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M. Rafique v. Mst. Rukhsana Begum

Specific Performance - Rejection of the "Pardanashin Lady" Plea

Facts

The plaintiff sought specific performance for the sale of a residential house. The defendant lady resisted, claiming her husband had deceived her, she was coerced into signing, and as a pardanashin (veiled/secluded) lady, she lacked independent understanding of the contract.

Through a Court Witness (the stamp vendor), the following was established:

  • 01

    The defendant was not a pardanashin lady in the legal sense.

  • 02

    She appeared in person, signed voluntarily, and understood the nature of the document.

  • 03

    She never reported the alleged fraud to any authority and failed to challenge the document promptly.


Judicial Findings

The Court disbelieved the defence, observing it was a "calculated attempt to wriggle out of a concluded contract." The suit was decreed, affirming that the plea of being a pardanashin lady cannot be used as a shield where evidence demonstrates conscious execution.


Legal Significance

This landmark ruling clarifies that the special protections afforded to a pardanashin lady are not absolute and cannot be exploited to retroactively invalidate validly executed commercial or property agreements when independent volition and practical comprehension are evident from the facts.

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