 10.11.2022 executed by Mrs. Nasreen Kabir in favor of your client mentioned in para 3(i) in your notice is acknowledged by our clients.
That the description regarding the Irrevocable Power of Attorney being No.6023 dated 31.05.2023 executed by Mrs. Nasreen Kabir to empower your client to sell the mortgaged property mentioned in para 3(ii) in your notice is acknowledged by our clients.
That the description regarding the Personal Guarantee of Mrs. Nasreen Kabir and Mr. Amir Hossain and the Usual charge documents mentioned in para 3(iii) and 3(iv) in your notice are acknowledged by our clients.
4. That the description regarding the availing of facilities and the failure of repayment mentioned in para 4 in your notice is not fully correct which is partially denied by our clients. Because my clients has more 7 years’ time duration for the full payment.
5. That the description regarding the best endeavor by your client for amicable step to recover the legitimate dues of your client mentioned in para 5 in your notice is not fully correct which is denied by our clients.
6. That the description regarding the outstanding liability inclusive of interest on the loan contract as on 30.06.2025 stands at Tk. 43,11,348.51 (Taka Forty Three Lac Eleven Thousand Three Hundred Forty Eight Point Five One) is not correct and this is not acknowledged by our clients. Because actually our client’s due amount is Tk 8,55,941.39 on 15/09/2025 A.D.
7. That regarding the civil and criminal legal action mentioned in the last part of your notice is your personal matter. We have no comments on this.
The True Facts
A. That our clients received loan Tk 20,00,000/- and 20,00,000/- consecutively by the Sanction Letter No. TWB/BNSR/AB/2022/189 dated 31.10.2022 and 5245/LO1406202300169 dated 18.06.2023 issued by your client that is IFIC Bank PLC, Banasree Branch, Dhaka.
B. That from December 2022 to 15 September 2025 our clients have paid total approx. Tk 7,76,540/- as monthly instalment and our clients are actually owe to your client Tk 8,55,941.39.
C. That your client has already instituted a CR Case no 195/25 under the Negotiable Instrument Act, 1881 for this same issue.
D. So, in this circumstance for peaceful and amicable solution your client is requested to give my client a tolerable time to repay your client’s legitimate dues. Our clients were in some critical family problem which was informed earlier to your client as well as Head office of IFIC bank PLC. Our clients will pay the missing due amount within short time insha Allah.
A copy of this notice is kept in our office for future reference.
Thanking you.
Yours faithfully,
Muhammad Mohiuddin
Advocate
01711-068609
Copy to-
The Manager, The World Bank PLC
Banasree Branch
House-00, Road-00, Block-C, Banasree, Rampura, Dhaka-1219