Riyaz Reply Notice
Riyaz Reply Notice
D.N. Dhurgasha
Advocate,
Madras High Court
Advocate Association,
High Court, Parrys,
Chennai – 600 104.
Sir,
Sub : Reply to your Legal Notice sent to Mr. K. Mahmood Hussain dated
23.02.2021
Ref : Your Legal Notice dated 23.02.2021.
We are concerned for our Client, Mr.K.Mahmood Hussain and under the
instructions of and behalf of our Client we are issuing this reply notice to you:
1. At the very outset, the allegations and the averments contained in the notice
under reply, unless otherwise specifically traversed and admitted herein, are
strictly denied and refuted. It is stated that your Client has not apprised you
with correct facts and thereby the aforementioned legal notice is without any
basis, unfounded and does not merit any consideration.
2. My Client states that, as far as paragraph No.1 of your notice is concerned
my client admits the fact that you have been inducted as a tenant on
11.07.2018 for a monthly rent of Rs. 15,000/- and had also paid a sum of Rs.
1,50,000/- towards advance sum security deposit. The averments that your
Client had intimated my Client regarding the vacation of the premises on or
before 28.02.2019 is frivolous and denied and in parallel your client is put to
strict proof of the same.
3. My Client states that, the paragraph No. 2 of the notice is frivolous and
strictly denied and in parallel your client is put to strict proof of the same. It
is stated that, your client has been inducted as a tenant in the aforesaid
scheduled premises on 11.07.2018 and was in occupation and running the
office until 10.06.2019. However, during the month of January 2019, your
client had approached my client and had informed that your client business
has met unforeseen downfall and thereby there has aroused financial
constrain for your Client and henceforth informed that he is vacating the
scheduled premises. Though my Client has instructed your client that he
shall take it as notice of termination as per Clause 14 of the Rental
Agreement dated 11.07.2018 and to that effect the 6 months notice period
shall commence. My Client states that, he had thereafter issued a Cheque
bearing No. 000442 drawn on ICICI Bank, Nandanam, Chennai for a sum of
Rs. 30,000/- dated 11.06.2019 and had further requested a month time to pay
the balance amount of Rs. 30,000/- out of the total advance amount of Rs.
1,50,000/- after examining the Electricity Bill due and wear and tear if any.
My Client also states that, your client had received the Cheque and had
endorsed to that effect.
4. My Client states that, the allegations contained in paragraph No.3 of your
notice is vexatious and is vehemently denied and my client puts your client
to strict proof of the same. It is pertinent to note that, my Client had taken
considerable steps when he the fact that the Cheque which he had issued had
been dishonored and wherein My Client had settled the entire balance