06 December 2021

Judgement passed in the Family Suit No. 64/2019 (Child Custody)

                                                      BANGLADESH FORM NO. 3701

HIGH COURT FORM NO. (J) 2

HEADING OF JUDGEMENT IN ORIGINAL SUIT/CASE

District: Rajshahi

In the Court of Family Judge (Mohonpur), Rajshahi

Present: Md. Abdul Malek, Senior Assistant Judge

Family Suit No. 64/2019 

Mr. Md. Shahibul Islam, Plaintiff Versus Mrs. Morium Nesa (Mou), Defendant 

The suit’s coming on trial from 17/01/21 to 30/09/2021.

In the presence of

Mr.               ….……....Leaned Advocate for the Plaintiff.

Mr.             ................Leaned Advocate for the Defendant.

And having stood for consideration to this day, the Court delivered the following judgment: This is a family suit for child custody.

The Plaint in the nutshell:

A daughter named Mst. Fariha Khatun was born in the womb of the Defendant at the Plaintiff’s paternal legitimacy. In the aftermath, due to family feud, the defendant and plaintiff repudiated their marital tie on compromise on 08/09/2017. As per the provision of the agreement made in between, the child in question had been in the plaintiff’s custody since 08.09.2017. But the defendant went away along with the child from the plaintiff’s custody and control on 11/01/2018. Since then, the child in question has been in the custody of his mother defendant. The plaintiff claims that because the defendant has already married to another man, and this mother is not taking care of his daughter in an appropriate manner, she is not entitled to the child custody. The plaintiff also claims that for the sake of the child’s proper care, education and good health, he is entitled to her custody. In such conditions, when he claimed the child custody from his mother on 06/09/19, the latter declined to the same as such; and hence is the suit.

The Written Statement in brief:

The Defendant No. 01 contested the suit by filing written statement denying the material averments made in the plaint. He contended inter alia that the Plaintiff lacks in locus standi, the impugned facts lack in veracity, and the very suit is legally untenable, unjustifiable; and dismissible for cloudy cause of actions. The Defendant also stated that she is her biological mother and offers a safe place for her. The child in question has been in her custody since their marriage was dissolved. She also claims that if the child is given in the plaintiff’s custody, she would not be properly cared, treated, educated, and overseen. In addition, she objects to the plaintiff’s custody over the child because the latter even does not know the actual name of the child in question that evidences negligence to the child. Hence, the suit deserves to be dismissed with costs.

Issues:

Considering the pleadings of the parties, the issues are framed with modifications for discussion in the following way:

1.    Whether the suit is maintainable in the present form and manner.

2.   Whether the plaintiff is entitled to get custody of the minor in questions.

3.   Whether the plaintiff is entitled to get remedy as prayed for.

Discussions and Decisions:

In proof of the claims, the Plaintiff examined himself as PW 01; and produced other two witnesses as PW2-3 and some documents marked as exhibit No. 01-02. On the other side, the Defendant in support of her claim examined herself as DW- 01; and produced another witness as DW-02. After-trial reconciliation attempts become failed and arguments from both parties are heard.

Issue No. 1, 2 and 3:

All issues are jointly taken up for brevity, convenience, and cohesion. Upon considering the materials on record, it unambiguously appears that both the parties in their pleadings admitted by that ‘during the continuation of the wedlock between the plaintiff and the defendant No. 01, the minor child (defendant No. 02) was born in the womb of the Defendant at the Plaintiff’s paternal legitimacy. It is also admitted that their wedlock exists no more; and the minor daughter has been in the custody of the defendant mother since 11/01/2018. Since evidence shows that the minor child is now in the custody of the defendant mother, the suit is hereby held to be maintainable in the present forma and manner. 

 

02. Now, the court is to decide upon whether the plaintiff should get custody of the child in question. It is trite to highlight that the plaintiff is a father and the defendant is a mother of the daughter child in question. Evidence shows (birth certificate) that the child in question is less than seven years old. Undoubtedly, the general principle of Muslim law prioritizes the fathers’ custody of older boys and the mothers of older girls. Since the law of child custody in such a situation gives a preferential right of custody to the mother until and unless she is disqualified, it cogently appears that the mother defendant holds preferential positions over the plaintiff father. 

 

03. To put points relating the facts of any disqualification attributed to the custodian mother, the plaintiff claims in his pleading the existence of marriage of the mother defendant with another man; firstly, with one Rafiqul Islam, and secondly, with one Md. Ibrahim. In proof of his claims, he also submitted the copy of their Nikahnama (Ext: 02) and asserted in his evidence (PW-01) that although the defendant’s marriage with Rafiqul Islam exists no more, the defendant is now residing with Md. Ibrahim. So, it becomes clear that the plaintiff claims that the defendant's remarriage with the latter disqualifies the former from being entitled to the custody of the child in question. 

 

04. Conversely, the defendant expressed in her cross-examination that her marital tie was established with Ibrahim but it was repudiated later on, and thus, currently she has not been residing with any of her husband. In evidence, the defendant custodian mother is recurrently seen to gainsay the existence of any marriage with any man right now. Instead, she reiterated his living in her father’s house with the child in question. The maternal grandfather of the child also deposed as DW-01 and is vividly found to be concurrent with the position of the custodian mother defendant. Even, the PW-03, who is the father of the plaintiff, also supported the defendant’s custody in a way that the minor daughter child is now staying with her mother defendant under the shelter of the child’s maternal grandfather. In addition, the evidence adduced by the PW-02 carries the plaintiff nowhere so far as the current marital status of the defendant and the residence of the child in question. Accordingly, the evidence available on record suggests that the custodian defendant is now out of any marital knot and has been residing along with her minor child in her father’s house. Hence, the court holds that the plaintiff-side has not substantiated the disqualification of the defendant on the ground of remarriage with weighty and convincing evidential materials. 

 

05. Moreover, the plaintiff underscores in his pleading that since the custodian mother is not taking care of his daughter in an appropriate manner, she is not entitled to child custody. The plaintiff also expressed his apprehension that as long as the minor is in his mother’s custody, she would not properly be raised and brought up to be a good man. As a result, for the sake of the child’s proper care, education and good health, he claims that he is entitled to the custody of the child in question. But it appears on the record that although the plaintiff claims as such, in evidence, he neither put any collaborative causes, nor his other supporting witnesses did the same while standing in the witness-box. Moreover, the custodian mother was made subject to cross-examination, but it sheds no light in his favor on such points. However, PW-02 & 03 in their evidence, narrated that they tried to take up the child in their custody on behalf of the plaintiff from the custody of the defendant, but they put forward no sufficient relevant justifications for why the court should hand over the child to the plaintiff. In addition, the PW-02 clarified his evidential proposition by saying that he does not know the child's whereabouts. That being so as such, such words of comparative advantage equips the plaintiff with no armor. 

 

06. Another point is also mentionable that the father’s right of Hizanat is preferential only in the absence of ‘an able-mother’. The evidence on record tells the court that the plaintiff father offers no such better position than the mother defendant. In such conditions, it is to be kept in mind that the parent's earning capacity does not determine custody, but the capacity to provide a safe and secure environment does. Hence, it would be verbose to comment that the principle on which custody is decided is the ‘best interests of the child’. It may, for example, be a case that even a mother who is a housewife can gain custody of the child and the father will be asked to provide child support. Deciding facts include who can take better care of the child’s emotional, educational, social and medical needs is to be favored. The court is thus of view that the materials on the record does not adequately gives rapport to the existence of closer bonding and emotional ties between the plaintiff and the child than that of the mother.

 

07. Furthermore, in pleading and evidence, the plaintiff noticeably underscores that the defendant has relinquished her custodian rights due to an agreement made between them at the time of their marriage dissolution. In evidence, the plaintiff as DW-01 placed the copy of the agreement marked as exhibit No. 01. As a result, there arises a contention about whether the provision of the agreement made between them shall determine the suit's fate so far as the custody of the child. For this, an issue as to the status of such an agreement requires to be figured out now. As per condition No. 04 of the agreement, the child was handed over to the plaintiff’s custody at that time. Surprisingly, it also conditions that no party shall be allowed to take legal actions regarding the child custody in agreement. 

 

08. As aforesaid, it is admitted that the child in question is now in her mother’s custody. So, the plaintiff has already lost the physical custody of the child. In addition, in case of child custody, a bar to take legal recourse by any party appears to be abusive and untenable under the law of child custody, where the child’s best interest prevail in all circumstances. Besides, the agreement seems executed in a sitting where their wedlock got repudiated. The custodian defendant as DW-01, asserted in her cross-examination that she is not able to recall the incident of such an agreement. As a matter of fact, it could happen so far for any person in such an undergoing case. Accordingly, in contextualizing the issues mentioned above and considering applicable laws and purposes of the suit, it can be opined that the legal position of the contract law ought to be taken into consideration in the instant occasion: a contract (agreement) is voidable under at the option of the party who undergoes as such. 

 

09. Pertinently, it is well established that the quality of the relationship between the children and each parent is of paramount consideration; and thus, ‘the thinking has shifted from custody and access being the ‘right of a parent’ to being the ‘right of a child’. It also transpires in evidence (vide PW 01-03, DW-01 & DW-02) that the plaintiff father could not have in the child’s best interest demonstrated sufficient evidence to prove his comparative advantage with regard to his capacity and disposition to give the child love, affection, and guidance and to continue the education and rearing of the child. On that premise, it is not skeptic that the whole fabric of the materials on record conspicuously favors the defendant mother in the present context.

 

10. Again, it is concurrently contextual that the general principle of Muslim law prioritizes fathers’ custody of older boys and mothers of older girls, but it is not a strict rule and is primarily decided based on the child’s interests (best interest consideration). Therefore, only the mother holds the ultimate right to seek her child/children’s custody under the Right of Hizanat as long as she is not convicted or found guilty of any misconduct; that is to say, there is no confirmed evidence of domestic violence, abuse, or neglect by mother defendant. The whole evidential paradigm of the suit at hand does not demonstrate that the defendant mother is proven to neglect or ill-treat the child, or found guilty of any misconduct committed to the child, that could oust her custody rights. 

 

In consideration of pleadings, facts, surrounding circumstances, evidence of both oral and documentary on record, it appears before the Court that the suit deserves to be dismissed on the contest. However, this is not a suit relating to office or property; it is a suit that impacts the life and interest of a child in question. Hence, despite the suit being dismissed, the non-custodial father can get different types of access to the child based on circumstances and convenience, i.e., weekly, fortnightly, daily or monthly visitation rights. It can be a day or overnight access. It could also be free access with no fixed schedule, but as per the parents’ and the child’s convenience.