চেক ডিসওনার মামলার আরজি ইংরেজি ফরমেট বা নমুনা
IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, DHAKA
(MM COURT NO. )
C.R. CASE NO. OF 2025
IN THE MATTER OF :
An application under Section 138 of the Negotiable Instruments Act, 1881 [(as amended by the Act No. III of 2006 (with effect from 9th February, 2006)].
AND
IN THE MATTER OF :
MD JAHANGHIR MIA,
S/o Hazi Abdul Barek Mia & Hazi Alfon Nesa,
House-3, Road-19, Block-D, Section-6, Mirpur,
Pallabi, Dhaka-1216
———–Complainant.
– VERSUS –
(1) MD. RAYHAN CHOWDHURY,
S/o: Md. Shahab Uddin Chowdhury & Nasima Chowdhury
Mailing Address:
34/21, Pallabi, Section-12, Mirpur, Pallabi, Dhaka-1216
Mobile No: 01888-556262
(2) SANJIDA ISLAM SHATHI,
Wife of Md. Rayhan Chowdhury,
Daughter of Md. Shahidul Islam & Jharna Akter,
Mailing Address:
34/21, Pallabi, Section-12, Mirpur, Pallabi, Dhaka-1216
Mobile No: 01888-556262
————-Accused.
Witness:
1. The Complainant
2. Md. Razib Hossain,
House-3, Road-19, Block-D, Section-6, Mirpur,
Pallabi, Dhaka-1216
Mobilr No- 01740-592679
Place of occurrence : At the resident of the Complainant.
Date of occurrence : (a) Issue of Cheque : 27.04.2025
(b) Cheque Dishonored : 30.04.2025
(c) Date of Notice : 26.05.2025
(d) Cause of action arose on : 24.06.2025
The humble petition on behalf of the complainant named above most respectfully –
House-3, Road-19, Block-D, Section-6, Mirpur, Pallabi, Dhaka-1216
S H E W E T H :
- That the Complainant, MD JAHANGHIR MIA, was an expatriate in Saudi Arabia (KSA). But now he is residing at the above-mentioned address (House-3, Road-19, Block-D, Section-6, Mirpur, Pallabi, Dhaka-1216) in Dhaka. Both of the Accused No 1 and the Complainant were employed at a car showroom named Padma Car (Padma Car, Beside BRTA office, Mirpur-13, Dhaka) together. By virtue of working together the Accused No 1 became very closer with the Complainant. As a result, there was a good relation among the Accused No 1, the Accused No 2 & the Complainant. Based on this good relationship the Accused No. 1 & 2 proposed to the Complainant to give Accused No 1 Tk 10,00,000/- (ten lac taka) to invest in the newly planned business of the Accused No. 1 as capital money and the Accused No. 1 offered the Complainant to give Tk 35,000/- (thirty-five thousand taka) per month as profit as well as the Accused No. 1 promised to return the full capital money intact on completion of the contract.
- According to the proposal of the Accused No 1, the Complainant gave the Accused No. 1, Tk 10,00,000/- (ten lac taka) as capital money on 29/03/2023 A.D as investment and Tk 1,90,000/- (one lac ninety thousand taka) for an Italian visa processing. So the Accused No. 1 received Tk 11,90,000/- (eleven lac ninety thousand taka) as capital money.
- After that the Accused No 1, paid 30,000/- (Thirty thousand) to the Complainant as monthly profit for few months. After few months the Accused No. 1 stopped to pay the profit amount to the Complainant even the Accused No. 1 did not return the capital amount of money to my client.
- After that on 28/10/2024 A.D in presence of some local honorable people the Accused No. 1 & the Accused No. 2 made a contract with my client on non-judicial stamp paper (stamp value Tk 300/-) in which the Accused No. 1 & 2 promised to pay the capital money Tk 11,90,000/- (Eleven lac ninety thousand taka) to the Complainant in five installment which were mentioned in the contract as follows:
| Installment | Date | Taka to be paid |
| 1st installment | 31/01/2025 | 2,40,000/- |
| 2nd installment | 27/02/2025 | 2,40,000/- |
| 3rd installment | 31/03/2025 | 2,40,000/- |
| 4th installment | 30/04/2025 | 2,40,000/- |
| 5th installment | — | 2,30,000/- |
| Total = | 11,90,000/- | |
In word Eleven lac ninety thousand.
5. That according to the contract mentioned above the Accused No. 1 gave the Complainant 2 (two) security checks of Dutch Bangla Bank Limited whose account no. is 164.151.490458 and other information as follows-
| Check No | Date | Amount (tk) |
| SB/A 1632553 | 27/04/2025 | 7,00,000/- |
| SB/A 1632556 | 27/04/2025 | 3,00,000/- |
| Total | 10,00,000/- | |
In word: Ten lac taka.
6. According to the contract made among the Accused No. 1, the Accused No.2 and the Complainant as well as the checks provided by the Accused No. 1, the Complainant deserves the following amount of money to the Accused No. 1 as shown in the table below:
| Description | Deserved Amount (Tk) |
| As mentioned in the contract and provided checks | 10,00,000/- |
| As mentioned in the contract | 1,90,000/- |
| Profit amount till May 2025 (These profit will be increased time to time) | 2,25,000/- |
| Total | 14,15,000/- |
In word: fourteen lac fifteen thousand taka.
7. In spite of being committed by the written contract and provided checks mentioned above the Accused No. 1 & 2 did not pay the deserved amount to the Complainant. Therefore, in view of the above circumstances, the Accused No. 1 & 2 are liable to pay the Complainant Tk 10,00,000/- (ten lac tk) covered by Cheque No. SB/A 1632553 & 1632556 both dated 27/04/2025 of Dutch-Bangla Bank Limited issued by the Accused No. 1 in favor of the Complainant, Taka 1,90,000/- (One lac ninety thousand tk) as mentioned in the contract made among the Accused No. 1, the Accused No.2 and the Complainant which the Accused No. 1 took as capital money as well as Tk 2,25,000/- (two lac twenty five thousand taka) as monthly profit till May 2025 (monthly profit will be added in course of time), that is total deserved amount is Tk (10,00,000+1,90,000+ 2,25,000)= 14,15,000/- (fourteen lac fifteen thousand taka).
8. That thereafter in compliance with the provision of Section 138 of the Negotiable Instruments Act, 1881, the complainant, on 26.05.2025 sent a legal notice upon the Accused No. 1 & 2 by registered post (with acknowledgement due) demanding payment of the aforementioned cheque amount with profit within 30 (thirty) days of the receipt of notice. But the Accused No. 1 & 2 did not come forward to adjust the cheque amount within the stipulated period mentioned in the notice, that is, within 24.06.2025.
9. That issuance of such cheque for discharging any debt or liability and subsequent dishonour due to “Insufficient Fund” is a criminal offence on the part of the issuer of such cheque in accordance with the provision of Section 138 of the Negotiable Instruments Act, 1881 (as amended).
10. That the aforementioned cheque was issued by the accused and has been dishonored by the drawee Bank on the ground of “Closed, dormant or blocked” which made the accused criminally liable and to be punished accordingly.
11. That the cause of action to file this Complaint Case arose on 24.06.2025 when the accused failed to make the payment within stipulated time mentioned in the notice and the said cause of action is continuing till date.
12. That in view of the facts and circumstances stated above, this Court may take cognizance in accordance with Section 138 & 141 of the Negotiable Instruments Act, 1881 and the accused no. 1 & 2 should be brought to justice as provided under Section 138 of the Negotiable Instruments Act, 1881.
Wherefore, it is humbly prayed that the learned Court may graciously be pleased to take cognizance of the offence under Section 141 of the Negotiable Instruments Act, 1881, issue warrant of arrest against the accused no. 1 & 2 and bring the accused to justice for the offence committed by them under Section 138 of the Negotiable Instruments Act, 1881 and pass such other or further order or orders as the Court may deem fit and proper.
And for this act of kindness the complainant, as in duty bound, shall ever pray.
যেকোন আইনি সহায়তার জন্য আমাদের সাথে যোগাযোগ করুন-
যোগাযোগ
আইনবিদ ল’ প্যালেস
অন-স্টপ লিগ্যাল সলিউশন
সার্বিক পরিচালনায়- এডভোকেট মুহাম্মদ মহীউদ্দীন (শিশির)
এলএল.বি, এলএল.এম, এমবিএ
চীফ এডভাইজার
কোর্ট চেম্বার- ১৬, কৈলাশঘোষ লেন, ঢাকা জজ কোর্ট, কোতোয়ালী, ঢাকা।
অথবা
ইভিনিং চেম্বার- রোড-৫, ব্লক-এ, বনশ্রী, রামপুরা, ঢাকা
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