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Legal Notice

1) The document is a legal notice sent by Advocate Kirti Vashistha on behalf of his client Rajesh Kumar to Mohit Kumar regarding a loan of Rs. 2,00,000 that was given in 2016 and not repaid. 2) Mohit Kumar had sought several extensions to repay the loan and eventually gave Rajesh Kumar a cheque for Rs. 2,00,000 which bounced due to Mohit closing his bank account. 3) The notice demands that Mohit repay the amount within 15 days or legal action will be initiated against him.

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Ananaya Sachdeva
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86% found this document useful (7 votes)
21K views577 pages

Legal Notice

1) The document is a legal notice sent by Advocate Kirti Vashistha on behalf of his client Rajesh Kumar to Mohit Kumar regarding a loan of Rs. 2,00,000 that was given in 2016 and not repaid. 2) Mohit Kumar had sought several extensions to repay the loan and eventually gave Rajesh Kumar a cheque for Rs. 2,00,000 which bounced due to Mohit closing his bank account. 3) The notice demands that Mohit repay the amount within 15 days or legal action will be initiated against him.

Uploaded by

Ananaya Sachdeva
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Kirti Vashistha Chamber No.

F-709, F-Block
th
Advocate 7 Floor, Lawyers Chambers
Block, Kakardooma Courts
DELHI HIGH COURT Delhi-110032
Ph: 9868013999
==================================================================
Ref: Date: 05.02.2018

REGD. POST/SPEED POST


LEGAL NOTICE
To,
SH MOHIT KUMAR
S/o LATE SH. BHUSHAN KUMAR,
R/O E-109, UPPER GROUND FLOOR,
CHHATTARPUR EXTENSION,
DELHI-110074

Sir,
Under instructions from and on behalf of my
client SH RAJESH KUMAR, S/O LATE SH MURARI LAL,
R/O 114-116, BLOCK-D, B.K. DUTT COLONY, JOR
BAGH, NEW DELHI-110003 I hereby serve you
through this following legal notice, facts as
under:-

1. That you noticee and my client having


friendly relations with each other from last
so many years and having visiting terms with
each other.

2. That in the month of June-2016, you


approached to my client and requested for a
friendly loan of Rs.2,00,000/- (Rupees Two
Lacs only) for a period of one year for your
urgent need and after considering the
friendly relations with you my client gave a
sum of Rs.2,00,000/- (Rupees Two Lacs only)
to you in cash in the presence of marginal
witnesses and at the time of borrowing the
aforesaid amount, you assured my client to
return the abovesaid amount within one year.

3. That after passing about one year i.e. in


the month of June-2017, my client approached
to you noticee and demanded the aforesaid
friendly loan amount of Rs.2,00,000/-
(Rupees Two Lacs only), but at that time,
you noticee showed your inability to pay the
same and sought some more time of 4-5 months
from my client and my client on believing
your words, kept waited for your payment.

4. That consequently in the month of December,


2017, my client again approached you and
demanded the aforesaid borrowed amount of
Rs.2,00,000/- (Rupees Two Lacs only), then
you noticee in discharge of your above said
liability, issued a cheque bearing No.000036
dated 10.01.2018 amounting to Rs.2,00,000/-
drawn on Kotak Mahindra Bank, Noida Branch,
U.P, in favour of my client and at the time
of issuing the said cheque you assured my
client that at the time of presentation the
said cheque would be encashed.

5. That my client had presented the said cheque


with his banker i.e. ICICI Bank, Branch at:
Jor Bagh, Delhi, but the said cheque was
dishonored by his banker with the remarks
“ACCOUNT CLOSED” vide returning memo dated
12.01.2018.

6. That immediately my client contacted to you


and disclosed the fact about the dishonor of
said cheque and my client demanded the said
cheque amount in cash from you, but since
then you are kept passing the time by one
pretext to another and now you instead of
making the payment of the said cheque, you
have flatly refused to pay the said cheque
amount to my client in any manner and had
also extended threats to face dire
consequences.

7. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have closed your account and
thus you breached the trust of my client and
committed an offence punishable under
section 138 of N.I. Act R/W Section 406/420
of Indian Penal code.

I, therefore call upon you through


this legal notice to return the amount of
above said dishonoured cheque i.e.
Rs.2,00,000/- (Rupees Two Lac only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constraint to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.

Kirti Vashistha
Advocate
PRAMOD KUMAR Seat No.1, 1st Floor, F-Block,
Advocate Lawyers Chambers Block,
Karkardooma Courts,
Delhi -110032.
====================================================
Ref. No. DATED: 20.01.2018

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
SH. AMISH GOEL,
ADVOCATE,
AT: CHAMBER NO.321,
NEW LAWYERS CHAMBERS COMPLEX,
SECTOR-12, KARNAL,

Sir,
My client (1) M/S IRAM INTERIOR PRIVATED
LIMITED, (2) MOHD. SHAHID SIDIQUI and (3) MS.
SITARA, ALL AT: D-2/1317, KABIR NAGAR, BABARPUR,
SHAHDARA, DELHI-110032 has placed before me your
legal notice dated 24.11.2017 sent by you on
behalf of your client DLA Industries Pvt. Ltd.
at Nagla Megha Chowk, Modipur Road, Karnal,
through its Director Mr. Pankaj Arora, and my
clients instructed me to give the reply of the
same and brought true facts into your knowledge,
which facts are as under:-

PRELIMINARY OBJECTIONS:-
1. That the notice sent by you on behalf of
your client is totally false, baseless and
bogus and your client has suppressed the
material facts from you and sent the
present false notice.
2. That your client has concealed the true
and material facts from your good self and
has not come to you with clean hands.
3. That the true fact is that my client is
doing the business of interior and
decorator in the name and style of M/s
Iram Interior Pvt. Ltd., at the
aforestated address.
4. That your client contacted my client and
disclosed that he is doing the business of
supply of laminates sheets and requested
my client to give him some orders for
supplying the laminates sheets.
5. That consequently my client placed order
to your client for supply laminates sheets
and your client at that time assured my
clieny that he will provide the best
quality laminates sheets to my client, but
thereafter, when my client received the
said laminates sheets, he found that the
laminates sheets supplied by your client
are of very inferior and low quality and
the same were not upto the mark of
satisfaction at all.
6. That my client contacted your client and
requested him to take back all his
supplied laminates sheets and also
requested to supply the laminates sheets
of good quality as assured by your client
at the time of placing the order, but your
client totally failed to do so.
7. That all the articles supplied by your
client are still lying with my client and
my client despite issuing the aforesaid
cheque to your client is in great loss and
crisis.
8. That my client is not liable to pay even a
single penny to your client in any manner
and your client is liable to return the
said cheque bearing No.937091 dated
11.11.2017 amounting to Rs.7,79,783/-drawn
on Yes Bank to my client with immediate
effect and your client is also entitled to
take away his all supplied material/
laminates sheets from my client as your
client has cheated my client by supplying
the laminates sheets of low and inferior
quality.
9. That my client also reserves his right to
initiate separate legal proceedings agaist
your client for his abovesaid act of
cheating and criminal breach of trust.

REPLY ON MERITS:-
1.5. That the contents of Para No.1 to 5 of
the legal notice are wrong and denied in
Toto. However, it is submitted that the
preliminary objections may kindly be read as
part and parcel and the same are not being
repeated herein for the sake of brevity.

I, therefore, call upon you through this


reply to recall back/withdraw your legal
notice dated 24.11.2017. If your client did
not do so, then my client instructs me to
initiate appropriate legal action against
your client under the penalized law, on your
client’s costs, risks and consequences.

Copy kept in my office for further


future references.

PRAMOD KUMAR
ADVOCATE
Shyam Kumar Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-1661/2007 M:- 9868613511
Ref: Dated: 22.01.2018

REGD. A.D./SPEED POST


STATUTORY NOTICE U/S 80 OF CPC, 1908
To,
THE SECRETARY,
CENTRAL BOARD OF SECONDARY EDUCATION

AT: CBSE BUILDING,


PREET VIHAR COMPLEX,
VIKAS MARG, BEHIND PETROL PUMP,
DELHI-110092

ALSO AT:-
CBSE BUILDING, PS 1-2,
INSTITUTIONAL AREA, I.P EXTN.,
PATPARGANJ, DELHI-110092

Sir,
Under the instructions from and on behalf of
my client Ms. Shagun Sachdeva, D/o Sh. Sham
Sachdeva, R/o C-212, Narwana Apartment, 89, I.P.
Extension, Patparganj, Delhi-110092, I hereby
serve upon you with the following legal notice:
1. That my client is a peace loving and law
abiding citizen and is residing at the above
given address and having full faith over the
due process of law.

2. That my client has passed her Secondary


class from you noticee i.e. CBSE in the
year-2015 vide her Roll No.8121262 and the
date of birth of my client is mentioned as
25.11.2000. Thereafter my client has passed
her Senior Secondary class from you noticee
i.e. CBSE in the year-2017 vide her Roll
No.9118058.

3. That it is relevant to note here that as per


the Birth Certificate of my client issued by
Municipal Council, Ambala, her date of birth
is mentioned as 25.11.1999, which is her
actual and correct date of birth, but
inadvertently due to bonafide mistake and
oversight, the date of birth of my client
has been wrongly mentioned in her
qualification records as 25.11.2000 instead
of 25.11.1999.

4. That recently my client has applied for


issuance of passport, but the concerned
passport authority has raised objection
regarding mentioning of different date of
birth in both the documents i.e. one in the
birth certificate and another in the
qualification certificates of my client.

5. That my client is facing very hardships and


problems due to mentioning of her wrong date
of birth in her qualification documents/
certificates.

6. That it would be expedient and in the


interest of justice that you noticee may
mention the correct date of birth of my
client in her qualification documents
thereby rectifying her exact date of birth
i.e. 25.11.1999 instead of her wrong date of
birth i.e. 25.11.2000 for all future
purposes and to avoid any inconvenience,
hence this notice.

I, therefore call upon you through this


legal notice to kindly mention the correct
date of birth of my client in her
qualification documents thereby rectifying
her exact date of birth i.e. 25.11.1999
instead of her wrong date of birth i.e.
25.11.2000 for all future purposes and to
avoid any inconvenience, within 60 days from
the receipt of this legal notice, failing
which my clients shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

Shyam Kumar
Advocate
Shyam Kumar Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-1661/2007 M:- 9868613511
Ref: Dated: 19.01.2018

REGD. A.D./SPEED POST


STATUTORY NOTICE U/S 80 OF CPC, 1908
To,
THE SECRETARY,
CENTRAL BOARD OF SECONDARY EDUCATION

AT: CBSE BUILDING,


PREET VIHAR COMPLEX,
VIKAS MARG, BEHIND PETROL PUMP,
DELHI-110092

ALSO AT:-
CBSE BUILDING, PS 1-2,
INSTITUTIONAL AREA, I.P EXTN.,
PATPARGANJ, DELHI-110092

Sir,
Under the instructions from and on behalf of
my client Mr. Mukesh Sachdeva, D/o Sh. Sham
Sachdeva, R/o C-212, Narwana Apartment, 89, I.P.
Extension, Patparganj, Delhi-110092, I hereby
serve upon you with the following legal notice:

1. That my client is a peace loving and law


abiding citizen and is residing at the above
given address and having full faith over the
due process of law.

2. That my client has passed his Secondary


class from you noticee i.e. CBSE in the
year-2011 vide his Roll No.8115272 and the
date of birth of my client is mentioned as
19.09.1995. Thereafter my client has passed
his Senior Secondary class from you noticee
i.e. CBSE in the year-2013 vide his Roll
No.9111757.

3. That it is relevant to note here that as per


the Birth Certificate of my client issued by
Municipal Council, Ambala, his date of birth
is mentioned as 19.09.1994, which is his
actual and correct date of birth, but
inadvertently due to bonafide mistake and
oversight, the date of birth of my client
has been wrongly mentioned in his
qualification records as 19.09.1995 instead
of 19.09.1994.

4. That recently my client has applied for


issuance of passport, but the concerned
passport authority has raised objection
regarding mentioning of different date of
birth in both the documents i.e. one in the
birth certificate and another in the
qualification certificates of my client.

5. That my client is facing very hardships and


problems due to mentioning of his wrong date
of birth in his qualification documents/
certificates.

6. That it would be expedient and in the


interest of justice that you noticee may
mention the correct date of birth of my
client in his qualification documents
thereby rectifying his exact date of birth
i.e. 19.09.1994 instead of her wrong date of
birth i.e. 19.09.1995 for all future
purposes and to avoid any inconvenience,
hence this notice.

I, therefore call upon you through this


legal notice to kindly mention the correct
date of birth of my client in his
qualification documents thereby rectifying
his exact date of birth i.e. 19.09.1994
instead of her wrong date of birth i.e.
19.09.1995 for all future purposes and to
avoid any inconvenience, within 60 days from
the receipt of this legal notice, failing
which my clients shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

Shyam Kumar
Advocate
C.P. SINGH Chamber No.F-612, F-Block,
ADVOCATE Sixth Floor, Lawyers Chamber
Karkardooma Courts Complex,
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1649/01 M:- 9818512101
Ref. No. DATED: 22.01.2018

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HAIDER ALI,
PROP. OF M/S A.R. ENTERPRISES,
AT: G-71/A, SHAHEEN BAGH,
NEAR BUS STAND SHAHEEN BAGH, P.S OKHLA,
NEW DELHI-110044

Sir,
Instructions received from and on behalf of
my client Sh. Raj Kumar, S/o Sh. Birda Yadav,
R/O Jhuggi No.140, Subhash Camp, Badarpur, New
Delhi, also at: Village Parsada, Post Mason,
Tehsil Mohammadabad, Ghazipur, U.P., I hereby
serve upon you through this following legal
notice facts as under:-

1. That my client had been appointed by you


noticee as “Mason/Painter” on daily wages
and my client has been working with you
noticee for the last about 10 years for
the said work.
2. That it is relevant to point out here that
you noticee is the Contractor of the work
of construction and you noticee used to
engage my client for the said work on
daily wages.

3. That consequently you noticee as usually


engaged my client for the Mason/
Painting /POP work at Irish Tower, Near
Shubhash Chowk, Village Tikri, Gurgaon,
Haryana and my client done all the work as
directed by you noticee and upto your
complete satisfaction.

4. That it is relevant to note here that


during the said work, my client has
requested you noticee to make some initial
payments, but you noticee assured my
client that you will make the whole
payment after completin of the work.

5. That it is further pertinent to note here


that it was agreed between my client and
you noticee that you will pay Rs.450/- per
day and half of the same for over time and
Rs.100/- as conveyance expnses and
fooding.
6. That my client had worked for 37 days (@
Rs.450/- per day) and 19 days overtime (@
Rs.225/- per day), 02 days double overtime
(@ Rs.450/- per day) and 04 night shift (@
Rs.900/- per day) and by this way as per
the statement of account maintained by my
client, you noticee were under the
liability to make the payment of
Rs.29,125/- (Rupees Twenty Nine Thousand,
One Hundred and Twenty Five only) and out
of which you noticee paid only Rs.20,000/-
to my cliet and you are still liable to
pay a sum of Rs.9,125/- (Rupees Nine
Thousand, One Hundred and Twenty Five
only) to my client alongwith interest at
the tune of 24% p.a.

7. That my client requested you noticee on


several occasions to make the aforesaid
payment of Rs.9,125/- (Rupees Nine
Thousand, One Hundred and Twenty Five
only), but you noticee kept passed the
time by one pretext or the other with the
malafide intention and ulterior motives to
cause wrongful loss to my client and
wrongful gain to yourself.
8. That you noticee are legally liable as
well as bound to make the payment of
Rs.9,125/- (Rupees Nine Thousand, One
Hundred and Twenty Five only), hence this
notice.

I, therefore call upon you through this


legal notice to make the payment of the due
amount of Rs.9,125/- (Rupees Nine Thousand,
One Hundred and Twenty Five only) to my
client, within 15 days from the date of
receipt of this legal notice, failing which
my client shall be constrained to initiate
appropriate legal proceedings against you
totally on your costs, risks and
consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.

C.P. Singh
Advocate
C.P. SINGH Chamber No.F-612, F-Block,
ADVOCATE Sixth Floor, Lawyers Chamber
Karkardooma Courts Complex,
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1649/01 M:- 9818512101
Ref. No. DATED: 22.01.2018

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HAIDER ALI,
PROP. OF M/S A.R. ENTERPRISES,
AT: G-71/A, SHAHEEN BAGH,
NEAR BUS STAND SHAHEEN BAGH, P.S OKHLA,
NEW DELHI-110044

Sir,
Instructions received from and on behalf of
my client Sh. Shiv Kumar S/o Sh. Birda Yadav,
R/O Jhuggi No.140, Subhash Camp, Badarpur, New
Delhi, also at: Village Parsada, Post Mason,
Tehsil Mohammadabad, Ghazipur, U.P., I hereby
serve upon you through this following legal
notice facts as under:-

1. That my client had been appointed by you


noticee as “Mason/Painter” on daily wages
and my client came in contact with you
noticee through Sh. Raj Kumar.
2. That it is relevant to point out here that
you noticee is the Contractor of the work
of construction and you noticee used to
engage my client for the said work on
daily wages.

3. That consequently you noticee as usually


engaged my client for the Mason/
Painting /POP work at Irish Tower, Near
Shubhash Chowk, Village Tikri, Gurgaon,
Haryana and my client done all the work as
directed by you noticee and upto your
complete satisfaction.

4. That it is relevant to note here that


during the said work, my client has
requested you noticee to make some initial
payments, but you noticee assured my
client that you will make the whole
payment after completin of the work.

5. That it is further pertinent to note here


that it was agreed between my client and
you noticee that you will pay Rs.450/- per
day and half of the same for over time and
Rs.100/- as conveyance expnses and
fooding.
6. That my client had worked for 26 days (@
Rs.450/- per day) and 17 days overtime (@
Rs.225/- per day), 03 days double overtime
(@ Rs.450/- per day) and 03 night shift (@
Rs.900/- per day) and by this way as per
the statement of account maintained by my
client, you noticee were under the
liability to make the payment of
Rs.22,175/- (Rupees Twenty Two Thousand,
One Hundred and Seventy Five only) and out
of which you noticee paid only Rs.44,000/-
to my cliet and you are still liable to
pay a sum of Rs.17,775/- (Rupees Seventeen
Thousand, Seven Hundred and Seventy Five
only) to my client alongwith interest at
the tune of 24% p.a.

7. That my client requested you noticee on


several occasions to make the aforesaid
payment of Rs.17,775/- (Rupees Seventeen
Thousand, Seven Hundred and Seventy Five
only), but you noticee kept passed the
time by one pretext or the other with the
malafide intention and ulterior motives to
cause wrongful loss to my client and
wrongful gain to yourself.
8. That you noticee are legally liable as
well as bound to make the payment of
Rs.17,775/- (Rupees Seventeen Thousand,
Seven Hundred and Seventy Five only),
hence this notice.

I, therefore call upon you through this


legal notice to make the payment of the due
amount of Rs.17,775/- (Rupees Seventeen
Thousand, Seven Hundred and Seventy Five
only) to my client, within 15 days from the
date of receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate legal proceedings
against you totally on your costs, risks and
consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.

C.P. Singh
Advocate
C.P. SINGH Chamber No.F-612, F-Block,
ADVOCATE Sixth Floor, Lawyers Chamber
Karkardooma Courts Complex,
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1649/01 M:- 9818512101
Ref. No. DATED: 22.01.2018

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HAIDER ALI,
PROP. OF M/S A.R. ENTERPRISES,
AT: G-71/A, SHAHEEN BAGH,
NEAR BUS STAND SHAHEEN BAGH, P.S OKHLA,
NEW DELHI-110044

Sir,
Instructions received from and on behalf of
my client Sh. Rahul S/o Sh. Lal Chand, R/O
Jhuggi No.140, Subhash Camp, Badarpur, New
Delhi, I hereby serve upon you through this
following legal notice facts as under:-

1. That my client had been appointed by you


noticee as “Mason/Painter” on daily wages
and my client came in contact with you
noticee through Sh. Raj Kumar.

2. That it is relevant to point out here that


you noticee is the Contractor of the work
of construction and you noticee used to
engage my client for the said work on
daily wages.

3. That consequently you noticee as usually


engaged my client for the Mason/
Painting /POP work at Irish Tower, Near
Shubhash Chowk, Village Tikri, Gurgaon,
Haryana and my client done all the work as
directed by you noticee and upto your
complete satisfaction.

4. That it is relevant to note here that


during the said work, my client has
requested you noticee to make some initial
payments, but you noticee assured my
client that you will make the whole
payment after completin of the work.

5. That it is further pertinent to note here


that it was agreed between my client and
you noticee that you will pay Rs.450/- per
day and half of the same for over time and
Rs.100/- as conveyance expnses and
fooding.

6. That my client had worked for 16 days (@


Rs.450/- per day) and 8 days overtime (@
Rs.225/- per day) and by this way as per
the statement of account maintained by my
client, you noticee were under the
liability to make the payment of
Rs.10,600/- (Rupees Ten Thousand Six
Hundred only) and out of which you noticee
paid only Rs.3,000/- to my cliet and you
are still liable to pay a sum of
Rs.7,600/- (Rupees Seven Thousand Six
Hundred only) to my client alongwith
interest at the tune of 24% p.a.

7. That my client requested you noticee on


several occasions to make the aforesaid
payment of Rs.7,600/- (Rupees Seven
Thousand Six Hundred only), but you
noticee kept passed the time by one
pretext or the other with the malafide
intention and ulterior motives to cause
wrongful loss to my client and wrongful
gain to yourself.

8. That you noticee are legally liable as


well as bound to make the payment of
Rs.7,600/- (Rupees Seven Thousand Six
Hundred only), hence this notice.

I, therefore call upon you through this


legal notice to make the payment of the due
amount of Rs.7,600/- (Rupees Seven Thousand
Six Hundred only) to my client, within 15
days from the date of receipt of this legal
notice, failing which my client shall be
constrained to initiate appropriate legal
proceedings against you totally on your
costs, risks and consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.

C.P. Singh
Advocate
C.P. SINGH Chamber No.F-612, F-Block,
ADVOCATE Sixth Floor, Lawyers Chamber
Karkardooma Courts Complex,
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1649/01 M:- 9818512101
Ref. No. DATED: 22.01.2018

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HAIDER ALI,
PROP. OF M/S A.R. ENTERPRISES,
AT: G-71/A, SHAHEEN BAGH,
NEAR BUS STAND SHAHEEN BAGH, P.S OKHLA,
NEW DELHI-110044

Sir,
Instructions received from and on behalf of
my client Sh. Surender, R/O Jhuggi No.140,
Subhash Camp, Badarpur, New Delhi, I hereby
serve upon you through this following legal
notice facts as under:-

1. That my client had been appointed by you


noticee as “Mason/Painter” on daily wages
and my client came in contact with you
noticee through Sh. Raj Kumar.

2. That it is relevant to point out here that


you noticee is the Contractor of the work
of construction and you noticee used to
engage my client for the said work on
daily wages.

3. That consequently you noticee as usually


engaged my client for the Mason/
Painting /POP work at Irish Tower, Near
Shubhash Chowk, Village Tikri, Gurgaon,
Haryana and my client done all the work as
directed by you noticee and upto your
complete satisfaction.

4. That it is relevant to note here that


during the said work, my client has
requested you noticee to make some initial
payments, but you noticee assured my
client that you will make the whole
payment after completin of the work.

5. That it is further pertinent to note here


that it was agreed between my client and
you noticee that you will pay Rs.450/- per
day and half of the same for over time and
Rs.100/- as conveyance expnses and
fooding.

6. That my client had worked for 5 days (@


Rs.450/- per day) and 5 days overtime (@
Rs.225/- per day) and 01 night shift (@
Rs.900/- per day) and by this way as per
the statement of account maintained by my
client, you noticee were under the
liability to make the payment of Rs.4775/-
(Rupees Four Thousand Seven Hundred and
Seventy Five only) and out of which you
noticee paid only Rs.3900/- to my cliet
and you are still liable to pay a sum of
Rs.875/- (Rupees Eight Hundred and Seventy
Five only) to my client alongwith interest
at the tune of 24% p.a.

7. That my client requested you noticee on


several occasions to make the aforesaid
payment of Rs.875/- (Rupees Eight Hundred
and Seventy Five only), but you noticee
kept passed the time by one pretext or the
other with the malafide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.

8. That you noticee are legally liable as


well as bound to make the payment of
Rs.875/- (Rupees Eight Hundred and Seventy
Five only), hence this notice.

I, therefore call upon you through this


legal notice to make the payment of the due
amount of Rs.875/- (Rupees Eight Hundred and
Seventy Five only) to my client, within 15
days from the date of receipt of this legal
notice, failing which my client shall be
constrained to initiate appropriate legal
proceedings against you totally on your
costs, risks and consequences.
Copy kept in my office for further
references.

C.P. Singh
Advocate
C.P. SINGH Chamber No.F-612, F-Block,
ADVOCATE Sixth Floor, Lawyers Chamber
Karkardooma Courts Complex,
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1649/01 M:- 9818512101
Ref. No. DATED: 22.01.2018

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HAIDER ALI,
PROP. OF M/S A.R. ENTERPRISES,
AT: G-71/A, SHAHEEN BAGH,
NEAR BUS STAND SHAHEEN BAGH, P.S OKHLA,
NEW DELHI-110044

Sir,
Instructions received from and on behalf of
my client Sh. Guddu, R/O Jhuggi No.140, Subhash
Camp, Badarpur, New Delhi, I hereby serve upon
you through this following legal notice facts as
under:-

1. That my client had been appointed by you


noticee as “Labour” on daily wages and my
client came in contact with you noticee
through Sh. Raj Kumar.

2. That it is relevant to point out here that


you noticee is the Contractor of the work
of construction and you noticee used to
engage my client for the said work on
daily wages.

3. That consequently you noticee as usually


engaged my client for the labour work at
Irish Tower, Near Shubhash Chowk, Village
Tikri, Gurgaon, Haryana and my client done
all the work as directed by you noticee
and upto your complete satisfaction.

4. That it is relevant to note here that


during the said work, my client has
requested you noticee to make some initial
payments, but you noticee assured my
client that you will make the whole
payment after completin of the work.

5. That it is further pertinent to note here


that it was agreed between my client and
you noticee that you will pay Rs.300/- per
day and half of the same for over time and
Rs.100/- as conveyance expnses and
fooding.

6. That my client had worked for 12 days (@


Rs.300/- per day) and 5 days overtime (@
Rs.150/- per day) and by this way as per
the statement of account maintained by my
client, you noticee were under the
liability to make the payment of Rs.5550/-
(Rupees Five Thousand Five Hundred and
Fifty only) and out of which you noticee
paid only Rs.2100/- to my cliet and you
are still liable to pay a sum of
Rs.3,450/- (Rupees Three Thousand Four
Hundred and Fifty only) to my client
alongwith interest at the tune of 24% p.a.

7. That my client requested you noticee on


several occasions to make the aforesaid
payment of Rs.3,450/- (Rupees Three
Thousand Four Hundred and Fifty only), but
you noticee kept passed the time by one
pretext or the other with the malafide
intention and ulterior motives to cause
wrongful loss to my client and wrongful
gain to yourself.

8. That you noticee are legally liable as


well as bound to make the payment of
Rs.3,450/- (Rupees Three Thousand Four
Hundred and Fifty only), hence this
notice.

I, therefore call upon you through this


legal notice to make the payment of the due
amount of Rs.3,450/- (Rupees Three Thousand
Four Hundred and Fifty only) to my client,
within 15 days from the date of receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
legal proceedings against you totally on
your costs, risks and consequences.
Copy kept in my office for further
references.

C.P. Singh
Advocate
Ved Prakash Masih Chamber No.F-423, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1898/99 M. 9818613737
Ref: DATE: 19.01.2018

REGD.A.D./SPEED POST
LEGAL NOTICE
To,
M/S LADDU SHAH JEWELLERS
Through its PROP.
SH GURUSHARAN BHOLA,
AT: 1274-A, MAIN ROAD,
BHOLA NATH NAGAR,
NEAR BABU RAM SCHOOL,
SHAHDARA, DELHI-110032

Sir,
Under instructions from and on behalf of my
client SMT. NEELAM BHARDWAJ, W/O SH. SANJAY
BHARDWAJ, R/O 98, GURU ANGAD NAGAR EXTN., LAXMI
NAGAR, DELHI-110092, I hereby serve upon you
through this following legal notice, facts as
under:-

1. That you noticee is running your shop of


jewellers at the above said address.
2. That my client and her family are the old
customers of you noticee and consequently
my client approached you noticee and
requested for a gold bangal of her desired
design and for the said purpose you
noticee received Rs.80,000/- (Rupees
Eighty Thousand only) from my client in
eight installments.

3. That thereafter in the month of December,


2017, my client approached to you noticee
and demand her gold bangals as ordered,
but you noticee failed to provide the same
on pretext of your personal issue and
hence in discharge of your above said
liability, you noticee issued, signed and
delivered a cheque bearing No.560186 of
Rs.80,000/-, dated 01.01.2018, drawn on
State Bank of India, branch at Bhola Nath
Nagar, Shahdara, Delhi, and you noticee
assured to my client that the said cheque
would be honoured positively at the time
of its presentation in its banker.

4. That consequently as per your assurances


and as per your instructions, my client
has deposited the said cheque in her
banker i.e. Punjab National Bank, Branch
at Laxmi Nagar, Delhi, but the said cheque
was dishonoured by your banker with the
remarks “FUNDS INSUFFICIENT”, and my
client received the information through
returning memo dated 09.01.2018.

5. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

6. That you for discharging your liability,


issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.80,000/- (Rupees Eighty Thousand only)
to my client within 15 days from the
receipt of this legal notice, failing
which my client shall be constraint to
initiate appropriate criminal u/s 138 N.I.
Act as well as civil proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/-
as fee of this legal notice.
Copy kept in my office for further
references.

V.P. MASIH
ADVOCATE
Shyam Kumar Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-1661/2007 M:- 9868613511
Ref: Dated: 19.01.2018

REGD. A.D./SPEED POST


STATUTORY NOTICE U/S 80 OF CPC, 1908
To,
THE SECRETARY,
CENTRAL BOARD OF SECONDARY EDUCATION

AT: CBSE BUILDING,


PREET VIHAR COMPLEX,
VIKAS MARG, BEHIND PETROL PUMP,
DELHI-110092

ALSO AT:-
CBSE BUILDING, PS 1-2,
INSTITUTIONAL AREA, I.P EXTN.,
PATPARGANJ, DELHI-110092

Sir,
Under the instructions from and on behalf of
my client Ms. Shagun Sachdeva, D/o Sh. Sham
Sachdeva, R/o C-212, Narwana Apartment, 89, I.P.
Extension, Patparganj, Delhi-110092, I hereby
serve upon you with the following legal notice:
7. That my client is a peace loving and law
abiding citizen and is residing at the above
given address and having full faith over the
due process of law.

8. That my client has passed her Secondary


class from you noticee i.e. CBSE in the
year-2015 vide her Roll No.8121262 and the
date of birth of my client is mentioned as
25.11.2000.

9. That thereafter my client has passed her


Senior Secondary class from you noticee i.e.
CBSE in the year-2017 vide her Roll
No.9118058.

10. That it is relevant to note here that as per


the Birth Certificate of my client issued by
Municipal Council, Ambala, her date of birth
is mentioned as 25.11.1994, which is her
actual and correct date of birth, but
inadvertently due to bonafide mistake and
oversight, the date of birth of my client
has been wrongly mentioned in her
qualification records as 25.11.2000 instead
of 25.11.1999.
11. That recently my client has applied for
issuance of passport, but the concerned
passport authority has raised objection
regarding mentioning of different date of
birth in both the documents i.e. one in the
birth certificate and another in the
qualification certificates of my client.

12. That my client is facing very hardships and


problems due to mentioning of her wrong date
of birth in her qualification documents/
certificates.

13. That it would be expedient and in the


interest of justice that you noticee may
mention the correct date of birth of my
client in her qualification documents
thereby rectifying her exact date of birth
i.e. 25.11.1999 instead of her wrong date of
birth i.e. 25.11.2000 for all future
purposes and to avoid any inconvenience,
hence this notice.

I, therefore call upon you through this


legal notice to kindly mention the correct
date of birth of my client in her
qualification documents thereby rectifying
her exact date of birth i.e. 25.11.1999
instead of her wrong date of birth i.e.
25.11.2000 for all future purposes and to
avoid any inconvenience, within 60 days from
the receipt of this legal notice, failing
which my clients shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

Shyam Kumar
Advocate
Shyam Kumar Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-1661/2007 M:- 9868613511
Ref: Dated: 19.01.2018

REGD. A.D./SPEED POST


STATUTORY NOTICE U/S 80 OF CPC, 1908
To,
THE SECRETARY,
CENTRAL BOARD OF SECONDARY EDUCATION

AT: CBSE BUILDING,


PREET VIHAR COMPLEX,
VIKAS MARG, BEHIND PETROL PUMP,
DELHI-110092

ALSO AT:-
CBSE BUILDING, PS 1-2,
INSTITUTIONAL AREA, I.P EXTN.,
PATPARGANJ, DELHI-110092

Sir,
Under the instructions from and on behalf of
my client Mr. Mukesh Sachdeva, D/o Sh. Sham
Sachdeva, R/o C-212, Narwana Apartment, 89, I.P.
Extension, Patparganj, Delhi-110092, I hereby
serve upon you with the following legal notice:

7. That my client is a peace loving and law


abiding citizen and is residing at the above
given address and having full faith over the
due process of law.

8. That my client has passed his Secondary


class from you noticee i.e. CBSE in the
year-2011 vide his Roll No.8115272 and the
date of birth of my client is mentioned as
19.09.1995.

9. That thereafter my client has passed his


Senior Secondary class from you noticee i.e.
CBSE in the year-2013 vide his Roll
No.9111757.

10. That it is relevant to note here that as per


the Birth Certificate of my client issued by
Municipal Council, Ambala, his date of birth
is mentioned as 19.09.1994, which is his
actual and correct date of birth, but
inadvertently due to bonafide mistake and
oversight, the date of birth of my client
has been wrongly mentioned in his
qualification records as 19.09.1995 instead
of 19.09.1994.

11. That recently my client has applied for


issuance of passport, but the concerned
passport authority has raised objection
regarding mentioning of different date of
birth in both the documents i.e. one in the
birth certificate and another in the
qualification certificates of my client.

12. That my client is facing very hardships and


problems due to mentioning of his wrong date
of birth in his qualification documents/
certificates.

13. That it would be expedient and in the


interest of justice that you noticee may
mention the correct date of birth of my
client in his qualification documents
thereby rectifying his exact date of birth
i.e. 19.09.1994 instead of her wrong date of
birth i.e. 19.09.1995 for all future
purposes and to avoid any inconvenience,
hence this notice.

I, therefore call upon you through this


legal notice to kindly mention the correct
date of birth of my client in his
qualification documents thereby rectifying
his exact date of birth i.e. 19.09.1994
instead of her wrong date of birth i.e.
19.09.1995 for all future purposes and to
avoid any inconvenience, within 60 days from
the receipt of this legal notice, failing
which my clients shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

Shyam Kumar
Advocate
Ved Prakash Masih Chamber No.F-423, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1898/99 M. 9818613737
Ref: DATE: 14.09.2017

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
SH. AMIT GUPTA,
ADVOCATE,
AT: CHAMBER NO.626,
LAWYERS BLOCK, SAKET COURTS,
NEW DELHI-110017

Sir,
My client SH. SUSHIL KUMAR CHIBBER, S/O SH.
RAM SWAROOP CHIBBER, R/O OM SAI APARTMENTS, FLAT
NO.A-12, 1041, WARD NO.8, MEHTA CHOWK, MEHRAULI,
NEW DELHI-110030 has placed before me your legal
notice dated 29.08.2017 sent by you on behalf of
your client MS. UPASANA SINGH, D/O SH. B.B.
NAYYAR, R/O 1092/C, WARD NO.1, MEHRAULI, NEW
DELHI-110030, and my clients instructed me to
give the reply of the same and brought true
facts into your knowledge, which facts are as
under:-
PRELIMINARY OBJECTIONS:-
1. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.

2. That your client did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

3. That the true fact is that your client is a


professional money lender even without any
money lending license and she is doing the
said illegal business under the garb of her
another businesses in the name and style of
M/s Rips Collection & Communication and M/s
Pisces Innovation and she is running her
aforesaid businesses in the vicinity of
Mehrauli, New Delhi and even she is well
known in the locality for lending money to
the needy persons, but she is running her
said illegal business within the collusion
and conspiracy of some local police
officials and goonda elements.

4. That my client is in the business of


colonizing of properties on small scale
basis and due to the said reason he was in
the urgent need of money to promote his
business and due to the said reason my
client came in contact with your client
through one of his common friend.

5. That consequently on 05.10.2015, my client


borrowed a sum of Rs.20 Lacs from your
client for a period of six months and for
the said purpose your client disclosed that
she will charge Rs.9 Lacs as interest on the
said amount of Rs.20 Lacs and for the said
purpose, your client had taken the
signatures of my client on one blank stamp
paper and some blank papers and disclosed
that she will deliver a copy of Loan
Agreement to my client at a later stage.
After passing some days, your client has
given a photocopy of a Loan Agreement
allegedly prepared on dated 05.10.2015 in
favour of my client, but it is also relevant
to point out here that your client
intentionally and deliberately didn’t
mention any interest being charged by her on
the aforesaid amount. It is also pertinent
to mention here that your client had also
taken three cheques from my client for
security purpose i.e. two cheques of Rs.10
Lacs each towards principal amount and one
Cheque of Rs.9 Lacs towards interest, but
your client had not mentioned the cheque of
interest amount in the said loan agreement
intentionally and deliberately.

6. That consequently on 20.10.2015 my client


was further in need for a sum of Rs.10 Lacs,
as he was in short of money for the purpose
which he previously had borrowed the said
loan of Rs.20 Lacs and consequently your
client given Rs.10 Lacs to my client for a
period of six months and again the same
procedure was followed by your client i.e.
your client had taken the signatures of my
client on one blank stamp paper and some
blank papers and disclosed that she will
deliver a copy of Loan Agreement to my
client at a later stage. After passing some
time, your client has given a photocopy of a
Loan Agreement allegedly prepared on dated
21.10.2015 in favour of my client, but it is
also relevant to point out here that your
client intentionally and deliberately didn’t
mention any interest being charged by her on
the aforesaid amount. It is also pertinent
to mention here that your client had also
taken two cheques from my client for
security purpose i.e. one cheque of Rs.10
Lacs towards principal amount and one Cheque
of Rs.4.5 Lacs towards interest, but your
client had again not mentioned the cheque of
interest amount in the said loan agreement
intentionally and deliberately.

7. That thereafter again in the month of


December 2015, my client was again in need
for a sum of Rs.20 Lacs, as he was in the
promotion of his business limitations and
consequently your client given Rs.20 Lacs to
my client and in the middle of January-2016
and at that time also, your client had taken
the signatures of my client on one blank
stamp paper and some blank papers and
disclosed that she will deliver a copy of
Loan Agreement to my client at a later
stage. After passing some time, your client
has given a photocopy of a Loan Agreement
allegedly prepared on dated 19.01.2016 in
favour of my client, but it is also relevant
to point out here that your client
intentionally and deliberately didn’t
mention any interest being charged by her on
the aforesaid amount. It is also pertinent
to mention here that your client had also
taken four blank signed cheques from my
client for security purpose, but mention
only two cheques in the said agreement
intentionally and deliberately with the sole
motive to cause wrongful loss to my client
and wrongful gain to herself.

8. That it is also relevant to point out here


that my client started paying/ returning his
aforesaid borrowed amount to your client
since the month of March-2016 and my client
has paid the full and final payment to your
client upto January-2017 by various modes
viz. cash payment, RTGS. And it is also
relevant to point out here that all the
above said payments were made by my client
in the presence of marginal witnesses and
sometimes by his friend/colleague. And in
the month of January-2017 your client again
taken signatures of my client on blank
papers and stamp paper on the pretext that
this is your formality for closing the loan
account of my client, as my client had
already given the full and final payments to
your client.
9. That on receiving the full and final
payments from my client, your client had
returned previously given five cheques which
were mentioned in the alleged loan
agreements dated 05.10.2015 and 21.10.2015,
but your client had not returned the four
blank signed cheques (including the cheques
in question/dispute) to my client which were
given, with the last borrowed amount of
Rs.20 Lacs, on the pretext that the same
have been misplaced somewhere in the house
and are not traceable and your client had
duly assured my client she will not misuse
the said security cheques of my client in
future in any manner and she will return the
same as and when found in future and due to
previous good relations and dealings, my
client kept faith on your client.

10. That it is also relevant to point out here


that as per the statement of account
maintained by my client, my client has paid
much more amount to your client against the
amount which he had borrowed, viz. my client
had already paid approx. Rs.87,45,000/- to
your client towards his debt of total Rs.50
Lacs only.
11. That now my client has shocked to receive
the present legal notice, as he has come to
know that the above said cheques which were
blank signed and taken by your client for
security purpose, have been misused by your
client with the malafide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to herself,
hence my client is going to file separate
criminal/ legal complaint against your
client for her above said illegal and
unwarranted acts. My client having
sufficient proofs to prove his contention,
which may be produced at the relevant stage.

12. That my client is not liable to pay even a


single penny to your client in any manner,
while it is your client who is liable to
return the said cheques issued for security
purpose to your client.

REPLY ON MERITS:-
1.8. That the contents of Para No.1 to 8 of your
legal notice are wrong, false, and
concocted, hence denied. However, it is
submitted that all the averments and
versions as alleged in the paras under reply
are nothing, but an ill tactics only to
create false evidences against my client,
and the same is total bunch of lies nothing
else. It is further submitted that my client
is not liable to pay even a single penny to
your client in any manner. The contents of
whole Preliminary Objections may be read as
part and parcel as reply of this Para, same
are not being reproduced herein for the sake
of brevity.

I, therefore request you through this


reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my client
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.

Your client is also liable to pay


Rs.11,000/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

V.P. Masih
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
Ref. No. DATED: 19.01.2018

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH NAIM (PARCHUN WALA)
S/o SHAMIM,
R/o AT THE GATE OF NASARIA MASJID,
NEAR BIHARI HOTEL,
E-43/A-218, D-BLOCK,
NEW SEEMAPURI, DELHI-110095

Sir,
Under instructions from and on behalf of my
client NAJRUL, S/o LATE NOOR ISLAM, R/o E-43/A-
1537, NEW SEEMAPURI, DELHI-110095, I hereby
serve upon you through this following legal
notice, facts as under:-
1. That the father of my client late Noor
Islam was the sole and absolute owner of
the property bearing No.E-43/A-218, D-
BLOCK, NEW SEEMAPURI, DELHI-110095, and
after his death in 1991, my abovesaid
client became the owner of his father’s
property as right of inheritance.
2. That my client Sh. Najrul orally inducted
you noticee as tenant in the abovesaid
property on 01.04.2005 on a monthly rent
of Rs.2,000/- with the condition that the
said rent shall be increased by 10% after
every three years.

3. That on 01.04.2017, the monthly rent of


the said tenanted premises was revised to
Rs.2,926/- per month and you the noticee
paid the said rent to my client till April
2017 only, and thereafter you noticee
stopped making the payment of monthly rent
to my client since 01.05.2017.

4. That you noticee are also committing the


misuse of the premises, as you noticee
were allotted the residential premises,
but now you are using the same for
commercial purpose.

5. That my client is also in the bonafide


requirement of the aforesaid property for
living alongwith his wife and two
children, as he has no other property
except the aforesaid property as my client
is living on rent at E-43/A-1537, NEW
SEEMAPURI, DELHI-110095.

1. That my client is not willing to keep you


noticee in the said tenanted premises any
more and terminated your tenancy with
immediate effect.

I, therefore call upon you through


this legal notice that my client does not
wants to keep you as tenant any more in
her premises and terminated your tenancy
with immediate effect, hence I further
call upon you kindly handover the peaceful
vacant physical possession of the said
tenanted premises within stipulated period
or within 15 days after receiving the
present legal notice, failing which my
client shall be constrained to take legal
action against you for getting the
possession of the said tenanted premsies
before the competent court of law totally
on your costs, risks and consequences. You
shall also be liable to pay the damages
and other charges.
I further call upon you through this
legal notice to make the payment of the
outstanding rent amount @ Rs.2,926/- per
month w.e.f. 01.05.2017 to my client
within 15 days from the receipt of this
legal notice, failing which my client
shall be constrained to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5,500/-


as legal expenses to my client.

Copy kept for further references in my


office.

PANKAJ BHUSHAN
ADVOCATE
B.D. Sharma & Associates
Advocate’s
Delhi High Court and Supreme Court of India
Chamber No.F-525, F-Block, Karkardooma Court Complex,
Shahdara, Delhi -110032.
EN. No. D/979B/2000 M. 9868364837
Ref: DATE: 19.12.2017

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH SURESH SINGH,
S/o LATE SH. PARSHU RAM SINGH,
R/O SHOP NO.3, GROUND FLOOR,
SITUATED AT PROPERTY NO.9/214,
GALI NO.6, GHAS MANDI,
KAILASH NAGAR, GANDHI NAGAR,
DELHI-110031

Sir,
Under the instruction from and on behalf of
my client SMT LAL MANI DEVI, W/O LATE SH. HRIDAY
NARAIN PANDEY, R/O Property bearing No.9/214,
GALI NO.6, GHAS MANDI, KAILASH NAGAR, GANDHI
NAGAR, DELHI-110031, I hereby serve upon you
through the following legal notice, which facts
as under:-

2. That the husband of my client late Sh.


Hriday Narain Pandey was the owner of the
property bearing No. 9/214, GALI NO.6,
GHAS MANDI, KAILASH NAGAR, GANDHI NAGAR,
DELHI-110031.

3. That the husband of my client in his


lifetime let out one shop bearing No.3 to
you addressee at a monthly rent of Rs.27/-
per month excluding electricity and water
charges and you addressee has lastly paid
a sum of Rs.324/- as rent for a period of
01.01.2016 to 31.12.2016 and now you have
not paid the rent since 01.01.2017 to my
client.

4. That the husband of my client has expired


on 12.07.2014 and the husband of my client
was looking after the whole affairs of his
family during his lifetime, but after his
death, sole responsibility came on the
shoulder of my client, being wife of the
deceased husband.

5. That my client is having six sons and four


daughters and all are married and later on
the son of my client Shri Ram Sajeevan
Pandey was also expird and he left two
sons, one daughter and his wife and after
the said demise of her husband as well as
hersons and daughter, the whole family of
my client is struggling for their
survival, because no one in the family are
doing any proper job or business.

6. That now it has been decided amongst the


family members of my client that they want
to open a shop of general merchant or any
other suitable work as per the locality in
the said tenanted shop for survival of the
family members which was let out by the
deceased husband of my client during his
lifetime to you addressee.

7. That in the month of November, 2017 my


client continuously requested you
addressee to vacate the said shop in
question due to the circumstances changed
after the death of her husband as well as
his son and one daughter, but you
addressee requested my client to give some
time for a period of one month, for which
you addressee can make an alternative
arrangement and on request of you
addressee my client agreed to give one
month’s time to you, but you addressee
intentionally and deliberately with
malafide intention and ulterior motives
flatly refused to vacate the shop in
question after expiry of one month and you
addressee have also tendering threats for
dire consequences and to falsely implicate
in false cases.

8. That after the death of her husband and


her son, and for survival of their
families, the said shop in question needs
urgently for my client so that my client
can open a small shop of suitable work in
the said tenanted shop for their survival.

9. That my client is having a big family and


this shop is required to my client for her
own use for opening the small work as
suitable in the locality.

10. That all requests of my client has been


turned down by you addressee, however, you
addressee is fighting with my client on
frivolous issues and gathering goonda
types of persons hence my client is living
in constant fear of mishappening.

11. That now my client is in need to get


vacated the abovesaid presmises from you
noticee, because he wants to open a
suitable work for herself and her family
for their survival.

12. That my client is not willing to keep you


noticee in the said tenanted premises any
more and terminated your tenancy with
immediate effect.

I, therefore call upon you through


this legal notice that my client does not
wants to keep you as tenant any more in
her premises and terminated your tenancy
with immediate effect, hence I further
call upon you kindly handover the peaceful
vacant physical possession of the said
tenanted shop within stipulated period or
within 15 days after receiving the present
legal notice, failing which my client
shall be constrained to take legal action
against you for getting the possession of
the said tenanted premsies/Shop No.3
before the competent court of law totally
on your costs, risks and consequences. You
shall also be liable to pay the damages
and other charges.

You are also liable to pay Rs.5,500/-


as legal expenses to my client.

Copy kept for further references in my


office.

B.D. Sharma
Advocate
Subhash Chand Bakshi Seat No.D-4, D-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/41/2011 M. 9213345825
Ref: DATE: 19.12.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
Life Insurance Corporation of India,
Through its Branch Manager,
Branch office-111,
Life Insurance Corporation,
Connaught Place, New Delhi-110 001

Sir,
Under instructions from and on behalf of my
client Smt. Neeraj, W/o Late Sh. Hari Chand, R/o
B-5/393, 394, B-Block, Nand Nagri, Delhi-110093
I hereby serve upon you through this following
legal notice, facts as under:-

1. That my client is a peace loving and law


abiding citizen of India and is residing at
the above given address and having full
faith over the due process of law.

2. That the husband of my client namely Late


Sh. Hari Chand got expired on 30.12.2016
leaving behind my client and her two
children namely _______________ aged about
____ years and _____________ aged about __
Years respectively as his only legal heirs.

3. That it is relevant to point out here that


the concerned South Municipal Corporation of
Delhi has issued a Death Certificate vide
Regn. No. MCDOLIR-0215-004860749 dated
31.12.2016 regarding the death of the
deceased husband of my client.

4. That there is no other legal heir of late


Sh. Hari Chand except my client and her two
minor children.

5. That the above named deceased husband of my


client namely Late Sh. Hari Chand was holder
of Life Insurance Policies issued by you
noticee vide Nos. 116938026, 116938027,
116938028 and 116038029. The relevant copies
of the insurance policies are enclosed
herewith for your kind consideration.

6. That it is relevant to note here that when


the deceased husband of my above client had
purchased/taken the aforesaid insurance
policies from you noticee, he was
accompanied with one of his relative namely
Amit Kumar only for the sake of someone’s
company.

7. That my client and her both minor children


are under great shock and agony due to the
death of Sh. Hari Chand and my client also
living under great mental trauma and stress
due to the death of her husband.

8. That after the death of the husband of my


client, she approached to you noticee for
claiming the insurance amount of the
insurance policies of her deceased husband,
but it was utter shock and surprise for my
client when she has come to know that the
above said relative of my client namely Amit
Kumar within the collusion and conspiracy of
some of your officials wanted to grab the
money of my client qua the insurance claims
towards the insurance policies of the
deceased husband of my client without having
any right, title and interest over the same
in any manner.

9. That the said Amit Kumar and any other


person having no right, title and interest
over any moveable and immoveable property of
the deceased husband of my client namely
late Sh Hari Chand including the
aforementioned insurance policies.

10. That my client and her both minor children


being the only legal heirs of late Sh. Hari
Chand are entitled and having all the
rights, titles and interest over the all
moveable and immoveable property of the
deceased husband of my client namely late Sh
Hari Chand including the aforementioned
insurance policies.

11. That my client is also going to initiate


separate legal proceedings qua civil as well
as criminal against the said Amit Kumar and
his associates, if any, for any act, deeds
and things being done by them for having the
intention and trying to grab the money of my
client illegally and unlawfully without
having any rights, titles and interest.

12. That the present legal notice is being sent


to you noticee so that you may be requested
not to release any insurance claim of the
aforesaid insurance policies of the deceased
husband of my client to any other person
including the above said Amit Kumar, except
my client and her both minor children, to
avoid any miscarriage of justice.

I, therefore, call upon you through this


legal notice not to give even a single penny to
any person including above said Amit Kumar qua
the insurance policies of the deceased husband
of my client in any manner and kindly release
the insurance claim of the above mentioned
insurance policies in favour of my client and
her both minor children, belongs to the deceased
husband of my client within 15 days from the
receipt of this legal notice, failing which my
client shall be constrained me to initiate
appropriate civil as well as criminal
proceedings against you, totally on your risks,
costs and consequences.
You are also liable to pay Rs.11,000/- as
fee of this legal notice.
Copy kept for further references in my
office.

S.C. Bakshi
Advocate
Adarsh Kumar Chamber No.G-404, G-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/304-C/94 M. 9891247869
Ref: DATE: 15.12.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH. LALA RAM,
S/o Late Sh. Bihari Lal,
R/O B-1/304, Nand Nagri,
Delhi-110093

Sir,
Under instructions from and on behalf of my
client Sh. Krishna Barman, S/o Sh. Madhav
Chandra Barman, R/O 472, A-2 Block, Nand Nagri,
Delhi-110093 I hereby serve upon you through
this following legal notice, facts as under:-

1. That my client is a peace loving and law


abiding citizen of India and having full
faith over the due process of law.

2. That an Agreement To Sell/Bayana dated


26.08.2016 was executed between my client
and you noticee whereby you were agreed to
sell your property bearing No.A-2/44B,
measuring 22½ sq. yards, situated in the
area of A-2 Block, Nand Nagri, Delhi-110093,
duly built upto two and half storey and it
was agreed between you and my client that
the said property shall be sold to my client
in a total consideration amount of
Rs.22,80,000/- (Rupees Twenty Two Lacs,
Eighty Thousand only) and out of which my
client had paid Rs.1,80,000/- (Rupees One
Lac, Eighty Thousand only) to you noticee in
presence of marginal witnesses on dated
26.08.2016.

3. That it has been agreed that between you


noticee and my client that my client shall
get execute the final sale documents of the
said property on or before 23.11.2016 after
making the payment of the balance amount.

4. That it is relevant to mention here that on


8th November 2016, the Government of India
announced the demonetisation of all ₹500 and
₹1,000 banknotes of the Mahatma Gandhi
Series and the sudden nature of the
announcement. It is reiterated that our
Prime Minister of India Mr.Narendra Modi
announced the demonetisation in an
unscheduled live televised address at 20:00
Indian Standard Time (IST) on 8th November,
2016. In the announcement, Prime Minister
declared that use of all ₹500 and ₹1000
banknotes of the Mahatma Gandhi Series would
be invalid past midnight, and announced the
issuance of new ₹500 and ₹2000 banknotes of
the Mahatma Gandhi New Series in exchange
for the old banknotes. It is not a hidden
fact that the prolonged cash shortages in
the weeks that followed created significant
disruption throughout the economy,
threatening economic output and my client is
one of the victim of the said
demonetisation.

5. That thereafter my client approached to you


noticee and disclosed his above said problem
as due to the demonetisation he couldn’t
arrange the remaining amount of sale
consideration in time and therefore it was
orally settled in the presence of marginal
witnesses namely Iliyas between you noticee
and my client that my client will arrange
the remaining amount of sale consideration
on or before 30.06.2017 and due to good
faith and relations, no any endorsement
regarding extension of period of execution
of final sale documents, was made on the
said agreement/Bayana and the same was
settled on oral basis.

6. That since the mid of June-2017, my client


has arranged the balance amount of sale
consideration i.e. Rs.21 Lacs and my client
has given various intimations to you noticee
to receive the balance amount of sale
consideration and to execute the final sale
documents of the said property in favour of
my client, but on each and every occasions,
you noticee kept passed the time by one
pretext or the other with the malafide
intention and ulterior motives to cause
wrongful loss to my client and wrongful gain
to yourself.

7. That now you noticee has flatly refused to


execute the final sale documents of the said
property in favour of my client with the
sole motive to grab the hard earned money of
my client and to return the double amount to
my client as per the said Agreement/Bayana.
I, therefore call upon you through this
legal notice either to execute the Regd.
Sale Documents of the said property in
question in favour of my client as per the
current market value or to pay the double
amount of the received money i.e. total
Rs.3,60,000/- (Rupees Three Lacs Sixty
Thousand only) to my client, within 15 days
from the receipt of this legal notice,
failing which my client shall be constrained
me to initiate appropriate civil as well as
criminal proceedings against you, totally on
your risks, costs and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept for further references in my


office.

ADARSH KUMAR
ADVOCATE
Salim Ahmed Khan Chamber No.F-218, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1068/92 M. 9810507166
Resi-cum-Off: A-55, Masjid Lane 2, Babarpur, Shahdara, Delhi-110032
Ref: Dated: 13.12.2017

REGD.A.D./SPEED POST
LEGAL NOTICE
To,

1. M/S WHOLLY JOY PRODUCTS PVT. LTD.


DELHI CENTRAL
THROUGH ITS DIRECTORs/A.R.

REGD. OFFICE AT:


R-13, S/F, GREATER KAILASH-I,
NEW DELHI-110048

2. SH HARIMOHAN GUPTA
DIRECTOR OF
M/S WHOLLY JOY PRODUCTS PVT. LTD.
AT:

3. SH AMIT KUMAR SHARMA


DIRECTOR OF
M/S WHOLLY JOY PRODUCTS PVT. LTD.
AT:
Sir,
Under instructions from and on behalf of my
client SH SATVEER SINGH, S/O S. CHARANJEET
SINGH, R/O J-197, VISHNU GARDEN, NEW DELHI-
110018, I hereby serve upon you through this
following legal notice, facts as under:-

7. That you noticee No.1 is the sister


concern company named Wholly Cow Dairy
Private Limited, which is doing the
business of manufacturing and supplying
various milk and milk products and you
noticee No.2 and 3 are the Directors of
the Noticee No.1 respectively.

8. That the son of my client namely Sh.


Harsimran Singh has been trapped and
allured by you noticee by executing a
Memorandum of Understanding/ Agreement for
C&F with him on dated 12th September, 2016,
by virtue of which you noticees and your
sister company has appointed the son of my
client as your C&F Agent for the sale of
your products in the assigned territory of
some part of West Delhi, more particularly
areas/ locality covered are Moti Nagar,
Tilak Nagar, Ramesh Nagar, Bali Nagar,
Rajouri Garden etc.

9. That it was agreed between your above said


sister concern company and the son of my
client that the son of my client will earn
commission as well as reimbursement of
certain expenses from the principal as per
the details marked and mentioned in
Annexure ‘A’ to the aforesaid MOU/
Agreement.

10. That it is relevant to point out here that


initially my client in the name of his
above son had deposited Rs.4,00,000/- as
security amount as per the instructions
and demands of you noticee and the said
amount of security will be increased as
and when demand of crates will be
increased.

11. That all the above said promises,


assurances and agreement/MOU executed by
you noticees on behalf of your sister
concern company found fake when you
noticees have failed to supply any
products to my client despite repeated
requests and demands and my client and his
son have been trapped by you noticees in
your heavenly dreams as you noticees have
showed dreams of multiple profits in the
said business to my client and his son and
all your commitments found fake and
futile.

12. That thereafter my client and his son


approached to you noticees and demanded
back their above said security amount of
Rs.4 Lacs as you noticees have played
fraud with my client and his son and also
cheated and induced them by receiving Rs.4
Lacs as security in the garb of executing
MOU/Agreement with the son of my client.

13. That consequently you noticees have


compelled my client to receive back
Rs.3,87,643/- (Rupees Three Lacs, Eighty
Seven Thousand, Six Hundred and Fourty
Three only) in the garb of settling the
matter from you noticees by issuing a No
Dues Certificate on 19.04.2017 and for
discharging your above said liability of
your sister concern company, you noticees,
have issued, signed and delivered three
cheques bearing No.828817 of Rs.1,50,000/-
of dated 25.09.2017, another cheque
No.828815 of dated 20.10.2017 of
Rs.1,50,000/- and Cheque No.828818 of
Rs.87,643/- of dated 24.11.2017, all drawn
on YES Bank Ltd., Branch at Nehru Place,
New Delhi and at the time of issuing the
aforesaid cheques, you noticee assured to
my client that the said cheques would be
honoured positively at the time of its
presentation in its banker.

14. That consequently as per your assurances


and instructions, my client had deposited
the said cheques in its banker i.e. Bank
of India, branch at Vishnu Garden, Delhi-
110018 for its encashment, but the said
cheques were dishonoured by your banker
with the remarks “FUNDS INSUFFICIENT”, and
my client received the information through
returning memos dated 30.11.2017 and
08.12.2017 respectively.

15. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheques and my client
demanded the said cheques amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheques, you have flatly
refused to pay the said cheques amount to
my client in any manner.

16. That you for discharging your legal


liability, issued, signed and delivered
the abovesaid cheques, which were
dishonored by your banker and thus you
breached the trust of my client and
committed an offence punishable under
Section 138 of N.I. Act.

17. That not only this, you noticees have


played fraud my client and his son and
committed cheating with them by inducing
and alluring them to invest in your
business and take your distributorship by
depositing the security amount of Rs.4
Lacs and after that you noticees failed to
honour your commitments which resulted
into heavy loss in business for my client
and you noticee also misappropriated the
funds of my client illegally and
unlawfully, and thus you noticees further
renders yourself liable to be prosecuted
under Criminal Law for commission of
offences U/s 406/416/417/419/420/120-B of
the Indian Penal Code, 1908.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.3,87,643/- (Rupees Three Lacs, Eighty
Seven Thousand, Six Hundred and Fourty
Three only) to my client within 15 days
from the receipt of this legal notice,
failing which my client shall be
constraint to initiate appropriate
criminal u/s 138 N.I. Act as well as civil
proceeding against you totally on your
costs, risks and consequences.

Copy kept in my office for further


references.

Salim Ahmed Khan


Advocate
ZAKIR ALI Chamber No.F-602, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
M. 9213939759
Ref: DATE: 08.12.2017

COURIER/SPEED POST
LEGAL NOTICE
To,
MOHD. SHAFI ALAM
S/o MOHD HADEES
R/O H.NO.C-6, GALI NO.4,
CHANDU NAGAR, KARAWAL NAGAR ROAD,
DELHI-110094

ALSO AT:
VILLAGE MUSKINPUR, P.S GOGRI,
JAMALPUR, DISTT. KHAGARIA,
BIHAR-851202,

Sir,
Under instructions from and on behalf of my
client SH ABID MALIK, S/O SHEHZAD MALIK R/P 521,
GALI NO.7, RAJIV NAGAR, NEW MUSTAFABAD, DELHI-
110094, I hereby serve you through this
following legal notice, facts as under:-

8. That you noticee and my client are friends


from last so many years and having family
visiting terms.
9. That on 01.01.2017, you approached to my
client and requested for a friendly loan of
Rs.85,000/- (Rupees Eighty Five Thousand
only) for a period of 10-11 months for your
urgent need of money and after considering
the friendly relations with you on the same
day my client gave a sum of Rs.85,000/-
(Rupees Eighty Five Thousand only) to you in
cash in the presence of marginal witnesses
including Mr. Abdul Jabbar and you assured
my client to return the abovesaid amount
upto October-2017.

10. That in the month of October -2017, my


client approached to you noticee and
demanded the said friendly loan amount of
Rs.85,000/- (Rupees Eighty Five Thousand
only) from you noticee, but you noticee
instead of making the payment, sought some
more time from my client on pretext that you
have not arranged the sufficient amount and
for the sake of good relations, my client
became agreed with you.

11. That thereafter on 10.11.2017 my client


again approached to you noticee and demanded
his money back, but you kept passing the
time by one pretext to another and now you
instead of making the payment of the said
amount of Rs.85,000/- (Rupees Eighty Five
Thousand only), you have flatly refused to
pay the said borrowed amount to my client in
any manner and had also extended threats to
face dire consequences.

12. That you noticee for the sake of good


friendly relations induced my client to give
you a friendly loan of Rs.85,000/- (Rupees
Eighty Five Thousand only) and thereafter
you noticee didn’t repay the same
intentionally and deliberately with the
malafide intention and ulterior motives to
cause wrongful loss to my client and
wrongful gain to your self and therefore you
noticee also committed cheating, fraud,
criminal breach of trust with my client, for
which you noticee also renders yourself to
be liable Under section 406/420 of Indian
Penal Code, 1860.

13. That you noticee are still liable to pay a


sum of Rs.85,000/- (Rupees Eighty Five
Thousand only) to my client alongwith
interest at the tune of 24% per annum and
your above said liability is clearly
reflects from the evidences collected by my
client which will be placed on record before
the court of law as and when required in
future.

I, therefore call upon you through this


legal notice to make the payment of the
aforesaid borrowed amount of Rs.85,000/-
(Rupees Eighty Five Thousand only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.

Zakir Ali
Advocate
Mamtesh Sharma Chamber No.F-709, F-Block
Advocate 7th Floor, Lawyers Chambers
Block, Kakardooma Courts
DELHI HIGH COURT Delhi-110032
E-mail: mmamtesh@gmail.com Ph: 09810322929, 08860077857
==================================================================
Ref: Date: 30.11.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S TANEJA VIDYUT CONTROL PVT. LTD.
THROUGH ITS DIRECTOR/A.R.,
SH. ANIL TANEJA,
AT: 80/74-AB, MALVIYA NAGAR,
NEW DELHI-110017

Sir,
Under instructions from and on behalf of my
client namely M/S DIXIT UDYOG, THROUGH ITS PROP.
SH YOGENDER, AT: 62, MAIN ROAD, KARDAMPURI,
SHAHDARA, DELHI-110032, I hereby serve upon you
through this following legal notice, facts as
under:-

8. That you noticee is doing the business of


supplying and retailing of electrical
equipments etc. in the name and style of M/s
Taneja Vidyut Control Pvt. Ltd. and doing
your business at 80/74-AB, MALVIYA NAGAR,
NEW DELHI-110017.
9. That on the other side, my client is doing
his business of manufacturing and retailing
of all kinds of Iron Sheets Boxes in the
name and style of M/s Dixit Udyog at: the
above given address.

10. That you noticee is the customer of my


client and you have placed three Purchase
Orders vide P.O. No.8535 dated 25.02.2014,
P.O. No.8373, P.O. no.8727 dated 14.04.2014
and P.O. No.9049 dated 09.05.2014 to my
client for purchasing various electrical
equipments.

11. That consequently my client fulfilled the


aforesaid purchase orders placed by you
noticee and my client has consequently
raised the Retail Invoices/Bills as
tabulated below:

S.No. Retail Dated Amount(in Rs.,


Invoice/ Bill Including VAT)
No.
1. Sr. No.318, 10.03.2014 Rs.35,861/-
Book No.07
2. Sr. No.322, 22.03.2014 Rs.29,580/-
Book No.07
3. Sr. No.331, 05.05.2014 Rs.18,360/-
Book No.07
4. Sr. No.342, 11.06.2014 Rs.42,330/-
Book No.07
TOTAL 1,26,131/-

12. That in discharge of your above said


liability, you noticee have issued, signed
and delivered the following cheques in
favour of my client, the details of the
cheques are tabulated below for the ease of
reference:
S.No. Cheque No. Dated Amount
(in Rs.)
1. 081532 20.05.2014 Rs.35,861/-
2. 081620 24.05.2014 Rs.29,580/-
3. 086330 21.06.2014 Rs.18,360/-
4. 086532 13.07.2014 Rs.42,330/-
TOTAL 1,26,131/-

It is relevant to point out here that at the


time of issuing the said cheques, you
noticee assured my client that the said
cheques would be honoured positively at the
time of its presentation.

13. That it is also relevant to point out here


that, as per your assurance and instructions
my client had presented the cheque mentioned
above at Serial No.1 in the above table, in
its banker i.e. Punjab and Sind Bank, Branch
at Delhi for its encashment, but the said
cheque was dishonored by your banker with
the remarks “PAYMENT STOPPED BY DRAWER” and
my client has received the returned memo
received of dated 25.06.2014.

14. That thereafter my client immediately


contacted to you noticee and disclosed the
fact about dishonour of cheque, then you
noticee showed your financial problem and
transferred an amount of Rs.20,000/- in the
account of my client on dated 13.08.2014
through RTGS.

15. That you noticee has further requested my


client not to present the cheque mentioned
at Serial No.2 in the above table, on the
pretext that you have not arranged the
sufficient balance in your account and
sought some more time from my client and my
client became agreed with you, but all of
this was nothing, but ill tactics on your
part, as you noticee got succeed to passed
the mandatory period of presentation of the
said cheque and the said cheque mentioned at
Serial No.2 remained un-presented.

16. That thereafter my client has further


presented the said both cheques mentioned at
Serial No.3 and 4 in its banker for its
encashment, but the same were also returned
unpaid with the remarks “PAYMENT STOPPED BY
DRAWER”.

17. That since then my client contacted with you


noticee and requested on several occasions
to make the payment of the aforesaid
cheques, but on each and every time, you
noticee kept on giving false and frivolous
assurances with the malafide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.

18. That it is also relevant to point out here


that you noticee is now stopped raising
further purchase orders to my client
intentionally and deliberately.

19. That now finally in the first week of


August, 2016, you noticee has flatly refused
to make the payment of aforesaid cheques to
my client in any manner.

20. That on 30.08.2016, I sent a legal notice to


you noticee on behalf of my above said
client thereby calling upon you to pay a sum
of Rs.1,06,131/- (Rupees One Lac Six
Thousand One Hundred and Thirty One only)
alongwith interest at the tune of 24% p.a.
and after receiving the said legal notice,
you noticee approached my client and made
various payments on multiple dates through
cheques and out of the total recoverable
amount of Rs.1,06,131/- (Rupees One Lac Six
Thousand One Hundred and Thirty One only),
you notice had paid Rs.45,000/- (Rupees
Forty Five Thousand only) to my client but
after 01.09.2017, you noticee has not paid
even a single penny to my client and hence
by this way, you noticee are still liable to
pay a sum of Rs.61,131/- (Rupees Sixty One
Thousand One Hundred and Thirty One only) to
my client alongwith interest at the tune of
24% p.a., hence this notice.

I, therefore call upon you through this


legal notice to make the payment of
Rs.61,131/- (Rupees Sixty One Thousand One
Hundred and Thirty One only) alongwith
interest at the tune of 24% p.a. to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.
Mamtesh Sharma
Advocate
JAGDISH CHANDRA Seat No.D-9, D-Block,
ADVOCATE Saraswati Hall, First Floor,
Delhi High Court Karkardooma Court
Enrl. No.D-1106/99 Complex, Delhi-110032
(M) No.9810741639
Ref. No. DATED: 29.11.2017

STATUTORY LEGAL NOTICE U/s 80 CPC


BY SPEED POST/REGD. A.D.
To,
1. THE EXECUTIVE DIRECTOR (PERSONNEL)
2. THE D.G.M./HQRs
3. THE D.G.M./HINDI/I.R.S.
4. THE D.G.M. (FINANCE)
ALL C/O FOOD CORPORATION OF INDIA
AT: 16-20, BARAKHAMBA LANE,
HEAD QUARTERS, NEW DELHI-110001

Sir,
Under the instructions from and on behalf of
my client MR. NEERAJ GUPTA (HANDICAPPED/ LEGAL
HEIR/LEGIBLE CANDIDATE), S/o LATE SH BRIJMOHAN
GUPTA, R/o H.No.8, GANESH NAGAR EXTN.-II,
SHAKARPUR, DELHI-110092, I hereby serve upon you
addressees through this legal notice on the
following text:-

1. That the father of my client namely Sh.


Brijmohan Gupta was the Principal employee
of Food Corporation of India on the post
of AGM (Finance) and he was doing his
duties sincerely, honestly and in
dedicated manner, but unfortunately during
his service period i.e. prior to his
retirement, he was expired on 22.12.2007.

2. That on 28.12.2007, the General Manager of


FCI issued an official circular in respect
of the death of father of my client for
condolence at 5.10 PM in his building/
Office. Subsequently, the concerned
officers bearers also called my client and
his mother for consideration the name of
my client for selection in FCI department
on compensatory ground, on which my client
visited at your Office alongwith his
mother and submitted his all relevant
educational documents. The concerned
officers took an application alongwith
documents from my client and at that time
the said officials assured my client that
his selection will be done as soon as
earlier.

3. That since the date of submitting his


application, educational certificates, my
client regularly contacted and visited the
concerned officials of you addressees
alongwith his widow mother as and when
called by the Authority, but till date no
fruitful result came out in favour of my
client due to malafide intention of you
noticees.

4. That finding no alternative my client’s


mother namely Smt. Nirmal Gupta, widow of
Sh. Brijmohan Gupta also submitted several
requests in writing for job of her son on
compassionate ground to the higher
Authorities of FCI, N.D. & also demands
the necessary & essential information from
the HQRs, so FCI regarding the appointment
of her handicapped son namely Neeraj Gupta
who is legally entitled for the same as
per law, but all the efforts of my client
and his widow mother went in vain.

5. That my client is Graduate and as per


medical certificate he is a person of
permanent disability of more than 40% and
in this regard the concerned doctor of Lok
Nayak Hospital, New Delhi issued a
Permanent Disability Certificate in favour
of my client on 14.02.2003.
6. That except my client there is no male
earning member in his family to lookafter
his old aged widow mother, who is aged
about 69 years and suffering from diabetes
disease since last 11 years due to
unemployment of her son.

7. That my client has no moveable or


immoveable property in his name in India
or valuable items and his mother has not
taken any pension or other benefits/
reliefs of her deceased husband from the
concerned Department of FCI.

8. That my client is the First Class legal


heir of late Sh. Brijmohan Gupta
(deceased) and has full responsibilities
to lookafter his widow mother as well as
himself.

9. That my client came to know through RTI


that you addressees namely Suresh Kapoor,
DGM and N. Balakrishan Nadar DGM
(HINDI/IR-S) (R.K. Maindiratta) DGM
(Finance) appointed 12 persons on the
compassionate ground, but you all did not
consider the name of my client
intentionally, deliberately and
dishonestly. My client is unemployed till
date due to such acts of you noticees and
he came under depression and suffering
from hypertension, irreparable loss and
injury. While my client is legally
entitled for his appointment as per the
service rules and regulations of the
Central Govt. of India.

10. That there is no Govt. Servant in entire


family of my client, the status of my
client is helpless, unemployed,
handicapped and also an indigent person,
as my client is not having any source of
income from any side or corner.

I, therefore call upon you addressees


through this statutory legal notice to
consider the application for appointment
of my client with FCI department as soon
as possible and select my client for
suitable post as per the qualification of
my client, within 60 days from the date of
receipt of this legal notice, failing
which my client has instructed me to
initiate appropriate legal action against
you addressees before the competent Court
of law totally on your costs, risks and
consequences and you addressees will be
liable to pay all the expenses of
litigations to my client.

You noticees are liable to pay


Rs.5,500/- towards the cost of present
legal notice.

Copy kept for further references in my


office.

JAGDISH CHANDRA
ADVOCATE
Salim Ahmed Khan Chamber No.F-218, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1068/92 M. 9810507166
Resi-cum-Off: A-55, Masjid Lane 2, Babarpur, Shahdara, Delhi-110032
Ref: Dated: 29.11.2017

REGD.A.D./SPEED POST
LEGAL NOTICE
To,
M/S PRIYANKA SAREE & SUIT CO. SHOP
THROUGH ITS PROP.
SH MOHD. IRSHAD,
AT: SHOP NO.1, SUNEHRI MARKET,
NEAR METRO STATION SECTOR-18,
ATTA MARKET, NOIDA, U.P-201 301

Sir,
Under instructions from and on behalf of my
client M/S UMERA FASHIONS, THROUGH ITS PROP.
SH.ISLAM, AT: D-93, NEW SEELAMPUR, DELHI-110053,
I hereby serve upon you through this following
legal notice, facts as under:-

18. That my client is doing the business of


ladies suit in the name and style of M/s
Umera Fashions and doing its business at
the above given address.

19. That you noticee used to purchase ladies


suits from my client few time back and by
passing the time, you noticee established
good relations with my client.

20. That consequently you noticee approached


my client at his above said shop and
purchased the ladies suits from my client
against Invoice No.015 dated 26.09.2017
for a total sum of Rs.98,772/- (Rupees
Ninety Eight Thousand, Seven Hundred and
Seventy Two only) duly received by you
noticee /your authorized person.

21. That at the time of purchasing the said


suits, you noticee assured my client that
you will make the payment of the aforesaid
ladies suits within one month.

22. That consequently in the last week of


October, 2017 you noticee approached my
client at his above said shop and issued,
signed and delivered a cheque bearing
No.158214 of dated 30.10.2017 for
Rs.98,772/- drawn on Corporation Bank,
branch at Noida, U.P. and at the time of
issuing the aforesaid cheque, you noticee
assured to my client that the said cheque
would be honoured positively at the time
of its presentation in its banker.

23. That consequently as per your assurances


and as per your instructions, my client
has lastly deposited the said cheque in
its banker i.e. State Bank of India,
branch at Seelampur, Delhi, but the said
cheque was dishonoured by your banker with
the remarks “FUNDS INSUFFICIENT”, and my
client received the information through
returning memo dated 03.11.2017.

24. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.
25. That you for discharging your liability,
issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.98,772/- (Rupees Ninety Eight Thousand,
Seven Hundred and Seventy Two only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constraint to initiate
appropriate criminal u/s 138 N.I. Act as
well as civil proceeding against you
totally on your costs, risks and
consequences.

Copy kept in my office for further


references.

Salim Ahmed Khan


Advocate
Muneesh Kumar Shukla CHAMBER No.G-404,
ADVOCATE G-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.

Mob: 9654855644
Ref. No. DATED: 22.11.2017

REGD.A.D./SPEED POST
LEGAL NOTICE
To,
M/S NISHAT INTERNATIONAL
Through its Managing Director
SH NESHAT AHMAD
AT: 1-F, SECOND FLOOR,
NEAR HEFCO MEDICAL, BHARAT NAGAR, NFC,
NEW DELHI-110025

Sir,
Under instructions from and on behalf of my
client SH. MANSUR, S/O SH. MEHMUD, R/O VILLAGE
JAHANABAD, P.O. DARA NAGAR GANJ, DISTRICT
BIJNOR, U.P., I hereby serve upon you through
this following legal notice, facts as under:-

26. That you noticee came in contact with my


client through one of his friend and you
noticee has informed my client that you
will arrange a job for my client in Saudi
Arabia, as you are doing the said business
on commission basis.
27. That consequently you noticee taken
Rs.97,000/- (Rupees Ninety Seven Thousand
only) from my client in lieu of sending
him to Saudi Arabia for job and you
noticee assured that you have already
arranged a job in Saudi Arabia for my
client.
28. That on 1st May-2017, my client went to
Saudi Arabia as per the assurances given
by you noticee, but my client got shocked
when he reached to Saudi Arabia, as there
was no any job arranged by you noticee for
my client and it was only an act of
cheating on your part.
29. That when my client contacted to you
noticee, then you noticee told my client
that there was no job at present and you
noticee told my client to enjoy the said
foreign trip and return as per his
convenience.
30. That consequently my client returned to
India on 01.08.2017 and contacted to you
noticee and at that time you noticee
apologized your guilt and disclosed that
you will return all the money which was
taken by you noticee from my client and in
discharge of your above said liability,
you noticee issued a cheque bearing
No.465711 of Rs.20,000/-, dated
27.10.2017, drawn on Yes Bank Ltd., branch
at Okhla Industrial Area, New Delhi, you
noticee assured to my client that the said
cheque would be honoured positively at the
time of its presentation in its banker.
You noticee further assured my client that
the remaining amount of Rs.77,000/- shall
also be given by you noticee to my client
within some time.
31. That consequently as per your assurances
and as per your instructions, my client
has lastly deposited the said cheque in
its banker i.e. Punjab National Bank,
Branch at Mukherjee Nagar, Delhi, but the
said cheque was dishonoured by your banker
with the remarks “FUNDS INSUFFICIENT”, and
my client received the information through
returning memo dated 03.11.2017.
32. That immediately my client contacted to
you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.
33. That you for discharging your liability,
issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.
I, therefore call upon you through
this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.20,000/- (Rupees Twenty Thousand only)
to my client within 15 days from the
receipt of this legal notice, failing
which my client shall be constraint to
initiate appropriate criminal u/s 138 N.I.
Act as well as civil proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/-
as fee of this legal notice.
Copy kept in my office for further
references.

Muneesh Kumar Shukla


Advocate
To,
Sh. M.K. Dwivedi,
Hon’ble Addl. District Megistrate,
District North-East,
Delhi,

Ref: No.F/ADM/NE/133 Cr.P.C./2017/1042 DATED


24/10/2017

Subject: Reply to the Notice on behalf of M/s


Aman Motors, Hero Show Room, 3½
Pushta, Delhi

Hon’ble Sir,
Most respectfully showeth:

The undersigned is in the receipt of

aforesaid Notice No. F/ADM/NE/133 Cr.P.C./

2017/1042 dated 24/10/2017 sent by your good

self with the alleged activities, which are

reproduced as below:-

“Parking vehicles outside showroom which

cause hindrance on path for general public”

The undersigned is hereby wish to furnish his

submissions qua the aforesaid notice as follows:


1. True fact is that the undersigned has not

committed any encroachment on service lane

or any parking of vehicles on the service

lane at any point of time, as the true fact

is that on day of alleged incident i.e.

16.10.2017, there was extreme atmosphere of

festival Deepawali and just on the next day

i.e. 17.10.2017, the festival Dhanteras was

going to be celebrated and due to the said

reason, the markets were full of public at

large for the purpose of shopping of

household, utensils, sweets, clothes, etc.

and even various street hawkers were also

present with their rehdi/theli for selling

various items.

2. That it is also relevant to point out here

that the showroom of the undersigned is

situated on service lane and there is

sufficient space on the opposite side of the


showroom of the undersigned and on the

Festival Season (Deepawali) on the said

space various people who came for shopping

purposes, have parked their vehicles on the

said space and even the neighbourers/local

habitants have also parked their vehicles on

the said space, but despite that there was

no hindrance on the passer-by traffic on the

service lane, as there is enough space on

the opposite side of the showroom of the

undersigned.

3. That when the undersigned has come to know

about the parking of vehicles by the general

public, neighbourers/ local habitants, he

immediately took steps for stopping the

parking by general public on the service

lane and also directed the showroom staff

not to permit anyone to park their vehicles

on the said space.


4. That now there is no hindrance on the path

for general public and the undersigned has

taken all precautions that no one can park

their vehicles on the said service lane

either by the general public, people of the

locality /neighbourers and the own customers

of the undersigned and undersigned further

undertakes to maintain the said condition in

future with all due respects and regards to

the law and order of the country. (Relevant

photographs are enclosed herewith)

It is, therefore, most respectfully

prayed to your goodself that kindly drop the

proceedings against the undersigned.

And for this act of kindness, the

undersigned shall ever oblige.

Thanking you,

Delhi,
Dated: 23.11.2017 For M/s Aman Motors
Manager (Works)
VISHWAS AHUJA CHAMBER No.D-619,
ADVOCATE D-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.

Mob: 9999797537
Ref. No. DATED:

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S CHENNAI NETWORK INFRASTRUCTURE LIMITED,
A GLOBAL GROUP ENTERPRISE

REGD. OFFICE AT:


ALSA TOWERS, 6TH FLOOR, 186,
POONAMALLEE HIGH ROAD,
KILPAUK, CHENNAI- 600 010

ALSO AT:
403/L, SAMSON TOWER,
7TH FLOOR, PANTHEON ROAD,
EGMORE-600008, TAMILNADU

CIRCLE OFFICE AT:


M/S G.T.L. INFRASTRUCTURE LTD.
OFFICE AT: 3RD FLOOR, 20/4, PLAM COURT
BUILDING, MDI CHOWK, SECTOR-14,
GURGAON, HARYANA

Sir,
Under the instructions from and on behalf of
my client SH. MANMOHAN LAL ARORA, S/O LATE SH.
CHANDU LAL ARORA, R/O H.NO. 1/9043, GALI NO.1,
WEST ROHTASH NAGAR, SHAHDARA, DELHI-110032, I
hereby serve upon you with the following legal
notice:

1. That my Client is the sole and


absolute owner of the property bearing
No. 1/9043, Gali No.1, West Rohtash
Nagar, Shahdara, Delhi-110032.

2. That M/s Aircel Ltd. is engaged in the


business of providing cellular telephone
services and for the aforesaid purposes,
my Client had entered into a License
Agreement dated 19th October 2008 with
Aircel Ltd. whereby Aircel Ltd. to set
up/ installed a Cellular/ microwave
antennae and other related equipments at
the said Property of my Client i.e.
H.No. 1/9043, Gali No. 1, West Rohtash
Nagar, Shahdara, Delhi-110032 for a
fixed period of 20 years w.e.f.
19.10.2008 to 18.10.2028.

3. That it was agreed between my Client


and Aircel Ltd. that Aircel Ltd. shall
pay a sum of Rs.12,000/- (Rupees Twelve
Thousand only) per month as License Fee.
It was further agreed that the license
fee shall be enhanced by 10% at the
expiry of every 5 years of the last
license fee paid.

4. That Aircel Ltd. also deposited an


interest free security of Rs.36,000/-
(Rupees Thirty Six Thousand only), which
is equivalent to 3 months’ license fee/
compensation, which shall be refunded on
the day of the expiry or earlier
determination of the said License
Agreement without any deduction there
from along-with the unadjusted amount of
advance license fees, if any, paid to
Petitioner.

5. That Aircel Ltd. was regularly paying


the said license fee to my Client
without any default.

6. That on 20th July 2010, my Client


received a letter from Aircel Ltd. that
you noticee shall be the successor and
shall be liable for compliance towards
all obligations under the License
Agreement, including payment of monthly
rents to my Client henceforth.
Therefore, you noticee started to pay
the monthly license fee to my Client
which was directly being transferred by
you notice into the bank account of my
Client.

7. That it is relevant to point out here


that since 1st April 2017, you noticee
stopped paying the monthly license fee
under the aforesaid License Agreement to
my Client despite repeated requests and
demands being made by my Client with you
noticee specifically to official of you
noticee namely Mr. Sandeep Yadav, but
they did not pay any heed towards the
requests of my Client and the aforesaid
official Mr.Sandeep Yadav continued to
linger on the matter with one false
pretext or the other.

8. That you noticee is in arrears of


license fee w.e.f. 1st April 2017 to till
date, hence this notice.

9. That Aircel Ltd. is the original party


of the License Agreement dated
19.10.2008 and by virtue of a letter
dated 20.07.2010, Aircel Ltd. informed
my client that you noticee shall be the
successor and shall be liable for
compliance towards all obligations under
the License Agreement, including payment
of monthly rents to my Client
henceforth.

I, therefore call upon you through


this legal notice to refer the matter to
Arbitration and appoint a Sole Arbitrator
as agreed upon in the License Agreement
dated 19th October 2008 and inform my
client accordingly within 15 days from the
receipt of this legal notice, failing
which my client shall be constraint to
initiate appropriate legal proceeding
against you totally on your costs, risks
and consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

Vishwas Ahuja
Advocate

REGD.A.D./SPEED POST
To,
M/S G.K. ENGINEERS,
THROUGH ITS PROP.
SH SANDEEP TYAGI
AT: A-3/44-E, JAGRITI APARTMENTS,
SECTOR-71, NOIDA, U.P.,

Sir,
Under instructions from and on behalf of my
client M/S YOGESH AGENCIES, THROUGH ITS PROP.
SH._____________, AT:KHASRA NO.209, VILLAGE
SADARPUR, SECTOR-45, NOIDA, U.P., I hereby serve
upon you through this following legal notice,
facts as under:-

34. That my client is doing the business of


selling PVC-U Pipes, fittings, sanitation
system & CVPC Pipe & Fittings in the name
and style of M/s YOGESH AGENCIES, and
doing his business at KHASRA NO.209,
VILLAGE SADARPUR, SECTOR-45, NOIDA, U.P.

35. That you noticee usually used to purchase


various articles from my client and
consequently on 25.12.2003, you noticee
purchased various articles from my client
against Bill No.278, book No.06, worth
Rs.1,10,849/-.

36. That in discharge of your above said


liability, you noticee issued, signed and
delivered a cheque bearing No.803509 of
Rs.1,10,850/- of dated 24.10.2017, drawn
on Vijaya Bank, branch at Noida, U.P. and
at the time of issuing the aforesaid
cheque, you noticee assured to my client
that the said cheque would be honoured
positively at the time of its presentation
in its banker.

37. That consequently as per your assurances


and as per your instructions, my client
has lastly deposited the said cheque in
its banker i.e. State Bank of India,
branch at Rama Market,
____________________, but the said cheque
was dishonoured by your banker with the
remarks “FUNDS INSUFFICIENT”, and my
client received the information through
returning memo dated 13.07.2017.
38. That immediately my client contacted to
you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

39. That you for discharging your liability,


issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.20,714/- (Rupees Twenty Thousand Seven
Hundred Fourteen only) to my client within
15 days from the receipt of this legal
notice, failing which my client shall be
constraint to initiate appropriate
criminal u/s 138 N.I. Act as well as civil
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

AUTHORITY LETTER

I, Javed Khan, General Manager, M/s Aman Motors,


at: Hero Show Room, 3½ Pusta, Delhi, do hereby
nominate/ appoint/ authorize Mr. J.S. Sharma,
Manager (Works), M/s Aman Motors, at: Hero Show
Room, 3½ Pusta, Delhi, to appear before your
Hon’ble Sir and to file reply on our behalf and
to do all such type of work on our behalf and to
give statement /undertaking before your Hon’ble
Sir on our behalf.

M/s Aman Motors

General Manager
AUTHORIZED REPRESENTATIVE

Manager (Works)
M/s Aman Motors
Sharma & Associates
(The Law Firm)
Sanjay Singh Chamber No.E-415, E-Block
ADVOCATE Karkardooma Courts
Complex
Delhi-110032
DELHI HIGH COURT M: 9968052909
================================================================================
Ref: Date: 02.11.2017
LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH. YATENDRA SINGH @ BOHRE


S/O SH HARPRASAD SINGH

2. SMT. SADHNA @ RANI,


W/O SH. YATENDRA SINGH @ BOHRE,
R/O H.NO.189, GALI NO.5, PHASE-4,
GAUTAM VIHAR, SHIV VIHAR,
KARAWAL NAGAR, DELHI-110094

Sir/Madam,
Under instructions from and on behalf of my
client namely SH. HAR PRASAD SINGH, S/O SH. TEJ
PAL SINGH, R/O H.NO.189, GALI NO.5, PHASE-4,
GAUTAM VIHAR, SHIV VIHAR, KARAWAL NAGAR, DELHI-
110094, I hereby serve upon you through this
following legal notice, facts as under:-

1. That you noticee No.1 are the real son of


my client and you noticee No.2 are the
daughter-in-law of my client, being wife
of noticee No.1.
2. That it is relevant to point out here that
you noticee No.1 is the adopted son of my
client, as you noticee No.1 is the natural
son of Sh. Horam Singh, S/o Sh. TejPal
Singh, R/o Village Kakebhal, P.O.
Kakebhal, Distt. Aligarh, U.P. and the
said Sh. Ram Singh is the real brother of
my client, but my client has never treated
you noticees with any partiality and
treated you noticees as his own natural
children without any hesitation in any
manner.

3. That you both the noticees are regularly


harassing and humiliating my client by
your illegal, and uncooperative acts and
activities and being real son and
daughter-in-law, you noticees are not
caring and helping my client and want to
capture the property of my client within
the collusion and by hatching the
conspiracy with the family members of the
noticee No.2.

4. That very often since beginning, you


noticee No.1 and 2 used to quarrel with my
client on minor issues or the others. And
you noticee No.1 and 2 have threatened my
client that you will implicate my client
and his family members in any false
criminal case and since then my client
always remained in great tension.

5. That my client is the owner of the


property bearing No.189, GALI NO.5,
PHASE-4, GAUTAM VIHAR, SHIV VIHAR, KARAWAL
NAGAR, DELHI-110094, and the said property
is the self-acquired by my client from his
own funds, sources and earnings and status
of you both noticees in the said property
were/are only as a licencee.

6. That you both noticees No.1 & 2 due to


dishonest intention humiliating and
torturing to my client by one pretext and
another at every moment, due to all these
circumstances and seeing the behaviour of
you noticee No.1 & 2, my client have
debarred you both noticees No.1 & 2 by way
of publication of public notice in daily
Newspaper Rashtriya Sahara dated
22.01.2016. The copy of said publication
is enclosed herewith.

7. That after publishing the said debarred


notice, my client have broken all the ties
and relations with you addressee No.1 & 2
and hence you noticee No.1 & 2 have no
right to stay in the above said property
of my client any more in any manner.

8. That my client do not wish to permit you


addressees No.1 & 2 to live in the said
property in respect of portion which is in
your possession i.e. one room, kitchen,
latrine-bathroom on ground floor in the
said property. You are further required to
be noted that my client have terminated
your living capacity/locus standi in said
premises, therefore you noticee No.1 and 2
have no right to stay in the property of
my client and both of you are liable to
pay occupational charges @ Rs.5,000/- per
month w.e.f. 01.12.2017 and now you are
living in the said property as
unauthorized occupants.

9. That it is relevant to mention here that


when you noticees came to know that my
client have debarred both of you noticees
from their all moveable and immoveable
properties, then you both noticees have
abused my client in filthy and abusive
language and threatened my client to
implicate them in some false criminal
cases and due to the said reason, my
client are under great terror and fear
from you noticees.

10. That despite knowledge and information


regarding debar publication and several
oral requests for vacating of the portion
of the above said property in your
possession, you both did not pay any heed
and also not bothered to vacate the
portion in your possession till date,
hence this notice.

I, therefore call upon you through this


legal notice that you noticee No.1 and 2 to
vacate the premises of my client in respect
of the portion which is in your possession,
within 15 days from the date of receipt of
this legal notice, failing which my client
instructed me to initiate appropriate legal
action against you noticee No.1 and 2
totally on your costs, risks and
consequences and you noticee No.1 and 2 will
be liable to pay all the expenses of
litigations to my client.
You are also liable to pay the use and
occupation charges @ Rs.5,000/- per month to
my client in respect of the said premises
w.e.f. 01.12.2017 till the vacation of the
same.

You noticees are liable to pay Rs.5500/-


towards the cost of present legal notice.

Copy kept for further references in my


office.

SANJAY SINGH
ADVOCATE
REGD. A.D./SPEED POST
LEGAL NOTICE
To,
M/S GARG UDYOG
THROUGH ITS PROP./OWNER.
SH. SURESH KUMAR GUPTA,
S/O SH. RAM SINGH GUPTA,
AT: KHASRA NO.152, RITHALA (ROHINI),
DELHI-110085

ALSO AT:
E-31, ASHOK VIHAR, PHASE-I,
NORTH-WEST, DELHI-110052

Sir,
Instructions received from and on behalf of
my client Sh. Ram Swaroop, S/o Sh. Sonpal, R/o
House No.D-495, Gokalpuri, Delhi-110094, I
hereby serve upon you through this following
legal notice facts as under:-

9. That my client was appointed by you


noticee as “Quality Control Engineer”
since 05.07.1997 as per your assurance
that the services of my client was
regularized by you and you have paid the
last drawn salary to my client as
Rs.20,500/- per month and in this regard
an Appointment Letter was also issued by
you on 06.07.1997.

10. That my client has never given any chance


of complaint to you and worked all along
to the satisfaction of you noticee and my
client has never given any chance of
complaint towards his duty at any point of
time.

11. That my client has always remained honest,


diligent, hardworking and sincere towards
his work.

12. That you noticee did not pay any salary to


my client since March-2016 despite
repeated requests and demands.

13. That since 10.11.2016, you noticee have


terminated the services of my client
without any sufficient rhyme and reasons.
The termination of my client is quite
illegal, unjustified and without
sufficient cause and reason.

14. That the action of you noticee of


terminating the services of my client, is
illegal, unjustified, vindictive,
victimizing and against the principles of
natural justice and fair play and my
client is entitled to reinstatement in
services with full back wages and other
service benefits.

15. That it is also relevant to point out here


that you noticee has not provided any
service benefits to my client
intentionally and deliberately.

16. That it is pertinent to mention here that


you noticee is still liable to pay all the
service benefits to my client alongwith
all due salary from March-2016.

I, therefore call upon you through this


legal notice to reinstate the services of my
client with full back/earned wages and
overtime and other service benefits/
consequential benefits of my client and
continuity of services, within 07 days from
the date of receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate legal proceedings
against you totally on your costs, risks and
consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.
ZAKIR ALI Chamber No.F-602, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
M. 9213939759
Ref: DATE: 27.10.2017

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
SH. ZAKIR RAZA
ADVOCATE,
AT: CHAMBER NO.F-424,
4TH FLOOR, F-BLOCK,
KARKARDOOMA COURTS,
DELHI-110032

Sir,
My client MOHD. NASIR, S/O SH GULAM SABIR,
R/O H.NO.1181, GALI NO.18/2, E2-BLOCK, NEAR
NIZAMIYA SCHOOL, NEHRU VIHAR, MUSTAFABAD, DELHI-
110094 has placed before me your legal notice
dated 09.10.2017 sent by you on behalf of your
client GULFAM, S/O LATE RAHIS AHMAD, R/O D-
285/6, GALI NO.4, NOOR ELAHI, GHONDA EXTN.,
DELHI-110053, and my clients instructed me to
give the reply of the same and brought true
facts into your knowledge, which facts are as
under:-
PRELIMINARY OBJECTIONS:-
13. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.

14. That your client did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

15. That the true fact is that my client has not


borrowed even a single penny from your
client at any point of time even my client
does not know your client in any manner.

16. That your client is a fraud and cheater and


the fact is that my client has lost his
original blank signed cheque bearing
No.107748 and completely blank Cheque
No.107749 somewhere and in this regard my
client has also lodged a missing report with
Crime Branch, Delhi vide LR No.1439561/2017
dated 17.08.2017.
17. That my client has further informed his
concerned bank to Stop Payment of the said
lost cheques.

18. That now my client has shocked to receive


the present legal notice, as he has come to
know that one of the above said cheque
No.107748 has been misused by your client
with the malafide intention and ulterior
motives to cause wrongful loss to my client
and wrongful gain to herself, hence my
client is going to file separate criminal/
legal complaint against your client for his
above said illegal and unwarranted acts. My
client having sufficient proofs to prove his
contention, which may be produced at the
relevant stage.

19. That my client is not liable to pay even a


single penny to your client in any manner,
while it is your client who is liable to
return the said original cheques to my
client with immediate effect.

REPLY ON MERITS:-
1-2. That the contents of Para No.1 & 2 of your
legal notice are wrong, false, and
concocted, hence denied. However, it is
submitted that all the averments and
versions as alleged in the paras under reply
are nothing, but an ill tactics only to
create false evidences against my client,
and the same is total bunch of lies nothing
else. It is further submitted that my client
does not even know your client and my client
is not liable to pay even a single penny to
your client in any manner. The contents of
whole Preliminary Objections may be read as
part and parcel as reply of this Para, same
are not being reproduced herein for the sake
of brevity.

3-5. That the contents of Para No.3 to 5 of


your legal notice are wrong and denied.
However, it is submitted that your client
has misused the blank cheques of my client
illegally and unlawfully, for which my
client reserves his right to initiate
separate legal proceedings against your
client.

6-7. That the contents of Para No.6 to 7 of your


legal notice are wrong and denied. However,
it is submitted that my client is not liable
to pay even a single penny to your client in
any manner and your client is a fraud and
cheater and has sent the present false legal
notice only to extort money from my client.

I, therefore request you through this


reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice and to return the said
original cheques to my client immediately,
otherwise my client will defend the same
with all possible measures laid down in law
and shall also be constrained to initiate
appropriate separate legal action against
your clients totally on the costs, risks and
consequences of your clients.

Your client is also liable to pay


Rs.11,000/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

ZAKIR ALI
ADVOCATE
COPY TO:
SH GULFAM,
S/O LATE RAHIS AHMAD,
R/O D-285/6, GALI NO.4, NOOR ELAHI,
GHONDA EXTN., DELHI-110053

Shyam Kumar Chamber No.F-621, Block-F,


Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-1661/2007 M:- 9868613511
Ref: Dated: 11.10.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH. SURAJ MOHAN
S/O LATE SH. HARI RAM,
R/O 42/15, DEVI NAGAR, GOHANA,
TEHSIL GOHANA, DISTRICT SONEPAT,
HARYANA,

Sir,
Under instructions from and on behalf of my
client SMT. GEETA, D/O SH. HARI OM VERMA, R/O C-
89, C-BLOCK, GANGA VIHAR, DELHI-110094, I hereby
serve upon you through this following legal
notice, facts as under:-

20. That my client got married with you noticee


on 21.02.2003 according to Hindu rites and
customs and in the said marriage, the
parents of my client have spent a huge
amount in the marriage, but despite that you
noticee and your family were not happy with
the same and they used to harass and
humiliate my client even on petty issues.

21. That you noticee and your other family


members usually used to harass and humiliate
my client and taunted her on petty issues
even you noticee used to abuse the parental
family members of my client and also
extended threats to face dire consequences.

22. That thereafter my client cases U/s 12 of


D.V. Act, U/s 125 Cr.P.C. against you
noticee.

23. That thereafter mediation was held between


both the parties on 23.08.2016 before the
Mediation Centre, Karkardooma Court, Delhi,
wherein it was agreed that you noticee shall
pay a total sum of Rs.6,50,000/- (Rupees Six
Lacs and Fifty Thousand only) to my client
and out of which you noticee has paid only
Rs.4 Lacs to my client and now you are
totally avoiding to pay the remaining amount
of Rs.2,50,000/- to my client.

24. That it is pertinent to mention here that as


per the above settlement the case U/s 125
Cr.P.C. was to be withdrawn on 16.09.2016,
but despite that you noticee had not
arranged the money in time, but you became
late in the said payment, but despite that
my client had not raised any objection.

25. That now you noticee is liable to pay


Rs.2,50,000/- to my client at the time of
withdrawal of petition U/s 12 of D.V. case
on 21.09.2016 as per the above said
settlement, but you noticee is regularly
avoiding the same.

26. That you noticee are liable to be prosecuted


under contempt of court proceedings for non
compliance of the order of mediation centre
as well as the statements given before the
court.

I, therefore call upon you through this


legal notice to contact with my client to
make the remaining amount of Rs.2,50,000/-
to my client within 15 days from the receipt
of this legal notice, failing which my
client shall be constrained me to initiate
appropriate civil as well as criminal
proceedings against you and also to re-open
all the withdrawn cases, totally on your
risks, costs and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept for further references in my


office.

Shyam Kumar
Advocate
Mohd. Tasleem G-70, 1st Floor, G-Block,
ADVOCATE Karkardooma Courts,
DELHI HIGH COURT Delhi-110032
EN. No. D-670/2008 M: 8750509595
================================================================================
Ref: Date: 11.10.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
M/S R.P. PACKAGINGS
THROUGH ITS PROP. MR RAJESH PAL
S/O S. RISHIPAL SINGH,
R/O VILLAGE & POST GHORI BACHHERA,
GREATER NOIDA, DISTT. GAUTAM BUDH NAGAR,
U.P.,

Sir,
Under instructions from and on behalf of my
client MR SYED HUSSAIN, S/O SH. NASIR HUSSAIN,
R/O 434, 3RD FLOOR, JANGPURA, MATHURA ROAD, NEW
DELHI, I hereby serve upon you through this
following legal notice, facts as under:-

40. That my client is the owner of an


industrial Unit No.220, having its area
451.20 sq. meters covered area 278.45 sq.m
situated at Sector Udhyog Kendra, Ecotech-
III, Greater Noida, Distt. Gautam Budh
Nagar, U.P.
41. That my client had let-out his above said
industrial unit to you noticee on a
monthly rent of Rs.35,000/- per month, but
thereafter you noticee have failed to pay
the monthly rent of the said tenanted
premises continuously for three months.

42. That consequently you noticee got vacated


the said tenanted premises and at that
time you noticee were under the liability
of paying three month’s rent i.e.
Rs.1,05,000/- alongwith electricity supply
and when my client demanded the said
amount, then you noticee in discharge of
your above said part liability issued,
signed and delivered a cheque bearing
No.422512 of dated 15.08.2017 of
Rs.30,000/-, drawn on Punjab National
Bank, Branch at Ghori Bachhera, Distt.
G.B. Nagar U.P. and at the time of issuing
the aforesaid cheque, you noticee assured
to my client that the said cheque would be
honoured positively at the time of its
presentation in its banker.

43. That consequently as per your assurances


and as per your instructions, my client
has lastly deposited the said cheque in
its banker i.e. ICICI Bank, Branch at RPC,
New Delhi but the said cheque was
dishonoured by your banker with the
remarks “FUNDS INSUFFICIENT”, and my
client received the information through
returning memo dated 27.09.2017.

44. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

45. That you for discharging your liability,


issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.
I, therefore call upon you through
this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.30,000/- (Rupees Thirty Thousand only)
to my client within 15 days from the
receipt of this legal notice, failing
which my client shall be constraint to
initiate appropriate criminal u/s 138 N.I.
Act as well as civil proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

MOHD. TASLEEM
ADVOCATE
Deo Raj Singh Chamber B-108, Baba Guru
ADVOCATE Charan Singh Block,
DELHI HIGH COURT Tis Hazari Courts,Delhi-54
EN. No. D-71/1985 M: 9818414544
================================================================================
Ref: Date: 10.10.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH ASHOK KUMAR
S/O SH KRISHNA KUMAR,
R/O E-74, SANGAM PARK,
MAKHAN PUR, KHODA COLONY,
NEAR HIGH TENSION WIRE,
GHAZIABAD, U.P.

2. SMT. ANNU,
W/O SH. ASHOK KUMAR,
D/O SH. SUBEY SINGH,
R/O E-74, SANGAM PARK,
MAKHAN PUR, KHODA COLONY,
NEAR HIGH TENSION WIRE,
GHAZIABAD, U.P.

Sir/Madam,
Under instructions from and on behalf of my
client namely SH. KRISHNA KUMAR, S/O SH. BHAGMAL
SINGH, R/O 12/301, BLOCK-12, KALYANPURI, DELHI-
110091, I hereby serve upon you through this
following legal notice, facts as under:-
11. That you noticee No.1 are the real son of
my client and you noticee No.2 are the
daughter-in-law of my client, being wife
of noticee No.1.

12. That you both the noticees are regularly


harassing and humiliating my client by
your illegal, and uncooperative acts and
activities and being real son and
daughter-in-law, you noticees are not
caring and helping my client and want to
capture the property of my client within
the collusion and by hatching the
conspiracy with the family members of the
noticee No.2.

13. That very often since beginning, you


noticee No.1 and 2 used to quarrel with my
client on minor issues or the others. And
you noticee No.1 and 2 have threatened my
client that you will implicate my client
and his family members in any false
criminal case and since then my client
always remained in great tension.

14. That my client is the owner of the


property bearing No. E-74, SANGAM PARK,
MAKHAN PUR, KHODA COLONY, NEAR HIGH
TENSION WIRE, GHAZIABAD, U.P., and the
said property is the self-acquired by my
client from his own funds, sources and
earnings and status of you both noticees
in the said property were/are only as a
licencee.

15. That you both noticees No.1 & 2 due to


dishonest intention humiliating and
torturing to my client by one pretext and
another at every moment, due to all these
circumstances and seeing the behaviour of
you noticee No.1 & 2, my client have
debarred you both noticees No.1 & 2 by way
of publication of public notice in daily
Newspaper Rashtriya Sahara dated
07.10.2017. The copy of said publication
is enclosed herewith.

16. That after publishing the said debarred


notice, my client have broken all the ties
and relations with you addressee No.1 & 2
and hence you noticee No.1 & 2 have no
right to stay in the above said property
of my client any more in any manner.
17. That my client do not wish to permit you
addressees No.1 & 2 to live in the said
property in respect of portion which is in
your possession. You are further required
to be noted that my client have terminated
your living capacity/locus standi in said
premises, therefore you noticee No.1 and 2
have no right to stay in the property of
my client and both of you are liable to
pay occupational charges @ Rs.5,000/- per
month w.e.f. 01.11.2017 and now you are
living in the said property as
unauthorized occupants.

18. That it is relevant to mention here that


when you noticees came to know that my
client have debarred both of you noticees
from their all moveable and immoveable
properties, then you both noticees have
abused my client in filthy and abusive
language and threatened my client to
implicate them in some false criminal
cases and due to the said reason, my
client are under great terror and fear
from you noticees.

19. That despite knowledge and information


regarding debar publication and several
oral requests for vacating of the portion
of the above said property in your
possession, you both did not pay any heed
and also not bothered to vacate the
portion in your possession till date,
hence this notice.

I, therefore call upon you through this


legal notice that you noticee No.1 and 2 to
vacate the premises of my client in respect
of the portion which is in your possession,
within 15 days from the date of receipt of
this legal notice, failing which my client
instructed me to initiate appropriate legal
action against you noticee No.1 and 2
totally on your costs, risks and
consequences and you noticee No.1 and 2 will
be liable to pay all the expenses of
litigations to my client.
You are also liable to pay the use and
occupation charges @ Rs.5,000/- per month to
my client in respect of the said premises
w.e.f. 01.11.2017 till the vacation of the
same.
You noticees are liable to pay Rs.5500/-
towards the cost of present legal notice.
Copy kept for further references in my
office.

D.R. Singh
Advocate
VIJAYA TYAGI Off-Cum-Resi: 1020
Advocate Janta Flats, GTB
DELHI HIGH COURT Enclave, Delhi-110093
ENL No.D-1459/07 M:- 9990698323
Ref: Date: 09.10.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
RAO TULA RAM MEMORIAL HOSPITAL
THROUGH ITS CMO(SHIB), DHS(HQ)
AT:- JAFARPUR, NEW DELHI-110073

Sir,
Under instructions from and on behalf of my
client SH. VIKAS TYAGI, S/O SH. KRISHAN KUMAR
TYAGI, R/O H.NO.355/4, WARD NO.7, VILLAGE GARHI
KESRI, TEHSIL GANNAUR, DISTT. SONEPAT, HARYANA,
I hereby serve upon you through this following
legal notice, facts as under:-

1. That my client is a well-qualified Doctor


and he has completed BDS from P.D.M. Dental
College and Research Institute, Bahadurgarh,
Haryana which a reputed university.
2. That on the basis of interview on 20.06.2017
and on the recommendation of selection
committee my client was qualified for the
post of Junior Resident (BDS) in your
hospital.

3. That my client is waiting since last 3½


months for your appointment letter to be
issued to my client. As per your policies,
the above merit list is valid for 6 months
only, but till date you have not offered my
client for any appointment. The merit list
is valid for 6 months only and almost 109
days (3½ months) have been lapsed, but you
did not send any appointment letter to my
client.

4. That if there is no requirement of J.R.


(BDS), then why the interviews were
conducted and you have clearly mentioned in
your merit list that the seats will be
available for the said post.

5. That the entire time of my client is being


wasted by you, due to which my client is
totally messed up and feels like harassed
and humiliated.
6. That my client has no other option but to
ruin his days only in waiting for your
response, which is inadmissible in any
manner.

I, therefore call upon you through this


legal notice to appoint my client on the
abovesaid post of J.R. (BDS), within 15 days
from the receipt of this legal notice,
failing which my client shall failing which
my client shall be constrained to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.

Copy kept for further references in my


office.

VIJAYA TYAGI
ADVOCATE
Salim Ahmed Khan Chamber No.F-218, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1068/92 M. 9810507166
Ref: Dated: 27.09.2017

REPLY OF NOTICE
REGD.A.D/SPEED POST

To,
Mr. Dhruv Vashisht
Advocate
At: H.No.1058, Sector-9,
HIG Duplex, Vasundhara, Ghaziabad,
U.P.,

Sir,
My client M/s Aman Motors, through its
Manager Sh J.S. Sharma, at A-7, Khasra No.30/2,
Main Wazirabad Road, Brijpuri, Delhi-110094 has
placed before me your legal notice dated
15.09.2017 sent by you on behalf of your client
Sh. Nazir Hussain, S/o Sh. Shabbir Ahmed, and my
clients instructed me to give the reply of the
same and brought true facts into your knowledge,
which facts are as under:-

PRELIMINARY OBJECTIONS:-
1. That the notice sent by you on behalf of
your client is totally false, baseless and
bogus and your client has suppressed the
material facts from you and got sent the
present false notice.

2. That your client through your good self is


using defamatory language towards my
client, hence my client is also reserves
his right to initiate separate legal
action against your client for such
defamatory act.

3. That your client has also concealed the


material fact that my client has duly
given a detailed representation dated
28.08.2017 received on 29.08.2017 by your
client in response to e-mails sent by your
client to my client time to time, and the
same has been totally misinformed to your
good self.

4. That the true fact is that your client


approached my client’s showroom on
05.02.2017 to purchase a two wheeler and
your client himself chose one Maestro Edge
VX2016, Red Colour Engine No.
JF33AAGGL13283 Chassis No.MBLJF33AAG and
your client purchased the abovesaid
vehicle worth Rs.59,855/- out of which
your client paid a sum of Rs.20,400/- vide
receipt No.64102 dated 05.02.2017 and rest
of the amount was financed by M/s Hero Fin
Corp. and the said vehicle was registered
in your client’s name vide Regn. No.DL-
5SAY-7655 and your client received the
delivery of the aforesaid vehicle on
05.02.2017 vide delivery receipt No.55132
duly signed and acknowledged by your
client.

5. That in the first week of August 2017,


your client approached my client’s
showroom and inform that in the insurance
policy of his aforesaid vehicle vide
policy No. 39010231166204511577 valid from
05.02.2017 till 04.02.2018, the
manufacturing year has been mentioned as
2017 and your client requested to make
necessary corrections in the said
insurance policy from the concerned
insurance company, i.e. the National
Insurance Co. Ltd., and thereafter, as per
your client’s request, the necessary
corrections have been made by the
concerned insurance in policy, but
thereafter, your client with malafide
intention to harass my client only to
extort money sent the false, baseless and
defamatory emails to my client.

6. That your client have sent many emails to


my client levelling defamatory and
baseless allegations, but the true fact is
that your client himself chosen the
vehicle and all the benefits like
warranty, insurance etc. shall be
effective from the date of purchase of the
abovesaid vehicle not from the date of
manufacturing of vehicle and there is no
harm to your client.

7. That your client levelled false, baseless


and concocted allegations upon my client
in his emails and in the presence of other
customer of my client’s showroom and
tarnish the esteemed reputation of my
client’s showroom outside his business
premises and your client’s said acts have
adversely affected my client’s esteemed
reputation.
8. That my client’s staff duly replied your
client’s emails and requested your client
to come to my client’s showroom to make
your client understand about the company
policy, standard warranty and other after
sale service benefits etc. and after
various requests your client came to my
client’s showroom on 25.08.2017 and he was
satisfied with the purchase of the
aforesaid vehicle from my client’s
showroom and your client has not suffered
any harm and its insurance, standard
warranty and other after sale benefits
would start from the date of purchase of
vehicle not from the date of manufacturing
of vehicle, but thereafter, your client
again sent many emails to my client
thereby levelling defamatory and baseless
allegations only to harass my client and
extort money from my client.

9. That your client is an educated person and


as per his own version he is employed with
M/s Sriram Commercial Vehicle Finance and
he is fully aware that his insurance,
standard warranty and other service
benefits would start from the date of
purchase of above said vehicle and and he
has put his signatures at the time of
purchasing the said vehicle on form No.20
on the basis of said form the abovesaid
vehicle was registered in his name and the
said form clearly shows the year of
manufacturing of vehicle in question as
2016 and it is also mentioned in the
company sticker affixed on the form 20.

10. That it is further noted that there has to


be some time gap in the date of
manufacturing of product and its sale by
the dealer and your client may also
consider one example for your client
understanding as to how can the vehicle
manufactured in the last week of December
2016 and sold in the year 2016 itself.

REPLY ON MERITS:
1. That the contents of your legal notice are
totally wrong, false and frivolous, hence
denied. It is specifically denied that when
your client booked the vehicle from my
client’s showroom the model as per
discussion from my client’s sale manager Mr.
Rajinder the model is of 2017 but after
purchasing and issuing of insurance the year
of model no. was 2017 and in your client
knowledge it was the year of model of 2017
but when your client had taken the vehicles
Registration Certificate he got to know that
the year of MGT DT was 2016. It also denied
that after your client approached to the
showroom and inquire about the matter the
showroom persons misbehave with your client
and said they are not responsible for such
things and your client should have to see
himself before buying the vehicle and said
they are not going to replace it. It is
further denied that after some mailing send
by your client towards the Aman Motors they
send two persons and they both admit that it
is my client’s company mistake or as per
section 420 IPC my client cheated your
client. However, it is submitted that all
the averments and versions as alleged in the
para under reply are nothing, but is a gross
abuse and misuse of the due process of law.
It is further submitted that the contents of
whole preliminary objections may kindly be
read as part and parcel as reply of these
paras, same are not being reproduced herein
for the sake of brevity.
I, therefore request you through this
reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my client
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.

Your client is also liable to pay


Rs.11,000/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

Salim Ahmad Khan


Advocate

COPY TO:

MR. NAZIR HUSSAIN


S/O SH. SHABBIR AHMED,
R/O H.NO.M-20, WELCOME SEELAMPUR-III,
DELHI
GEETA RANI RAJPUT Chamber No. P-19
ADVOCATE Tis Hazari Courts,Delhi-54
ENRL. No.D/1917/06 & Chamber No.E-513,
Karardooma Courts, Delhi
==================================================
Ref: Date: 22.09.2017
COURIER/SPEED POST
LEGAL NOTICE
To,
SH SUMIT UPADHYAY
S/o Dinesh Chandra Upadhyay
R/O C-58, 1ST FLOOR, PANDAV NAGAR,
DELHI-110092

Sir,
Under instructions from and on behalf of my
client SH VINAY KUMAR, S/o SH SURENDER SINGH,
R/o H.no.D-130, GANESH NAGAR, PANDAV NAGAR,
DELHI-110092, I hereby serve you through this
following legal notice, facts as under:-

14. That you noticee and my client are friends


from last so many years and having family
visiting terms.

15. That on 30.05.2017, you approached to my


client and requested for a friendly loan of
Rs.3,00,000/- (Rupees Three Lac only) for a
period of 3 months for your business purpose
and after considering the friendly relations
with you on the same day my client gave a
sum of Rs.3,00,000/- (Rupees Three Lac only)
to you in cash and you assured my client to
return the abovesaid amount within
prescribed period and on the same day in
discharge of your abovesaid liability you
noticee issued a cheque bearing No.000017
dated 30.05.2017 amounting to Rs.3,00,000/-
drawn on Bank of Baroda, Patparganj Branch,
Delhi, in favour of my client and at the
time of issuing the said cheque you assured
my client that at the time of presentation
the said cheque would be encashed.

16. That my client had presented the said cheque


with his banker i.e. ICICI Bank, Branch at:
Jhandewalan, Delhi, but the said cheque was
dishonored by his banker with the remarks
“FUNDS INSUFFICIENT” vide returning memo
dated 24.08.2017.

17. That immediately my client contacted to you


and disclosed the fact about the dishonor of
said cheque and my client demanded the said
cheque amount in cash from you, but since
then you are kept passing the time by one
pretext to another and now you instead of
making the payment of the said cheque, you
have flatly refused to pay the said cheque
amount to my client in any manner and had
also extended threats to face dire
consequences.

18. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act R/W Section 406/420
of Indian Penal code.
I, therefore call upon you through
this legal notice to return the amount of
above said dishonoured cheque i.e.
Rs.3,00,000/- (Rupees Three Lac only) to
my client within 15 days from the receipt
of this legal notice, failing which my
client shall be constraint to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.
Copy kept in my office for further
references.

GEETA RANI RAJPUT


ADVOCATE
Momin Khan F-416, F-Block, 4TH Floor
Advocate Lawyers Chambers Block
Karkardooma Courts Complex,
Delhi-110032.
DELHI HIGH COURT
EN. No. D-300/98 (R) M. 9891158390
Ref. No. DATED: 10.08.2017

REGD.A.D./SPEED POST
To,
SH SURENDER TANEJA,
PROP. OF M/s A.S. CREATION
AT:- F-72, SECTOR-8,
DISTT. GAUTAM BUDH NAGAR,
U.P.

Sir,
Under instructions from and on behalf of my
client M/S PARAS EXPORT, AT: X/4040, GALI No.16,
SHANTI MOHALLA, GANDHI NAGAR, DELHI-110031,
through its Prop. SH NARESH KUMAR JAIN, S/O LATE
SH. PADAM SAIN JAIN, I hereby serve upon you
through this following legal notice, facts as
under:-
46. That my client is in the business of
dealing in exports garments at the above
said address and there are/were business
dealing between you and my client.

47. That you noticee had approached to my


client and purchased the clothes for a sum
of Rs.20,214/- (Rupees Twenty Thousand Two
Hundred Fourteen Only) on 16.03.2017 vide
Bill No.757, dated 16.03.2017 of
Rs.20,214/-, the original bill was duly
received by you noticee and my client kept
the carbon copy of the same. It is also
made clear that a sum of Rs.500/- was also
added qua charges of conveyance which was
paid by my client in cash, hence the total
amount of bill to be paid is Rs.20,714/-.

48. That in discharge of your above said


liability, you noticee issued, signed and
delivered a cheque bearing No.586729 of
Rs.20,714/- of dated 16.04.2017, drawn on
Corporation Bank, Branch at Vasundhra
Enclave, Delhi-110096 in favour of my
client and at the time of issuing the
aforesaid cheque, you noticee assured to
my client that the said cheque would be
honoured positively at the time of its
presentation in its banker.

49. That consequently as per your assurances


and as per your instructions, my client
has lastly deposited the said cheque in
its banker i.e. Axis Bank, Branch at F-
2/25, Krishna Nagar, Delhi-110051, but the
said cheque was dishonoured by your banker
with the remarks “FUNDS INSUFFICIENT”, and
my client received the information through
returning memo dated 13.07.2017.

50. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

51. That you for discharging your liability,


issued, signed and delivered the abovesaid
cheque, which was dishonored by your
banker and thus you breached the trust of
my client and committed an offence
punishable under Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.20,714/- (Rupees Twenty Thousand Seven
Hundred Fourteen only) to my client within
15 days from the receipt of this legal
notice, failing which my client shall be
constraint to initiate appropriate
criminal u/s 138 N.I. Act as well as civil
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

MOMIN KHAN
ADVOCATE
Mamtesh Sharma Chamber No.F-709, F-Block
th
Advocate 7 Floor, Lawyers Chambers
Block, Kakardooma Courts
DELHI HIGH COURT Delhi-110032
E-mail: mmamtesh@gmail.com Ph: 09810322929, 08860077857
==================================================================
Ref: Date: 06.08.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S MILLENNIUM CONSTRUCTION PVT. LTD.
THROUGH ITS DIRECTOR/A.R.
REGD. OFFICE:
C-223, GOLF VIEW APARTMENTS,
SAKET, NEW DELHI-110017,
TEL: 011- 26966303

CORPORATE OFFICE ALSO AT:


104, SOUTH CITY ARCADE,
SOUTH CITY-1, GURUGRAM-122 007 (GURGAON)
TEL: 95-124-2581201

Sir,
Under instructions from and on behalf of my
client M/S GOYAL SALES CORPORATION, THROUGH ITS
PROP. SH. SANJAY GOYAL, HEAD OFFICE AT: 357,
VARDHMAN GRAND PLAZA, MANGLAM PLACE, SECTOR-3,
ROHINI, NEW DELHI-110085, ALSO CORPORATE OFF:
SHOP NO.2, GROUND FLOOR, PLOT NO.28, GIRDHAR
ENCLAVE, SAHIBABAD, GHAZIABAD, U.P., I hereby
serve upon you through this following legal
notice, facts as under:-
1. That my client M/s Goyal Sales Corporation
is doing the work of POP Fall Ceiling,
Gypsum, Grid, Paint, White Wash etc. at the
above given address.

2. That on 30.10.2013, you noticee placed a


work order vide Ref. No. MCPL/SITE/NOIDA-
100/W.O/13-14/3010 for the Scope of Work
“P.Fixing 12.5 mm thick gypsum board fall
ceiling work for boxes, ceiling etc. (with
gypsum India make material)” and “P/Fixing 8
mm thick calcium silicate board fall ceiling
in toilet & lobbies etc. (with Ramco make
board).

3. That it is relevant to point out here that


the rates for the said work were duly agreed
between my client and you noticee as per
your work order dated 30.10.2013.

4. That consequently my client has completed


the work which was assigned to him by you as
mentioned in the corresponding para upto the
total satisfaction of you noticee as well as
under your supervision.

5. That it is relevant to point out here that


my client during the above said period, had
raised various bills/ invoices to you
noticee from time to time and as per the
statement of account maintained by my
client, my client has raised the full and
final bill which includes the cost of
material, which was left at the site by my
client as well as 5% security amount.

6. That as per the statement of account


maintained by my client, you noticee are
still liable to pay a sum of Rs.5,89,588/-
(Rupees Five Lacs, Eighty Nine Thousand,
Five Hundred and Eighty Eight only) to my
client.

7. That it is important to note here that it


was agreed between my client and you noticee
that the payment will be made through cheque
and the monthly bill will be paid after 15
days of receiving the bill, but despite that
the said terms and conditions were not
complied by you noticee intentionally and
deliberately with the maalfide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.
8. That despite of repeated requests and
demands made by my client, you noticee have
failed to make the full and final payment to
my client till date, however, it is made
clear that you noticee had made the last
part payment of the bill on 18.02.2017.

9. That as per the records maintained by my


client, a sum of Rs.5,89,588/- (Rupees Five
Lacs, Eighty Nine Thousand, Five Hundred and
Eighty Eight only) are still due upon you
noticee, which are legally recoverable from
you, but despite repeated requests and
demands made by my client, you noticee have
failed to make the aforesaid due payment of
Rs.5,89,588/- (Rupees Five Lacs, Eighty Nine
Thousand, Five Hundred and Eighty Eight
only) to my client intentionally and
deliberately.

10. That it is also relevant to point out here


that you noticee only to avoid the aforesaid
payments to my client and with the intention
to grab the same, you started making false
and frivolous pretexts and started raising
question on the work, but it is made clear
that all the work was done in your regular
presence as well as under your whole
supervision and upto your total
satisfaction, but now only to avoid the
payment, you are plying ill tactics to grab
the hard earned money of my client.

11. That my client also reserves his right to


initiate separate criminal proceedings
against you noticee for cheating, criminal
breach of trust and misappropriation of
funds, which is a punishable offence under
the Indian Penal Code, 1860.

I, therefore call upon you through this


legal notice to make the payment of
Rs.5,89,588/- (Rupees Five Lacs, Eighty Nine
Thousand, Five Hundred and Eighty Eight
only) to my client alongwith interest at the
tune of 24% per annum to my client within 15
days, from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate civil as well
criminal proceeding against you totally on
your costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

Mamtesh Sharma
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: .08.2017

REGD.A.D/SPEED POST
LEGAL NOTICE

To,
M/S NAV SHAKTI BUILDER
Through its Prop./A.R.
Mr. K.P. DHAM,
AT: 218-A, RAMA MARKET,
PITAM PURA, DELHI-110034

Sir,
Under instructions from and on behalf of my
client M/s HOMZ HARDWARE, THROUGH ITS PROP.
SH.NARENDER KUMAR PAHUJA AT: SHOP NO.12, C-9/12,
KRISHNA NAGAR, DELHI-110051, I hereby serve upon
you through this following legal notice, facts
as under:-

52. That my client is doing the business of


manufacturing and supply of hardware
equipment in the name and style of M/s
Homz Hardware and running its office at
the above given address.
53. That you noticee is the regular customer
of my client and you noticee used to
purchase various articles from my client
against various invoices/bills time to
time.

54. That as per the statement of account


maintained by my client, you noticee have
purchased the articles/goods in the
between period i.e. 19.11.2016 to
06.03.2017 for a sum total of
Rs.2,14,186/-, out of which Rs.1,58,352/-
are still outstanding on you noticee.

55. That in discharge of your above said part


liability against the above said purchase,
you noticee have issued One cheque
No.047891 of Rs.4,000/- of dated
15.07.2017, drawn on Allahabad Bank,
Branch at Pitampura, New Delhi and at the
time of issuing the aforesaid cheque, you
noticee assured to my client that the said
cheque would be honoured positively at the
time of its presentation in its banker.

56. That consequently as per your assurances


and as per your instructions, my client
has deposited the said cheque in its
banker i.e. Axis Bank, Branch at Ashoka
Niketan, Delhi, but the said cheque was
dishonoured by your banker with the
remarks “EXCEEDS ARRANGEMENT”, and my
client received the information through
returning memo dated 27.07.2017.

57. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

58. That you for discharging your part


liability, issued, signed and delivered
the abovesaid cheque, which was dishonored
by your banker and thus you breached the
trust of my client and committed an
offence punishable under Section 138 of
N.I. Act.
I, therefore call upon you through
this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.4,000/- (Rupees Four Thousand only) to
my client within 15 days from the receipt
of this legal notice, failing which my
client shall be constraint to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

PANKAJ BHUSHAN
ADVOCATE
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: .08.2017

REGD.A.D/SPEED POST
LEGAL NOTICE

To,
M/S NAV SHAKTI BUILDER
Through its Prop./A.R.
Mr. K.P. DHAM,
AT: 218-A, RAMA MARKET,
PITAM PURA, DELHI-110034

Sir,
Under instructions from and on behalf of my
client M/s HOMZ HARDWARE, THROUGH ITS PROP.
SH.NARENDER KUMAR PAHUJA AT: SHOP NO.12, C-9/12,
KRISHNA NAGAR, DELHI-110051, I hereby serve upon
you through this following legal notice, facts
as under:-

1. That my client is doing the business of


manufacturing and supply of hardware
equipment in the name and style of M/s
Homz Hardware and running its office at
the above given address.
2. That you noticee is the regular customer
of my client and you noticee used to
purchase various articles from my client
against various invoices/bills time to
time.

3. That as per the statement of account


maintained by my client, you noticee have
purchased the articles/goods in the
between period i.e. 19.11.2016 to
06.03.2017 for a sum total of
Rs.2,14,186/-, out of which Rs.1,58,352/-
are still outstanding on you noticee.

4. That in discharge of your above said part


liability against the above said purchase,
you noticee have issued four cheques
bearing No.014303 of Rs.9,000/- dated
20.06.2017, cheque No.014354 of
Rs.17,536/- dated 18.06.2017, cheque
No.014355 of Rs.17,536/- of dated
16.07.2017 and cheque No.014356 of
Rs.17,536/- of dated 25.07.2017 all drawn
on Allahabad Bank, Branch at Pitampura,
New Delhi and at the time of issuing the
aforesaid cheques, you noticee assured to
my client that the said cheques would be
honoured positively at the time of its
presentation in its banker.

5. That consequently as per your assurances


and as per your instructions, my client
had deposited the said cheques in its
banker i.e. Axis Bank, Branch at Ashoka
Niketan, Delhi, but the said cheques were
dishonoured by your banker with the
remarks “EXCEEDS ARRANGEMENT”, and my
client received the information through
returning memo dated 27.07.2017.

6. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheques and my client
demanded the said cheques amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheques, you have flatly
refused to pay the said cheques amount to
my client in any manner.

7. That you for discharging your part


liability, issued, signed and delivered
the abovesaid cheques, which was
dishonored by your banker and thus you
breached the trust of my client and
committed an offence punishable under
Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheques i.e.
total Rs.61,608/- (Rupees Sixty One
Thousand and Six Hundred and Eight only)
to my client within 15 days from the
receipt of this legal notice, failing
which my client shall be constraint to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

PANKAJ BHUSHAN
ADVOCATE
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: .08.2017

REGD.A.D/SPEED POST
LEGAL NOTICE

To,
M/S NAV SHAKTI BUILDER
Through its Prop./A.R.
Mr. K.P. DHAM,
AT: 218-A, RAMA MARKET,
PITAM PURA, DELHI-110034

Sir,
Under instructions from and on behalf of my
client M/s HOMZ HARDWARE, THROUGH ITS PROP.
SH.NARENDER KUMAR PAHUJA AT: SHOP NO.12, C-9/12,
KRISHNA NAGAR, DELHI-110051, I hereby serve upon
you through this following legal notice, facts
as under:-

1. That my client is doing the business of


manufacturing and supply of hardware
equipment in the name and style of M/s
Homz Hardware and running its office at
the above given address.
2. That you noticee is the regular customer
of my client and you noticee used to
purchase various articles from my client
against various invoices/bills time to
time.

3. That as per the statement of account


maintained by my client, you noticee have
purchased the articles/goods in the
between period i.e. 19.11.2016 to
06.03.2017 for a sum total of
Rs.2,14,186/-, out of which Rs.1,58,352/-
are still outstanding on you noticee.

4. That in discharge of your above said part


liability against the above said purchase,
you noticee have issued One cheque
No.014346 of Rs.20,120/- of dated
26.12.2016, drawn on Allahabad Bank,
Branch at Pitampura, New Delhi and at the
time of issuing the aforesaid cheque, you
noticee assured to my client that the said
cheque would be honoured positively at the
time of its presentation in its banker.

5. That consequently as per your assurances


and as per your instructions, my client
has deposited the said cheque in its
banker i.e. Axis Bank, Branch at Ashoka
Niketan, Delhi, but the said cheque was
dishonoured by your banker with the
remarks “EXCEEDS ARRANGEMENT”, and my
client received the information through
returning memo dated 23.03.2017.

6. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.

7. That you noticee are still liable as well


as legally bound to pay a sum of
Rs.20,120/- (Rupees Twenty Thousand One
Hundred Twenty only) to my client
alongwith interest at the tune of 24%
p.a., hence this notice.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.20,120/- (Rupees Twenty Thousand One
Hundred Twenty only) to my client
alongwith interest @ 24%, within 15 days
from the receipt of this legal notice,
failing which my client shall be
constraint to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.
u
Copy kept in my office for further
references.

PANKAJ BHUSHAN
ADVOCATE
ZAKIR RAZA F-424, 4th Floor, F-BLOCK
Advocate Lawyers Chambers
Karkardooma Courts,
Delhi -110032.
DELHI HIGH COURT M: - 9810424351
ENR No. D-819/1997(R)
Ref. No. DATED: 26.07.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
TO,
SH. SUNIL
PROP. M/S NEERU FASHION,
AT: SHOP NO.9/1257, SAVITRI MARKET,
TIKONA PARK, NEAR POLICE BOOTH,
GANDHI NAGAR, DELHI-110031

Sir,
Under the instructions from and on behalf of
my client namely SH. TALIB HUSSAIN, S/O DR ABDUL
KHALIQ, AT: CHAUDHARY BUILDING, GALI NO.8,
SUBHASH PARK,SHAHDARA, DELHI-110032, I hereby
serve upon you through this following legal
notice facts, as under:-

1. That my above named client is doing the work


of fabrication of readymade pants and
earning for the livelihood of himself and
his family.
2. That from the last few months, my client had
been engaged by you noticee for doing the
fabrication work of trousers (Pants) on
earned wages basis at the rate of Rs.70/-
per pant as agreed between you noticee and
my client.
3. That you noticee time to time placed orders
and supplied fabrics to my client only and
my client engaged cutting master and got
stitched the same by engaging other
stitching workers and when my client
demanded the said payment which is approx.
Rs.2,34,000/-, but you noticee had paid only
Rs.70,000/- to my client and assured that
the remaining amount will also be given
within few weeks.
4. That on 23.07.2017, my client approached you
noticee at your shop at Gandhi Nagar, Delhi
where some persons and two police officials
were already sitting and when my client
demanded his due amount, then they have
threatened my client with dire consequences
and instead of making any payment to my
client, you noticee in opposite demanded
money from my client and showed some forged
and fabricated paper/rough bill to my client
which is of dated 30.03.2017 and my client
has not done any signature on it, but you
noticee has forged the signatures of my
client.
5. That you noticee is still liable and legally
bound to pay Rs.1,64,000/- alongwith
interest at the tune of 18% p.a. to my
client which are legally recoverable from
you noticee and my client further reserves
his right to initiate separate criminal
proceedings against you for forging the
signatures of my client and preparing forged
documents, hence this notice.
I, therefore call upon through this
legal notice to pay Rs.1,64,000/- alongwith
interest at the tune of 18% p.a. to my
client 15 days from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

ZAKIR RAZA
ADVOCATE
INTIMATION CUM LEGAL NOTICE
REGD. A.D./SPEED POST
To,

1. THE GENERAL MANAGER


NORTHERN RAILWAY,
HEADQUARTER, BARODA HOUSE,
NEW DELHI-110001

2. THE INCHARGE,
NORTHERN RAILWAY,
FIROZPUR, LUDHIANA, PUNJAB,

Sir,
Under the instructions from and on behalf of
my client Sh. Sushil Chaturvedi, S/o Sh. Satish
Chaturvedi, R/o L-1/118, Block L-1, Mohan
Garden, D.K. Mohan Garden, West Delhi-110059, I
hereby serve upon you through this legal notice,
facts as under:-

1. That my client is a peace loving and law


abiding citizen of India and is residing at
the above given address and having full
faith over the due process of law.

2. That the brother of my client namely Late


Sh. Sumesh Chaturvedi was working with you
noticee on the post of Technician, Grade-I
and he was appointed on the aforesaid job
with you noticee in the year 1980.

3. That the above said brother my client namely


Late Sh. Sumesh Chaturvedi has expired on
14.06.2017.

4. That it is relevant to point out here that


during his life, the above deceased brother
of my client namely Late Sh. Sumesh
Chaturvedi came in contact with one lady
namely Smt. Shashi, D/o Sh. Asha Ram Pandey,
who disclosed herself as unmarried and got
mischievously solemnized her marriage with
Late Sh. Sumesh Chaturvedi and they both
lived together and out of their
relationship, two children namely Ritika
(Daughter, aged about 12½ years) and Anand
(Son, aged about 11 years) were born out.

5. That it is also pertinent to mention here


that on 23.08.2013, the said Late Sh. Sumesh
Chaturvedi (deceased brother of my client)
got published a public notice in the
newspaper Dainik Savera thereby mentioning
that his wife Shashi, who is aged about 45
years is missing since last sixteen months
and he had also debarred her from his all
moveable and immoveable properties and
broken all ties and relations with her.

6. That later on, it had also came into the


knowledge of my client and his deceased
brother namely Late Sh. Late Sh. Sumesh
Chaturvedi that the said Smt. Shashi was
already married lady with one Sh. Ram
Prakash Mishra, S/o Sh. Shambhu Dayal, but
she was living separately from her husband
due to matrimonial dispute and she had
concealed the said fact from Late Sh. Sumesh
Chaturvedi at the time of marrying with him,
hence the marriage between them is not
valid.

7. That recently after the death of his


brother, my client has also come to know
that the said Smt. Shashi also filed
multiple cases against her husband namely
Sh.Ram Prakash Mishra and one of the said
case is now fixed for 26.07.2017 vide
Petition No.1769/2016 before the concerned
Court at Farukhabad, U.P. and the said Smt.
Shashi is receiving Rs.500/- per month as
maintenance from her said husband.

8. That now the said Smt. Shashi has


established the malafide intention and
ulterior motives to clutch the service
benefits of the deceased brother of my
client namely Late Sh. Sumesh Chaturvedi
with the malafide intention and ulterior
motives.

9. That the said Smt. Shashi has no right,


title or interest over the all moveable and
immoveable properties of Late Sh. Sumesh
Chaturvedi as well as over any of the
service benefits/pension etc. of said Late
Sh. Sumesh Chaturvedi in any manner.

10. That it is also a question and matter of


trial and adjudication that whether the
above said children have any right or title
over the property/ service benefits of Late
Sh. Sumesh Chaturvedi, but it is still clear
from the facts and records that said Smt.
Shashi has no right, title and interest over
the all moveable immoveable properties of
the deceased Late Sh. Sumesh Chaturvedi, as
she was not the legally wedded wife of Late
Sh. Sumesh Chaturvedi, because of existence
of her first marriage and even though, she
had also been debarred from the all moveable
and immoveable properties by Late Sh. Sumesh
Chaturvedi.

11. That the present intimation cum legal notice


is being sent to your department, so that no
injustice can be done in this regard and you
are requested cum called upon not to release
any right, service benefits of Late Sh.
Sumesh Chaturvedi in favour of Smt. Shashi
in any manner whatsoever, as she is not
entitled for the same, hence this notice.

I, therefore, call upon you through this


intimation cum intimation not to release any
rights, service benefits etc. of Late Sh.
Sumesh Chaturvedi in favour of said Smt.
Shashi in future in any manner, failing
which my client shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

Sanjeev Kumar Shukla


Advocate
REGD.A.D.
REPLY OF LEGAL NOTICE
To,
Sh. Anil Chandra Singhal,
Advocate,
AT: W-62, Bhagat Singh Gali,
Babarpur, Shahdara, Delhi-110032

Sir,
My client SMT KESAR, W/o SH AJAY TANWAR, D/o
SH UDAYRAM, R/o VILL. MORTA, GHAZIABAD, U.P.
PRESENTLY AT:- H.No.618/14, RAVIDAS GALI,
VISHWAS NAGAR, SHAHDARA, DELHI-110032, has
placed before me your legal notice dated
12.07.2017 sent by you on behalf of your client
SH. AJAY TANWAR, S/o SH RAJ KUMAR, R/o H.No.160,
VILL. CHILLA, SARAUDA, MAYUR VIHAR, PHASE-I,
DELHI, and my clients instructed me to give the
reply of the same and brought true facts into
your knowledge, which facts are as under:-

PRELIMINARY OBJECTIONS:-
27. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.

28. That your client did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

29. That the true fact is that the marriage


between my client and your client was
solemnized on 24.11.2012 according to Hindu
Rites & Customs and the parents of my client
had gave huge dowry articles in the marriage
and had spent Rs.11 Lac in the said marriage
beyond their capacity.

30. That the marriage was duly consummated


between the parties, but no child was born
out from the said wedlock.

31. That after the marriage your client started


harassing, humiliating, torturing and
taunting my client on the pretext of
bringing less dowry and said that “ISKE
MATA-PITA NE DAHEJ HAMARE MUTABIK NAHIN DIYA
HAI AUR BIRADARI MEIN HAMARI NAAK KATWA DI
HAI” and they raised illegal and unlawful
demand of Rs.1 Lac and one plot measuring 50
Sq. Yds., in Delhi.
32. That the father-in-law used to keep evil
eyes upon my client and on the pretext of
giving blessings used to touch me on various
parts of my body and on refusal of my client
misbehaved with her, when my client brought
this matter to the knowledge of your client,
then your client said that “JAISE MERA
PARIWA CHAHEGA, WAISE HI TUJHE YAHAN RAHNA
PADEGA AUR MERE PITAJI JAISA CHAHTE HAIN
WAISE KARO AGAR TUMHEIN YE SAB PASAND NAHIN
HAI TO YAHAN SE BHAG JAO, KYONKI NAA TO
SHAKAL AUR SURAT KI HAI AUR NAA HI DAHEJ
LEKAR AAI HAI”.

33. That after two months of the marriage my


client became pregnant and when my client
brought this matter to the knowledge of your
client and his family members, then they
became angry and said that “YE BACHCHA KAHAN
SE LEKAR AAI HAI” and your client
pressurized my client to abort the said
unborn child and on refusal of my client
your client pushed my client from the stairs
and the parents of your client beaten her
very brutally with legs and fist blows, due
to which my client suffered a miscarriage,
and thereafter, none of your client and his
family members neither provided medical aid
to my client nor lookafter her. Thereafter,
my client informed her parents about the
said incident, and thereafter, her parents
came to her matrimonial home and then my
client was medically treated and my client
was got admitted in Max Hospital, as she was
denied for admission in Jeevan Hospital,
where my client was medically examined and
due to the abovesaid reason my client is
still suffering from migraine and your
client and his family members leveled false
allegations upon my client that she is
suffering from mental disorder “PAGAL”.

34. That the mother-in-law always used to abuse


my client as “RANDI” thereby saying that
“TERE MERE PATI KE SATH GALAT SAMBANDH
HAIN”.

35. That on 04.01.2015, in the night the father-


in-law under the heavy influence of liquor
misbehaved with my client and when my client
complained about the said incident to your
client, then he said that “JAISE MERE PITA
CHAHENGE TUMHEIN WAISA HI KARNA HOGA, NAHIN
TO TUJHE MARKAR NALE MEIN FENK DUNGA YA G.B.
ROAD PAR TUJHSE PESHA KARWAUNGA” and always
used to extend threats to give divorce to my
client and the mother-in-law said that “AGAR
TUJHE BACHCA NAHIN HUA TO APNE LADKE KI
DUSRI SHADI KAR DUNGI”.

36. That on 05.01.2015 in the night at about 9-


9:30 PM all your client and his family
members had beaten my client very brutally
on the pretext of their illegal demand of
dowry and thrown her out of the matrimonial
house and in this regard my client made 100
number and the Police reached at the spot
and took your client to P.S. Mayur Vihar.

37. That thereafter, on dated 13.01.2015 my


client lodged a complaint in the CAW Cell,
in which the matter was transferred to
Mediation Centre, Karkardooma Courts, Delhi,
where the mediator after seeing and
observing the behaviour and way of talking
of your client and his family members
advised my client to live separately from
her husband, and thereafter, settlement was
arrived between the parties in a total sum
of Rs.6,50,000/- as full and final
settlement and it was also agreed that both
the parties shall live separately and shall
also withdraw all their litigations filed
against each other and shall take divorce
with their mutual consent.

38. That as per the settlement arrived between


the parties, my client filed a first motion
petition for obtaining a decree of divorce
by way of mutual consent and it was agreed
that your client shall pay a sum of
Rs.3,25,000/- to my client at the time of
first motion and on the date of first
motion, your client and his family members
apologized for their guilt and assured my
client that they will never repeat their
illegal and unlawful activities again in
future nor will harass, humiliate and
torture her for their illegal demand of
dowry again and also assured that they will
keep my client and your client in a separate
accommodation and upon believing your client
and his family members my client just only
to save her matrimonial life on 02.06.2015
withdrawn her case and started residing with
your client in Najafgarh area.
39. That as per the settlement my client and
your client was to live in your client Nos.1
& 2’s house, but inspite of the same my
client was provided a rented accommodation
and my client herself borne out the expenses
of the rent. My client tolerated all these
things only in the hope that one day good
sense would prevail in the mind of your
client and his family members and all the
things would become normal and due to the
abovesaid reason my client started working
in a school and also started giving tuitions
and since then my client herself bearing the
entire expenses of the rent and other
household expenses and your client who is
running the shop of iron grills, gates,
welding etc. and whatever he earns from the
said shop used to spend all of it in
consuming liquor alongwith his friends and
despite repeated requests of my client your
client neither paid even a single penny for
the maintenance nor stopped drinking liquor
and they had also got operated my client on
the pretext of child.

40. That your client and his family members are


of quarrelsome nature, Gunda and criminal
type of persons and also convicted in many
other cases.

41. That my client tolerated all these things


only in the hope that one day good sense
would prevail in the mind of your client and
his family members and all the things would
become normal, but all went in vain and the
atrocities and cruelties of your client
increased day by day.

42. That your client and his family members kept


silence for sometime, but thereafter, again
started abusing my client in filthy language
and beaten her very brutally thereby saying
that “MAIN TO TUJHE RAKHNA HI NAHIN CHAHTA
THA, MAGAR COURT KE JHAMELE SE BACHNE KE
LIYE MERE PITAJI NE MUJHE MAJBOOR KAR DIYA”.

43. That your client used and beat my client


very brutally under the heavy influence of
liquor almost daily and again raised illegal
demand of dowry and your client also made
unnatural physical relations with my client
forcibly and when my client raised objection
in this regard, then he beaten her very
brutally like animals and your client also
used to instigate the locality persons,
students and teachers of the school against
my client.

44. That the father-in-law is having various


properties and in one of the property the
electricity department conducted raid, due
to which the electricity department issued
bill amounting in Lacs and the dues of the
same were paid by your client and 2 by
selling out the jewellery articles of my
client.

45. That on 01.04.2017, all your client and his


family members on the pretext of their
illegal demand of dowry beaten my client
very brutally and said that “JAB TAK TU 1
LAKH RUPYE CASH AUR EK 50 GAJ KA PLOT Delhi
MEIN APNE BAAP SE DILWA NAHIN DETI TAB TAK
TU YAHAN AANE KI KOSHISH MAT KARNA NAHIN TO
TUJHE JAAN SE MAAR DENGE”, on which my
client requested thereby saying that “MERE
MATA-PITA KAFI GARIB HAIN AUR MEHNAT MAJDURI
KARKE APNI GUJAR-BASAR KAR RAHE HAIN AUR
MERA CHHOTA BHAI ABHI AVIVAHIT HAI, USKE
BHARAN0POSHAN AUR SHADI KI JIMMEDARI UN PAR
HAI, WO APKI MANG PURI NAHIN KAR SAKTE”, on
which all your client and his family members
became angry and in connivance with each
other abused my client in filthy language
and beaten her very brutally and the parents
of your client were instigating your client
thereby saying that “AJAY ISKO ITNA MAAR KI
YE AAJ HI APNE BAAP SE HAMARI DEMAND PURI
KARNE KE LIYE KAHE” and your client Nos.1 &
2 have beaten my client with legs and fist
blows very brutally and the mother-in-law
caught hold the hairs of my client and gave
slaps on her face and thrown out my client
from her matrimonial home and after hearing
the noise the persons of the locality
gathered there and my client only to save
herself went to her parental home only in
wearing clothes.

46. That since then my client is residing at her


sister’s house, because her parents are very
poor and they are unable to bear the
expenses of my client, but your client and
his family members neither came to take my
client back to her matrimonial home nor
providing even a single penny to her towards
maintenance and the parents of my client on
several occasions requested your client and
his family members to keep back my client at
her matrimonial home, but your client and
his family members were adamant on their
illegal demand of dowry and your client said
that “AGAR HAMARI DEMAND PURI NAHIN HUI TO
MAIN TUJHE TALAK DE DUNGA AUR APNI DUSRI
JAGAH SE SHADI KAR LUNGA, JO MUJHE PLOT AUR
VASH PAISE DE RAHE HAIN”.

47. That just after the marriage, the mother-in-


law took all the jewellery articles of my
client on the pretext that “YAHAN CHORI HONE
KA DAR RAHTA HAI AUR JAB TUMHEIN INKI
JARURAT HOGI, TUMHEIN DE DUNGI”, but despite
repeated requests of my client the mother-
in-law did not return the same and sold out
the same without the knowledge and consent
of my client.

48. That your client is running a shop of Iron


Grills, Gates and Welding and is earning
more than Rs.50,000/- per month and your
client has also let out various properties
on rent from which he is getting a rent of
more than Rs.50,000/- per month and as such
your client is earning more than
Rs.1,00,000/- (Rupees One Lac only) approx.
and your client has no other liability
except to maintain my client.

49. That your client got sent the present false


and frivolous legal notice to my client only
to create false evidences and in counter
blast to the cases and complaint filed by my
client.

50. That it is also submitted that it is the


admitted case on your client’s part that the
alleged acts of defamation were occurred
much before, but he has not made even a
single complaint and did not raise this
issue earlier, which clearly shows that this
is an afterthought and no such incident had
ever been taken place at any point of time.

51. That no any act of defamation has ever been


committed by my client at any point of time.

REPLY ON MERITS:-
1.20. That the contents of Para No.1 to 20 of
your legal notice are wrong, false, and
concocted, hence denied. However, it is
submitted that all the averments and
versions as alleged in the paras under
reply are nothing, but an ill tactics only
to create false evidences against my
client, and the same is total bunch of lies
nothing else. It is further submitted that
my client is not liable to pay even a
single penny to your client in any manner.
The contents of whole Preliminary
Objections may be read as part and parcel
as reply of this Para, same are not being
reproduced herein for the sake of brevity.

I, therefore request you through this


reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my client
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.
Your clients are also liable to pay
Rs.5500/- as legal remuneration of this
reply.

Copy kept for further references in my


office.
Sunil Kumar
Advocate
LEGAL NOTICE
REGD. A.D./SPEED POST
To,
SH.AMAN,
S/o Sh.
R/O

Sir,
Under the instructions from and on behalf of
my client M/s Sunshine Buildtech, through its
Partner Sh. Bhupesh Arya, at: 70, Dayanand
Vihar, Delhi-110092, I hereby serve upon you
through this legal notice, facts as under:-

1. That my above said client is a reputed firm


and dealing in the field of civil
construction work and real estate etc. and
having its registered office at: 70,
Dayanand Vihar, Delhi-110092.

2. That you noticee approached to my client and


requested to give you a job as Site
Engineer, as you disclosed that you are a
civil engineer (B.Tech) by profession.
3. That consequently as per your ability, my
client has appointed you noticee as Site
Engineer in its above said firm.

4. That consequently my client got a tender for


construction work at Delhi Public School, at
Pataudi, Gurugram, Haryana and for the said
purpose, my client has appointed you noticee
as site engineer for doing the construction
work at the above said site.

5. That during the said construction work, you


noticee has done wrong construction work,
which is detailed as below:

(i) Wrong AAC Block work 14cm @ Rs.4,000/-


i.e. total Rs.56,000/-.

(ii) Dismantling the AAC costing to


Rs.6,000/-.

(iii) Wrong excavation and PCC in playground


costing to Rs.2100/-.

(iv) PCC labour with material costing to


Rs.10,500/-.

(v) Lintel level variation cost Rs.7,000/-


for ground floor in all ABC block and
at first floor A & B Block.
6. That besides the above said wrongful act,
you have done so many negligence during your
above said work and not only this, you
noticee were also given the work of bill
preparation, but you have negligently given
the same to the pity contractors of my
client by showing the extra measurements
without the permission and consent of my
client, and thus, you noticee breached the
trust of my client.

7. That the another partner of my client firm


namely Sh. Sudhir on so many occasions told
to you to meet with Mr. Ravi, one of the
pity contractor of my client for the purpose
to get him satisfied in respect of extra
measurement of bills, but you noticee also
not performed this part.

8. That as per the lumpsum calculation made by


my client, you noticee are liable to pay a
sum of Rs.83,000/- (Rupees Eighty Three
Thousand only) to my client as damages/ loss
caused because of your above said
unwarranted and negligent acts, hence this
notice.
I, therefore call upon you to pay a sum
of Rs.83,000/- (Rupees Eighty Three Thousand
only) to my client towards damages/ loss
caused because of your above said
unwarranted and negligent acts, within 15
days from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

A.Ali Khan
Advocate
Kapil Singhal D-402, D-Block, 4TH Floor
Advocate Lawyers Chambers Block
Karkardooma Courts Complex,
Delhi-110032.
DELHI HIGH COURT
EN. No. D-1959/11 M. 9818899123
Ref. No. DATED:21.07.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
1. SHRI HARI KISHAN AGGARWAL,
2. SHRI ASHOK KUMAR GARG,
3. SHRI SUSHIL KUMAR GARG,
4. SHRI SHASHI BHUSHAN GARG,
ALL S/O LATE SH MOTHEY LAL,
ALL R/O H-36, VIJAY CHOWK,
LAXMI NAGAR, DELHI-110092
5. SHRI JAGDISH PRASAD GARG
S/O LATE SH. MONTHEY LAL
R/o M-109/A, JAGAT RAM PARK,
LAXMI NAGAR, DELHI-110092
Sir,
Under instructions from and on behalf of my

clients (1) SMT RITA GARG, W/O LATE SH SATISH

KUMAR GARG, (2) HIMANSHU GARG, S/O LATE SH.

SATISH KUMAR GARG, (3) DIVYA GARG, D/O LATE SH.

SATISH KUMAR GARG, ALL R/O H-36, VIJAY CHOWK,


LAXMI NAGAR, DELHI-110092, I hereby serve you

through this following legal notice, facts as

under:-

1. That you notice no.5 had filed a suit for


partition against the aforesaid all noticees
and the husband of my aforesaid client no.1
regarding the property No. H-36, measuring
51X30, measuring 167 sq. yards and property
No.H-35, 18X30 measuring 59 sq. yards, which
is part of property bearing Khasra No.65,
situated in the area of village Shakarpur
Khas, abadi of Gulshan Park, Illaqa
Shahdara, Delhi-110092 which is in the name
of Smt. Kaushalya Devi, mother of all you
noticees.

2. That after the death of the husband of my


client no.1, you noticee no.5 has impleaded
my clients as the legal heirs in a civil
suit titled as “Jagdish Prasad Garg vs. Hari
Kishan Aggarwal & Ors”.

3. That on 20.04.2017, a compromise /


settlement had taken place between you
noticees and my clients in the mediation
centre, Karkardooma Courts which is as
under:

(a) That Smt. Kamla Devi, Laxmi Devi,


Krishna Devi, Shashi @ Rajni Gupta and
Chander Kala @ Pinki Gupta have already
relinquished their shares in respect of
property in the name of all you noticees
including the husband of my client No.1.

(b) That it was also settled during the


mediation that all the parties agreed to
make addition, alteration and repair in
the said property and make necessary
applications, if required for any of the
aforesaid work.

(c) That all the parties agree to engage,


appoint any Advocate, Attorney or
Attorneys to receive the compensation
from the government in case of
acquisition of the property or land, to
apply for enhancement of compensation or
take any other steps in respect of the
said subject matter.
(d) That all the parties mutually appoint
Sushil Garg as the Special Power
Attorney holder on behalf of all the
parties and all the parties also
executed the Special Power of Attorney
in favour of Sushil Garg dated
06.04.2017 duly registered in Notary
Public.

(e) That it is settled between all the


party(s) that the Property be sold on
mutual settled amount between all the
parties and when the said property is
sold by the attorney holder Sushil Garg
then the earnest money/ part payment /
bayana amount/ full n final
consideration amount shall be received
only in the presence of all the parties
and if he fail to do so then the said
agreement done by attorney Sushil Garg
will be treated as Null and Void.

(f) That all the money received by the


attorney holder must be divided equally
(1/6 share) among all the parties and
attorney holder must take the separate
receipt of among given to every party
for his future reference.

(g) That all the parties agree to take or


initiate any action before any authority
or court for the safety, protection and
maintenance of the said property and to
manage the same is the best possible
manner.

4. That my client many times requested you


noticees to follow the mediation order of
dated 20.04.2017, but you noticees are
avoiding the mediation orders on one and
other false pretexts and tried to delay the
mediation settlement.

5. That my client have several times brought


the buyers who wants to purchase the
aforesaid properties at very good price and
my client also asked you noticees to sale of
the property, but you noticees are avoiding
the same.

6. That now my client have understood the you


have no clear intentions to follow the
mediation settlement, but wants to avoid the
same, hence this notice.

I, therefore call upon you through this


legal notice to comply the mediation
settlement dated 20.04.2017 within the
period of 15 days from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

KAPIL SINGHAL
ADVOCATE
Momin Khan F-416, F-Block, 4TH Floor
Advocate Lawyers Chambers Block
Karkardooma Courts Complex,
Delhi-110032.
DELHI HIGH COURT
EN. No. D-300/98 (R) M. 9891158390
Ref. No. DATED:20.07.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH DEV PRAKASH
C/o BADRI PRASHAD,
R/o E-2/38, GALI No.9,
CHANDRALOK, SHAHDARA,
DELHI
Sir,
Under instructions from and on behalf of my

client SH AJAY KUMAR SHARMA, S/o LATE SH ANAND

KUMAR SHARMA, R/o 245, GALI No.1, CHANDRALOK,

SHAHDARA, DELHI, I hereby serve you through this

following legal notice, facts as under:-

1. That you and my client having good

friendly as well as visiting terms since

long-time and consequently on 10.04.2017

you requested to arrange a sum of

Rs.50,000/- as friendly loan you disclosed

that you were in dire need of money and on

same day i.e. on 10.04.2017, my client

handed over the said amount of Rs.50,000/-

in cash to you at his residence.

2. That thereafter, on 05.06.2017, you

noticee came at the residence of my client

and when my client demanded the said

amount of Rs.50,000/-, then in discharge


of your abovesaid liability, you noticee

issued a cheque bearing No.425393 of

Rs.50,000/- dated 05.06.2017 drawn on

Corporation Bank, branch at Dilshad

Garden, Delhi-110095 and at the time of

issuing the aforesaid cheque you assured

my client that the said cheque would be

honoured positively at the time of its

presentation.

3. That as per your assurance my client had

presented the said cheque with his banker

i.e. State Bank of India, branch at Satnam

Marg, Delhi-110051, three times, but

finally the said cheque was dishonoured by

your banker with the remarks “FUNDS

INSUFFICIENT” vide returning memo dated

10.07.2017.

4. That thereafter, my client contacted you

noticee and disclosed the fact about the


dishonour of the said cheque and my client

demanded the said dishonoured cheque

amount from you noticee, but you noticee

kept on passing the time by one pretext of

the another and now you noticee has flatly

refused to pay the said cheque amount to

my client.

5. That for discharging your abovesaid

liability issued signed and delivered the

abovesaid cheque which was dishonoured by

your banker and thus you breached the

trust of my client and committed an

offence punishable under Section 138 of

N.I. Act.

I, therefore, call upon you through


this legal notice to return the amount of
abovesaid dishonoured cheque i.e.
Rs.50,000/- (Rupees Fifty Thousand only)
to my client within 15 days from the date
of receipt of this legal notice, failing
which my client shall be constrained to
initiate appropriate Civil as well as
Criminal proceeding against you totally on
your costs, risks and consequences.
Copy kept in my Office for further
references.

MOMIN KHAN
ADVOCATE
R.K. Gupta & Associates
Advocates & Legal Advisors
Delhi High Court & Supreme Court of India
Chambers No.343, 3rd Floor, Lawyers, Chambers Block,
Saket Courts Complex, New Delhi-110017
Enl. No.D-754/1998(R), Mob: 9818090143
Ref: LN/07/2017/31 Date: 19.07.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S HARSH ART & CRAFT
THROUGH ITS PROP.
SH. HARSH VYAS
S/O NEELKAMAL VYAS,
AT: PLOT NO.70, K.NO.164/2,
HASTINAPUR, TANAVDA ROAD,
JODHPUR, RAJASTHAN

Sir,
Under instructions from and on behalf of my
client M/S A.R. ENTERPRISES, THROUGH ITS PROP.
SH. SANTOSH KUMAR, AT: 4731/47, HARDHIYAN SINGH
ROAD, REGHAR PURA, KAROL BAGH, NEW DELHI-110005,
I hereby serve upon you through this following
legal notice, facts as under:-

1. That my client is dealing in the business

of selling and supplying of various types

of Leather, Leather goods/items and doing


its business in the name and style of M/s

A.R. Enterprises and having its office at:

4731/47, HADHIYAN SINGH ROAD, REGHAR PURA,

KAROL BAGH, NEW DELHI-110005.

2. That you above named noticee usually used

to purchase the various items of Leather

from my client from time to time and you

used to make the payment accordingly as

per the retail invoices to my client by

cash /card / cheques etc.

3. That consequently in the month June-2017,

you noticee purchased the Dress Leather

from my client against Retail Invoice

No.1301, dated 28.06.2017 for Rs.98,303.94

and the same were duly received by you.

4. That in discharge of your above said

liability, you noticee issued, signed and

delivered one post-dated cheque bearing

No.000010 of Rs.98,494/- (against Retail


Invoice No.1301, dated 28.06.2017 and some

pity cash transaction of less than

Rs.200/- approx.) of dated 05.07.2017

drawn on Bank of Baroda, Kuri Bhgagtasani

Housing Board, Branch at Jodhpur,

Rajasthan and at the time of issuing the

aforesaid cheque, you noticee assured my

client that the said cheque would be

honoured positively at the time of its

presentation.

5. That thereafter, as per your instructions,

my client presented the said cheque with

his banker i.e. Bank of Baroda, Branch at

Karol Bagh, Delhi, but the said cheque got

dishonoured on with remarks “FUNDS

INSUFFICIENT” vide its returning memo

dated 06.07.2017.

6. That thereafter, my client approached you

noticee to apprise you about the dishonour


of the abovesaid cheque, but you noticee

showed your inability and did not pay any

heed to pay back the abovesaid amount to

my client and since then you noticee kept

passed the time by one pretext or the

other and now you noticee instead of

making the payment of the abovesaid

cheque, flatly refused to make the

aforesaid payment to my client in any

manner.

7. That in discharge of your legally

enforceable liability, you noticee issued,

signed and delivered the above said cheque

which was dishonoured by the banker of you

noticee, as you noticee has not arranged

the sufficient amount in your banker/

account and thus you noticee breached the

trust of my client and committed an

offence punishable under section 138 of

N.I. Act.
I, therefore call upon you through this
legal notice to make the payment of the
above said dishonoured cheque i.e.
Rs.98,494/- (Rupees Ninety Eight Thousand
Four Hundred and Ninety Four only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

R.K. GUPTA
ADVOCATE
GOPESH TRIPATHI & ASSOCIATES
ADVOCATES
CH.NO.E-712, 7TH FLOOR, LAWYER’S CHAMBER BLOCK, KARKARDOOMA COURTS
COMPLEX, DELHI
(M) No.9958841600
===========================================================================
REF. No. DATED: 19.07.2017

LEGAL NOTICE/REPLY
REGD. A.D./SPEED POST

To,
THE ORIENTAL INSURANCE COMPANY LIMITED
THROUGH ITS PRINCIPAL OFFICER/MANAGER
AT: SERVICE CENTRE (NRO-2), 4E/14,
JHANWALAN EXTN., GROUND FLOOR,
AZAD BHAWAN, DELHI-110055

REGD. OFFICE AT:


THROUGH ITS MANAGER,
A-25/27, ORIENTAL HOUSE,
ASAF ALI ROAD, NEW DELHI-110002

BRANCH OFFICE AT:


THROUGH ITS MANAGER,
CBO-12, A-159, VIKAS MARG,
SHAKARPUR, DELHI-110092

Sir,
Under the instructions from and on behalf of
my client SH MANVENDRA PRATAP SINGH, S/o SH
SURENDRA PAL SINGH, R/o H.No.G-1, MAIN MARKET,
SHAKARPUR, DELHI-110092, I hereby serve upon you
through this legal notice, facts as under:-

1. That my client is the registered owner of


the vehicle bearing No.DL-7CD-7687 (MARUTI
ESTEEM), which was insured with you the
noticee vide Policy No.271701/31/2016/4238
valid from 08.01.2016 to 07.01.2017. My
client has paid a sum of Rs.4,775/-, as
insurance premium, which has been duly
received by you the insurance company and
issued a motor insurance certificate-cum-
policy schedule from your Office vide its
issue Office code No.271701 and the
address of Office is CBO 12 SHAKARPUR,
situated at A-159, Vikas Marg, Shakarpur,
Delhi-110092. You noticee is also having
its divisional Office at B-15, Oriental
Enclave, Plot No.32, I.P. Extn.,
Patparganj, Delhi-110092 and to that
effect the CBO Office 12, Shakarpur, Delhi
situated at A-159, Vikas Marg, Shakarpur,
Delhi-110092, issued a receipt.

2. That at the time of above insurance, you


noticee had assessed the value of the
abovesaid vehicle of my client to the tune
of Rs.1,12,000/- including series of claim
arising out of one event and Per Annum
Cover U/s 3 Regd. owner-cum-driver
(C.S.I.) for Rs.20,000/- and the value for
the CNG and LPG is Rs.12,000/-.

3. That on 22.03.2016 my client was going to


petrol pump and when he reached near Bhai
Parmanand Polytechnic, Shakarpur, Delhi-
110092, then sudden a technical problem
was occurred in the said car and the car
got stalled/off down. My client tried to
start his car, but it did not start.
Thereafter my client parked his above said
Car near the gate of Bhai Parmanand
Polytechnic College and locked it properly
and told the watchman to keep an eye over
the said car, untill my client will not
return back. Thereafter my client went to
Bank, which was just in front of Bhai
Parmanand Polytechnic College, and after
that, he went to call the mechanic to get
the vehicle roadworthy.

4. That thereafter my client went back to the


vehicle alongwith motor mechanic, but
found that his car was not available
there. Then my client tried to search out
his car in the vicinity and also
approached the traffic Police Tow-away
parking near Mother Dairy Flats and also
to Shakarpur Police Station, but there was
no clue of the car of my client.

5. That finding no other alternate, my client


lodged an e-FIR bearing No.8772/2016, U/s
379 IPC, P.S. Crime Branch, Delhi
thereafter, an untrace report has been
filed by Crime Branch, Delhi Police.

6. That simultaneously, my client has


informed to you noticee also regarding the
theft of your said insured vehicle through
e-mail on 22.03.2016 i.e. within time and
you noticee company had completed all the
formalities including you noticee company
asked my client to deposit both the keys
of his car and other relevant documents
pertaining to the insurance of the vehicle
and the same were duly handed over by my
client for fulfilling the formalities of
the insurance claim procedure.
7. That thereafter, you noticee company has
sent a letter dated 06.07.2016, in which
it has wrongly been stated with the
malafide intention that the car had
already been parked unattended and alleged
for committing the carelessness/ gross.
Said letter is nothing, but an attempt to
evade the claim of the petitioner and to
avoid the legal liabilities of the
company.

8. That it is pertinent to mention here that


my client had been pursuing the matter
with the officials of you the insurance
company and met them on 08.07.2016 at CBO
Office and further met to their divisional
Office on 15.07.2016, thereafter, further
met to the insurance company at
Jhandewalan Extension Office on 25.07.2016
and they all assured that my client would
be getting the insured amount against the
theft of his insured vehicle within some
time.

9. That on 29.07.2016, my client received a


letter from you noticee company, in which
you noticee company has declined the claim
of my client and declared that the claim
of my client is not tenable on the ground
including scrutiny of the paper submitted
by my client in support of your claim and
you have claimed that the vehicle was
parked unattended. Whereas, the fact is
that every vehicle is being parked after
locking the vehicle and my client has
parked the vehicle before the gate of
Govt. institution, where there has already
been a watchman. The second ground you
have taken that in the event of accident
or breakdown the vehicle shall not be left
unattended without proper precautions. It
is submitted that the proper precaution
was taken and the vehicle was duly locked
in front of the Govt. institution.

10. That you noticee raised this issue that


the vehicle shall be entirely at the
insured’s risk, had it been so, nobody is
going to insure your vehicle with any
insurance company. My client further met
with the officials of insurance company on
01.08.2016 and 11.08.2016 regarding their
letter dated 29.07.2016, in which you the
insurance company, have claimed that the
claim of my client is not tenable contrary
to the fact that the officials of the
insurance company had already assured that
my client would be getting the insured
amount within 2 months. My client further
met the officials of you the insurance
company after two months i.e. on
14.11.2016 and enquired about disbursal
/payment of your claim, but you/ your
officials are not paying any heed to the
request of my client deliberately with
malafide intention.

11. That you addressees have given the false


assurances to mislead my client to avoid
yours legally enforceable liabilities
towards my client who has done his part
towards the insurance company.

12. That my client has been forced to run


pillar to post and helter and scatter for
his rightfully insurance claim which was
falsely assured and claimed by your
company to cheat my client despite all
dues have been paid by my client well
within the time.
13. That my client had also taken all the
steps to his obligation after the loss of
his insured vehicle even handed over both
the keys to you.

14. That to scuttle your liability and the


responsibility towards the insurance
claim, you all addressees have been
putting the false, baseless claim upon my
client and making the lame excuses.

15. That since the date of applying for the


insurance claim, you noticee kept on
making false and frivolous assurances to
my client regarding clearing his insurance
claim, but all these were nothing, but
flimsy facts only to pass the time by one
pretext or the other but now finally in
the last month, you noticee have flatly
refused for passing any insurance claim to
my client in any manner.

16. That you noticee are also liable to pay a


sum of Rs.2 Lac towards compensation for
deficiencies in services, mental pain and
agony, harassments and humiliations.
I, therefore, call upon you through
this legal notice to make the payment of
insured amount to my client and also to
pay a sum of Rs.2 Lac towards compensation
for deficiencies in services, mental pain
and agony, harassments and humiliations
within 7 days from the date of receipt of
this legal notice, failing which my client
shall be constrained to initiate
appropriate Civil as well as Criminal
proceeding against you totally on your
costs, risks and consequences.

Copy kept for further references in my


office.

GOPESH TRIPATHI
ADVOCATE
Vijaya Tyagi Resi-Cum-Off: 1020, Janta Flats
ADVOCATE GTB Enclave, Dilshad Garden
Delhi-110095
DELHI HIGH COURT
EN. No. D-1459/2007 M:- 9990698323
Ref. No. DATED: 19.07.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
1. THE SECRETARY
DELHI LEGAL SERVICE AUTHORITY,
EAST DISTRICT, KARKARDOOMA COURTS,
DELHI-110032

2. THE CONCERNED ACCOUNTS OFFICER,


DELHI LEGAL SERVICE AUTHORITY,
EAST DISTRICT, KARKARDOOMA COURTS,
DELHI-110032

3. THE BRANCH MANAGER,


BANK OF BARODA,
BRANCH AT:

MANDOLI, DELHI-110093

Sir,
Under instructions from and on behalf of my
client SMT. UPASANA DEVI, W/O LATE SH. RAHUL
KUMAR, R/O WB-197B, GANESH NAGAR, LAXMI NAGAR,
DELHI-110092, I hereby serve upon you through
this following legal notice, facts as under:-
1. That my client is a peace loving and law
abiding citizen of India and residing at the
above given address and having full faith
over the due process of law.

2. That an accident was occurred with the


husband of my client namely Late Sh. Rahul
Kumar and it was a hit and run case, wherein
neither the offender nor the offending
vehicle in question could be traced out.
Thereafter my client was duly identified by
the IO of the present case. The Secretary
DLSA (East) has inter-acted with my client
and consequently the untrace report filed by
the concerned I.O. in the present matter.

3. That thereafter an order was passed by the


Hon’ble Court of Ms. Ravinder Bedi, Addl.
District & Session Judge, dated 12.05.2016
with the recommendation for granting
compensation to the dependents of the
deceased under section 357-A Cr.P.C.

4. That the deceased husband of my client was


working at CNG Station and was earning
Rs.10,000/- per month. The family of the my
client was fully dependent on the earning of
her deceased husband.
5. That thereafter as per the order of DLSA
dated 16.08.2016, has pleased to grant total
Rs.4,00,000/- (Rupees Four Lacs only) to my
client, her father in law, mother in law,
and minor son namely Master Himanshu i.e.
Rs.1 Lac each.

6. That it is also pertinent to mention here


that it is specifically mentioned in the
aforesaid order of DLSA that “…Accounts
Officer is directed to verify the bank
details of the LR’s of the victim from the
concerned branch of the bank or to get the
same verified from the website of the ban
concerned…”.

7. That for the said purpose, my client has


furnished the details of bank accounts of
herself and her family members including her
minor son namely Master Himanshu viz. Bank
of Baroda, branch at Mandoli, Delhi-110093,
vide his Saving Bank Account No.
06430100072580 i.e. with noticee No.2.

8. That it is also relevant to point out here


that the said order was duly signed and
verified at the end by noticee No.1 being
the Secretary of DLSA (East).

9. That there is a blunder mistake in the


aforesaid order, act and conduct on part of
noticee no.1 and 2, as the bank account
number of the son of my client has been
wrongly mentioned as 06430100072500 instead
of 06430100072500, which belongs to Mohd.
Sulem and due to the said reason, the said
amount of Rs.1 Lac was transferred in the
account of Mohd. Sulem.

10. That not only this, the noticee no.3 has


again done another blunder by releasing the
said deposited amount of Rs.1 Lac in favour
of the said Mohd. Sulem.

11. That due to the aforedsaid reason, my client


has suffered from a great financial loss of
Rs.1 Lacs, because of your above said
negligent acts, and conduct, therefore all
of you are jointly and severally liable to
return the sum of Rs.1 Lac to my client,
which was wrongly transferred to another
account, because of negligent acts and
conduct on part of you noticees.
12. That my client has approached from pillar to
post to solve her grievances, but all went
in vain, because of no hearing on her issue,
hence you noticees are also liable to pay
Rs.1 Lac jointly or severally to my client
for harassments, mental pain and agony.

I, therefore call upon you through this


legal notice, to jointly or severally return
the sum of Rs.1 Lac to my client, which was
wrongly transferred to another account,
because of negligent acts and conduct on
part of you noticees and also to pay Rs.1
Lac jointly or severally to my client for
harassments, mental pain and agony, within
15 days from the receipt of this legal
notice, failing which my client shall be
constrained to initiate appropriate civil as
well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Vijaya Tyagi
Advocate
17. That earlier I have sent a legal notice
dated 29.05.2017 which was posted on the
same day i.e. 29.05.2017 vide Speed Post No.
ED290065921IN on your above given address,
but the same was returned back with the
remarks “item delivery attempted door
locked-intimation served” dated 30.05.2017
by Patparganj S.O. My client has also some
smells that this might be your collusion
with the local postman, but cannot be said
straightway without having any sufficient
proof, hence my client is also in the
proceedings to collect relevant evidences in
this regard. In view of the above and to
avoid any further delay, my client is also
sending the present legal notice /second
Talaq Notice to you noticee through Speed
Post, WhatsApp (on your personal mobile
number) to avoid any non-delivery.
I, therefore call upon you through this
legal notice to accept the present legal
notice and amend/change your behaviour and
further advised you to breakup your illegal
and unlawful relationship with the above
said Mohd. Arif within 30 days, otherwise
after 30 days from the receipt of this legal
notice, the Talaq between you and my client
will be completed and relation between my
client and you come to an end and marriage
between you and my client shall be
dissolved.

You are also liable to pay a sum of


Rs.5,500/- as fee of this legal notice.

Copy kept in my office for further


references and records.

Salim Ahmad Khan


Advocate
S. K. DAYAL Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-2410/1999 M:- 09868552908
Ref: Dated: 18.07.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
To,
1. SMT. RAJ NARUKA,
W/O SH. PUSHKAR SINGH,

2. SH. PUSHKAR SINGH,


BOTH R/o 8A/175, DDA FLATS, TRILOKPURI,
DELHI-110091

Sir,
Under the instructions from and on behalf of
my client SH SANJAY S/O SH. SUNDAR LAL, R/O
8A/107, DDA FLATS, TRILOKPURI, DELHI-110091, I
hereby serve upon you through this legal notice,
facts as under:-

1. That my client is dealing in the business of


real estate. In the year 2002 your husband
Sh.Pushkar Singh i.e. addressee no.2 become
the friend of my client and such relations
were converted into close family relations.
On 11.08.2010, my client purchased a car
vide Regn. No.DL7C-K-5870, make Chevrolet
Sparx (hereinafter mentioned as the ‘Car’),
then both of addressee no.2 asked to use the
Car and my client after considering the
relation with both of you, handed over the
car to both of you for your personal use on
the date of purchase/delivery itself.

2. In the year 2012, my client helped both of


you addressees for joining and opening the
business of Real Estate. In the year 2015,
some misunderstanding was developed between
both of you and my client with respect to
the alleged brother Govind of addressee No.1
and in the month of May, 2015, the close
family relations were put in end.

3. On 28.06.2017, my client demanded the car


from both of you and occupation and using
charges for a sum of Rs.5,000/- per month
which was agreed between both of you and my
client on oral basis, but both of you
refused the same and extended threats to
implicate my client in false criminal case.

4. On 29.06.2017, you addressee no.1 alongwith


10-12 ladies have reached the office of my
client and made quarrel and levelled false
allegations upon my client. Thereafter you
addressee no.1 made a 100 number PCR call
and after the preliminary enquiry conducted
on 29.06.2017, 30.06.2017 and 02.07.2017 by
the concerned police officials of P.s
Kalyanpuri, Delhi, the complaint of
addressee no.1 found fake.

5. That my client is in apprehension that both


of you will misuse the car and for the same,
my client made a written complaint to SHO,
P.s Kalyanpuri, Delhi on 07.07.2017.

6. That my client is entitled to recover the


car from both of you, as my client is the
registered owner of the car and he was
handed over the said car to both of you for
your personal use and you are also liable
for any challan, criminal case etc. during
the period from which the car is in your
possession till its handing over to my
client.
7. That you both the addresses are also liable
to pay the damages/ use and occupation
charges of the said car to my client to the
tune of Rs.5,000/- per month w.e.f.
11.08.2010 till handing over the possession
of the same to my client.

I, therefore call upon you through this


legal notice to handover the possession of
the Car to my client within 7 days from the
receipt of this legal notice and also to pay
the damages/ use and occupation charges of
the said car to my client to the tune of
Rs.5,000/- per month w.e.f. 11.08.2010 till
handing over the possession of the same to
my client, failing which my client shall be
constrained to initiate appropriate civil as
well as criminal proceeding against you
totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

S.K. Dayal
Advocate
Raman Sharma Chamber No.
Advocate Floor,
Delhi High Court Karkardooma Courts,
Delhi-110032.
M:-
Ref: Date:

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH PARAMJEET SINGH

Sir,
Under instructions from and on behalf of my

client SH RAHUL KASANA, S/o SH ____________, R/o

________________________, I hereby serve upon

you through this following legal notice, facts

as under:-

8. That my client is a peace loving and law

abiding citizen of India and is residing

at the above stated address and having

full faith over the due process of law.

9. That you noticee came in contact with my

client through some common friend and by

passing the time, you noticee has


established good friendly relations and

faith over my client.

10. That you noticee in the month of February,

2017, approached my client at his address

and requested to arrange a sum of

Rs.2,00,000/- (Rupees Two Lacs only) as a

friendly loan, as you noticee disclosed

that you were in dire need of money for

your urgent need and consequently in the

mid of February-2017, my client handed

over Rs.2,00,000/- (Rupees Two Lacs only)

in cash to you noticee in the presence of

marginal witnesses Sh. Vishesh Verma, S/o

Sh.__________, from his personal savings

and after collecting some amount from one

of his friend namely Sh. Vishesh Verma,

S/o Sh.__________ and at the time of

borrowing the aforesaid amount you noticee

assured my client that you will return the


abovesaid amount within 2-3 months

positively.

11. That in the first week of May-2017, my

client approached to you noticee and

demanded his aforesaid loan amount of

Rs.2,00,000/- (Rupees Two Lacs only) from

you, then you noticee showed your

inability in returning the said amount and

sought some more time and for the sake of

old relations, my client agreed for the

same.

12. That again in the mid of June, 2017, my

client approached to you noticee and

demanded the above amount of Rs.2,00,000/-

(Rupees Two Lacs only), then you noticee

in discharge of your above said liability,

you noticee issued two cheques bearing

No.342315 dated 22.06.2017 of Rs.50,000/-

and Cheque No.342316 of dated 23.06.2017


for Rs.1,50,000/- both drawn on Punjab

National Bank, Branch at: Maharal,

Hamirpur, H.P and at the time of issuing

the said cheques, you noticee assured to

my client that the said cheque would be

honoured positively on its presentation.

13. That thereafter, as per your above said

assurance and as per your instructions, my

client had presented the said both cheques

for its dishonour with his banker i.e. UCO

Bank, Branch at: Karkardooma Courts,

Delhi, but to the utter shock and surprise

for my client when the said both cheques

were dishonoured with the remarks “DRAWERS

SIGNATURE DIFFERS” and “DRAWERS SIGNATURE

NOT AS PER MANDATE” respectively and my

client had received the both returning

memos of dated 27.06.2017 and 03.07.2017

respectively
14. That thereafter, my client contacted you

noticee to apprise about the dishonour of

the abovesaid cheques and demanded the

abovesaid friendly loan amount of Rs.

Rs.2,00,000/- (Rupees Two Lacs only) in

cash, but you noticee showed your

inability and did not pay any heed to pay

back the abovesaid amount to my client and

since then you noticee kept passed the

time by one pretext or the other and now

you noticee instead of making the payment

of the abovesaid cheques, flatly refused

to make the aforesaid payment to my client

in any manner.

15. That in discharge of his legally

enforceable liability, you noticee issued,

signed and delivered the above said

cheques which were dishonoured by the

banker of you noticee, as you noticee

intentionally and deliberately made


different signatures on the said cheques

with the sole motive to cause wrongful

loss to my client and wrongful gain to

yourself and thus you noticee breached the

trust of my client and committed an

offence punishable under section 138 of

N.I. Act as well as 406/420 of the Indian

Penal Code.

16. That it is also relevant to point out here

that in addition to the proceedings U/s

138 of Negotiable Instruments Act, 1881

and recovery under the Civil Procedure

Code, 1908, my client further reserves his

right to initiate separate criminal

proceedings against you noticee for

cheating, misappropriation of funds and

criminal breach of trust, which is liable

to be prosecuted under the Code of

Criminal Procedure, 1973, hence this

notice.
I, therefore call upon you through this

legal notice to return the amount of above

said dishonoured cheques i.e. total

Rs.2,00,000/- (Rupees Two Lacs only) to my

client within 15 days from the receipt of

this legal notice, failing which my client

shall be constrained to initiate appropriate

civil as well as criminal proceeding against

you totally on your costs, risks and

consequences.

You are also liable to pay Rs.5500/- as

fee of this legal notice.

Copy kept in my office for further

references.

Raman Sharma
Advocate
Nazma Sultan Chamber No.F-412,
Advocate Fourth Floor,
Delhi High Court Karkardooma Courts,
Delhi-110032.
M:- 9818217943
Ref: Date: 16.09.2015

LEGAL NOTICE
REGD. A.D./SPEED POST
To,
THE GENERAL MANAGER,
BSES YAMUNA POWER LTD.
AT: SHAKTI KIRAN BUILDING,
NEAR KARKARDOOMA COURTS,
SHAHDARA, DELHI

Sir,
Under the instructions from and on behalf of
my client SH. RAVINDER, S/O LATE MITTHAN LAL,
R/O 244-A-42, VILLAGE GHONDLI, DELHI-110051, I
hereby serve upon you through this legal notice,
facts as under:-

1. That my client is residing at property


bearing No. 244-A-42, Village Ghondli,
Delhi-110051.

2. That the deceased wife of my client namely


Smt. Sushma was the registered consumer of
you noticee and had been allotted an
domestic category electricity connection
vide CA NO: 100911302.

3. That my client is regularly paying the


electricity bill and never defaulter in
making the payment of the electricity bills
to you noticee.
4. That it is relevant to point out here that
the BSES has never issued any regular bill
to my client towards actual consumption and
when my client approached to the BSES, they
used to give a lump sum bill of huge amount
to my client and pressurizes my client for
settlement.

5. That previously the BSES had issued a bill


of Rs.2,03,040/- on 23.12.2016 and
thereafter on 16.12.2016, my client paid
Rs.70,000/- towards the full and final
settlement to BSES.

6. That thereafter also the BSES had not


issued any regular bill to my client and
again made false pretexts.

7. That again on 22.05.2017, my client


received a lump sum bill of Rs.1,45,000/-
from BSES, while it is mentioned on the
said bill the last payment of Rs.70,000/-
is accounted upto 30.04.2017 which clearly
show that the BSES is sending false and
frivolous bills to my client only to extort
more money from him. Some of the agents of
BSES are indulged in this scam.

8. That official of you noticee are now


threatening to disconnect the electricity
supply of the premises of my client with
malafide intention and ulterior motives to
harass and humiliate my client and to build
pressure upon my client while is illegal
and unlawful.

I, therefore call upon you through this


legal notice to rectify the defected bills and
to issue fresh and correct bill to my client as
per the actual consumption, within 15 days from
the receipt of this legal notice, failing which
my client shall be constraint to initiate
appropriate criminal as well as civil
proceeding against you totally on your costs,
risks and consequences.

You are also liable to pay Rs.11,000/- as


fee of this legal notice.

Copy kept in my office for further


references.

NAZMA SULTAN
ADVOCATE
S. K. DAYAL Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-2410/1999 M:- 09868552908
Ref: Dated: 30.06.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
To,
SH MAHENDRA KUMAR SHARMA
S/o LATE SH HARSHARAN SHARMA
R/o H.No.188, RAJPURA GUD MANDI,
DELHI-110007

Sir,
Under the instructions from and on behalf of
my client SH C.L. SHARMA, S/o LATE SH P.C.
SHARMA, R/o B-12/279D, BRIJPURI, DELHI-110094, I
hereby serve upon you through this legal notice,
facts as under:-

1. That you noticee and my client are friends


for a long time and in the first week of
November 2015, you approached to my client
for a friendly loan for a sum of
Rs.1,25,000/- and my client assured to pay
the same within a week, thereafter, in the
third week of November 2015, my client
paid a sum of Rs.1,25,000/- to you noticee
in cash after arranging the same from his
friends/relatives and you noticee assured
to return the same on or before July 2016.

2. That on 22.07.2016, when my client


demanded the aforesaid friendly loan
amount of Rs.1,25,000/- from you, then you
in discharge of your liability issued
cheque bearing No.556459, dated 22.07.2016
amounting to Rs.1,25,000/- drawn on Punjab
National Bank, Rana Pratap Bagh, Delhi-
110007 and you requested my client to not
present the same for two months.

3. That in the month of September 2016 you


further asked not to present the aforesaid
cheque for its encashment, and thereafter,
you always seeks time by one pretext or
other for not presenting the said cheque.

4. That finally on 11.06.2017, when my client


visited at your residence and demanded the
aforesaid friendly loan amount from you
and you flatly refused to pay the same and
extended threats to face dire
consequences.

5. That you are liable to pay the aforesaid


friendly loan amount for a sum of
Rs.1,25,000/- to my client and my client
is also entitle to recover the aforesaid
loan amount from you before competent
Court of law.

I, therefore call upon of you noticee


through this legal notice to make the
payment of the aforesaid amount of
Rs.1,25,000/- (Rupees One Lac Twenty Five
Thousand only) to my client within 30 days
from the receipt of this legal notice,
failing which my client shall be
constrained to initiate appropriate Civil
as well as Criminal proceedings against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.
S.K. DAYAL
ADVOCATE
S. K. DAYAL Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-2410/1999 M:- 09868552908
Ref: Dated: 30.06.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
To,
SMT RANJEET KAUR
W/o SH SARVJEET SINGH,
R/o H.No.C-1, KOTLA FEROJ SHAH,
VIKRAM NAGAR, NEW DELHI-110002

Sir,
Under the instructions from and on behalf of
my client SH SURENDER SHARMA, S/o SH HARI SINGH,
R/o D-8/154, BRIJPURI, DELHI-110094, I hereby
serve upon you through this legal notice, facts
as under:-

1. That my client and you noticee are having


friendly relations and visiting terms
through your husband from last 5 years and
having faith upon each other.

2. That in the month of July 2016 you alongwith


your husband approached to my client and
requested for a sum of Rs.16,00,000/- (rupes
Sixteen Lac) as a friendly loan for the
purpose of purchasing a flat as you are in
urgent need of the same. My client after
considering the relation with you and agreed
to pay the same.

3. That thereafter, considering friendly


relations with you noticee, my client sought
time of one month for arranging the said
amount, thereafter, in the month of August
2016, my client paid a sum of Rs.16,00,000/-
(Rupees Sixteen Lac only) to you noticee
after arranging the same from his elder
brother Babu Ram Sharma and from his own
sources. At the time of receiving the
aforesaid amount you had assured to my
client that the abovesaid amount will be
returned by you on or before March 2017 and
in the event of not returning the aforesaid
amount she will sell out the flat in
question to my client.

4. That on 15.03.2017, my client approached to


you noticee and demanded the abovesaid loan
amount of Rs.16,00,00/-, then in discharge
of your liability you noticee issued a
cheque bearing No.598520, dated 15.03.2017
amount to Rs.16,00,000/- drawn on Central
Bank of India, Branch at Press Area, New
Delhi in favour of my client and assured him
that the said cheque would be encashed at
the time of its presentation.

5. That as per your assurances, my client had


presented the aforesaid cheque amounting
with his banker i.e. Bank of Baroda, Yamuna
Vihar, Delhi, but the said cheque was
dishonored by your banker with the remarks
“ACCOUNT CLOSED” vide returning memo dated
06.06.2017.

6. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have closed your account
intentionally and deliberately and thus you
breached the trust of my client and
committed an offence punishable under
section 138 of N.I. Act R/w Section 406/420
of Indian Penal code.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.16,00,000/-
(Rupees Sixteen Lac only) to my client
within 15 days from the receipt of this
legal notice, failing which my client shall
be constraint to initiate appropriate
criminal as well as civil proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.

S.K. DAYAL
ADVOCATE
S. K. DAYAL Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-2410/1999 M:- 09868552908
Ref: Dated: 30.06.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
To,
MOHD. RAHIS ANSARI @ MOHD. RAHIS
S/o MOHD. SADDIK ANSARI
R/O GALI NO.24, A-BLOCK,
SHRI RAM COLONY, RAJEEV VIHAR,
POST OFFICE KARAWAL NAGAR,
DELHI-110094

Sir,
Under the instructions from and on behalf of
my client SH CHAMAN LAL SHARMA, S/o LATE SH P.C.
SHARMA, R/o B-12/279D, BRIJPURI, DELHI-110094, I
hereby serve upon you through this legal notice,
facts as under:-

1. That you noticee and my client are friends


for a long time and in the first week of
June 2016, you approached to my client for
a friendly loan for a sum of Rs.6,00,000/-
and my client assured to pay the same
within a week, thereafter, in the third
week of June 2015, my client paid a sum of
Rs.6,00,000/- to you noticee in cash after
arranging the same from his
friends/relatives and you noticee assured
to return the same on or before May 2017.

2. That on 08.05.2017, when my client


demanded the aforesaid friendly loan
amount of Rs.6,00,000/- from you, then you
in discharge of your liability issued two
cheques bearing No.068299 & 068300 both
dated 08.05.2017 amounting to Rs.3 Lac
each drawn on Bank of Maharashtra, Yamuna
Vihar, Delhi-110053 and you requested my
client not to present the same for one
month.

3. That on 11.06.2017, when my client visited


at your residence and demanded the
aforesaid friendly loan amount from you
and you flatly refused to pay the same and
extended threats to face dire
consequences.

4. That you are liable to pay the aforesaid


friendly loan amount for a sum of
Rs.6,00,000/- to my client and my client
is also entitle to recover the aforesaid
loan amount from you before competent
Court of law.

5. That on 17.06.2017, as per your


assurances, my client had presented the
aforesaid cheque amounting with his banker
i.e. Post Office Saving Bank Account, at
I.P. Head Post Office, New Delhi-02, but
the said cheque was dishonored by your
banker with the remarks “REFER TO DRAWER”
vide returning memo dated 21.06.2017.

6. That for discharging your liability, you


issued, signed and delivered the above
said cheque, which was dishonored by your
banker, and thus you breached the trust of
my client and committed an offence
punishable under section 138 of N.I. Act
R/w Section 406/420 of Indian Penal code.

I, therefore call upon of you noticee


through this legal notice to make the
payment of the aforesaid amount of
Rs.6,00,000/- (Rupees Six Lac only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate
appropriate Civil as well as Criminal
proceedings against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.

S.K. DAYAL
ADVOCATE
S. K. DAYAL Chamber No.F-621, Block-F,
Advocate 6th Floor, Lawyers
Chambers, Kakardooma
DELHI HIGH COURT Courts Complex, Delhi-32
ENR No.D-2410/1999 M:- 09868552908
Ref: Dated: 30.06.2017

REGD. A.D./SPEED POST


STATUTORY NOTICE U/S 80 OF CPC, 1908
To,
Northern Railway
Through its General Manager,
Head Office at:
Baroda House, New Delhi-110001

Sir,
Under the instructions from and on behalf of
my client (1) Sh. C.L. Sharma, S/O Late Sh. P.C.
Sharma, (2) Smt. Munni Sharma, W/O Sh. C.L.
Sharma, (3) Sh. Sachin Sharma, S/o Sh. C.L.
Sharma, (4) Sh. Sandeep Sharmna, S/o Sh. C.L.
Sharma, all R/o b-12/279-D, Brij Puri, Delhi-
110094, I hereby serve upon you with the
following legal notice:
14. That you notice is well known railways
services in India popularly known as
“Northern Railways”, which is one of the 17
Railway zones of India and the northernmost
zone of the Indian Railways, its headquarter
is New Delhi Baroda House near India Gate.
And being a reputed organization, it is the
statutory duty case upon you to provide best
services to your consumers/passengers
without any negligent.

15. That on 11.03.2017 my clients had booked


four tickets of Train No.02171 namely CST
Jammu Tavi AC Spl. for the journey from
Nasik Road to New Delhi on 05.05.2017 vide
PNR No.841-2974850 and the said tickets were
confirmed in B-10 Coach at Seat 33 to 36. On
that day i.e. 05.05.2017, my clients were
reached Nasik Road Railway station and
according to your journey cum reservation
ticket, the schedule of departure of the
train was 10:25 AM, however, the said train
was departed on 17:50 hours (5:50 PM)
delayed by 7 hours and 25 minutes
approximately. My clients have no option
except to wait for the train to be departed
for the delay time from the aforesaid train,
as there was no prior intimation to my
clients regarding the said delay.

16. That on 06.05.2017, as per the aforesaid


journey cum railway ticket, the arrival time
of the said train was 07:30 AM, but the said
train was reached at New Delhi station at
17:00 hrs (5:00 PM), delayed by 9 hours and
30 minutes approximately.

17. That it is relevant to note here that one of


the most important reason for this journey
by my client was that, my client Sandeep
Sharma had to appear in Online Preliminary
Examinations for the recruitment of
Probationary Officers and the venue of the
said examination was at Laxmi Hitech
Solution, Plot No.29, Sector-31, New DLF
Industrial Area, Near IP Colony, Gate No.1,
Mewla Maharajpur Metro Station, Faridabad-
121 002 and the date of examination was
06.05.2017 at 10:30 AM, but due to delay on
your part, my aforesaid client couldn’t
attend his aforesaid examination. It is also
relevant to note here that it was the last
attempt for my aforesaid client to appear in
the aforesaid examination, because of his
age factor and he couldn’t do so, because
the sole negligent on part of you noticee.

18. That the career of my aforesaid client


namely Sandeep Sharma have been spoiled due
to the aforesaid delay in departure and
arrival of the train, which cannot be
compensate in any manner.

19. That my client C.L. Sharma is a Government


Employee and presently posted in Postal
Department at New Delhi and due to the
delay, he was remained absent from his
services and in this regard a memo was
issued to him by the concerned department,
just because of the delay of departure and
arrival of the aforesaid train. My client
Smt. Munni Sharma is old aged ailing
patient, and she is unable to reach the
hospital concerned for her treatment just
because of the aforesaid negligence on your
part.

20. That my client Sandeep Sharma because of the


aforesaid incident, has now came under great
mental tension and agony, because he has
lost all of his hopes for a bright future.
21. That the aforesaid loss which has been
caused to my clients cannot be compensated
in any manner, though, a sum of Rs.10 Lacs
as damages in whole, can make some meagre
relief for them.
I, therefore call upon you through this
legal notice to pay a sum of Rs.10 Lacs to
my clients as damages, within 60 days from
the receipt of this legal notice, failing
which my clients shall be constrained to
initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

S.K. Dayal
Advocate
Yogendra Kumar Office at: G-612, 6th Floor,
ADVOCATE G-Block, Karkardooma
Courts
DELHI HIGH COURT Complex Delhi-110032
EN. No. D-408-E/03 M: 09312498900
================================================================================
Ref: Date: 30.06.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH SANDEEP
S/O SH CHARAN SINGH,
R/O E-3/38A, GALI NO.3,
E-BLOCK, DAYALPUR, DELHI-110094

2. SMT. SHASHI,
W/O SH. SANDEEP,
D/O SH. BHAGWAN DASS,
R/O E-3/38A, GALI NO.3,
E-BLOCK, DAYALPUR, DELHI-110094

ALSO AT:
D-79, SLS VED VIHAR,
DLF LONI, NEAR PANI KI TANKI,
DISTT. GHAZIABAD, U.P

Sir/Madam,
Under instructions from and on behalf of my
client namely SMT. CHANDRA DEVI, W/O LATE SH.
CHARAN SINGH, R/O E-3/38A, GALI NO.3, E-BLOCK,
DAYALPUR, DELHI-110094, I hereby serve upon you
through this following legal notice, facts as
under:-

20. That you noticee No.1 are the real son of


my client and you noticee No.2 are the
daughter-in-law of my client, being wife
of noticee No.1.
21. That you both the noticees are regularly
harassing and humiliating my client by
your illegal, and uncooperative acts and
activities and being real son and
daughter-in-law, you noticees are not
caring and helping my client and want to
capture the property of my client within
the collusion and by hatching the
conspiracy with the family members of the
noticee No.2.
22. That very often since beginning, you
noticee No.1 and 2 used to quarrel with my
client on minor issues or the others. And
you noticee No.1 and 2 have threatened my
client that you will implicate my client
and his family members in any false
criminal case and since then my client
always remained in great tension.
23. That my client is the owner of the
property bearing No.E-3/38A, GALI NO.3,
E-BLOCK, DAYALPUR, DELHI-110094, measuring
25 sq. yards, and the said property is the
self-acquired by my client and her husband
from their own funds, sources and earnings
and status of you both noticees in the
said property were/are only as a licencee.
24. That my client also made a written
complaint to the SHO, P.s Khajuri Khas,
Delhi vide D.D. No.74-B dated 09.02.2017
against you both the noticees for your
illegal and unwarranted acts and
activities.
25. That you both noticees No.1 & 2 due to
dishonest intention humiliating and
torturing to my client by one pretext and
another at every moment, due to all these
circumstances and seeing the behaviour of
you noticee No.1 & 2, my client have
debarred you both noticees No.1 & 2 by way
of publication of public notice in daily
Newspaper Rashtriya Sahara dated
03.06.2017. The copy of said publication
is enclosed herewith.
26. That after publishing the said debarred
notice, my client have broken all the ties
and relations with you addressee No.1 & 2
and hence you noticee No.1 & 2 have no
right to stay in the above said property
of my client any more in any manner.
27. That my client do not wish to permit you
addressees No.1 & 2 to live in the said
property No. E-3/38A, GALI NO.3, E-BLOCK,
DAYALPUR, DELHI-110094 in respect of
portion which is in your possession i.e.
Ground Floor. You are further required to
be noted that my client have terminated
your living capacity/locus standi in said
premises, therefore you noticee No.1 and 2
have no right to stay in the property of
my client and both of you are liable to
pay occupational charges @ Rs.10,000/- per
month w.e.f. 01.08.2017 and now you are
living in the said property as
unauthorized occupants.
28. That it is relevant to mention here that
when you noticees came to know that my
client have debarred both of you noticees
from their all moveable and immoveable
properties, then you both noticees have
abused my client in filthy and abusive
language and threatened my client to
implicate them in some false criminal
cases and due to the said reason, my
client are under great terror and fear
from you noticees.
29. That despite knowledge and information
regarding debar publication and several
oral requests for vacating of the portion
of the above said property in your
possession, you both did not pay any heed
and also not bothered to vacate the
portion in your possession till date,
hence this notice.
I, therefore call upon you through this
legal notice that you noticee No.1 and 2 to
vacate the premises of my client i.e. E-
3/38A, GALI NO.3, E-BLOCK, DAYALPUR, DELHI-
110094 in respect of first floor’s portion
which is in your possession, within 15 days
from the date of receipt of this legal
notice, failing which my client instructed
me to initiate appropriate legal action
against you noticee No.1 and 2 totally on
your costs, risks and consequences and you
noticee No.1 and 2 will be liable to pay all
the expenses of litigations to my client.

You are also liable to pay the use and


occupation charges @ Rs.10,000/- per month
to my client in respect of the said premises
w.e.f. 01.08.2017 till the vacation of the
same.

You noticees are liable to pay Rs.5500/-


towards the cost of present legal notice.

Copy kept for further references in my


office.

Yogendra Kumar
Advocate
Arvind Kumar Bansal Chamber No.G-401, Block-G,
Advocate 4th Floor,Lawyers Chambers
Kakardooma Courts
DELHI HIGH COURT Complex, Delhi-32
Email: baisla_12@yahoo.in M:- 9015803232, 9582105501
Ref: Dated: 28.06.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
Sh. Deepak Singh Bhadouriya,
Prop. Of M/s Bala Ji Jewellers,
At: 3rd Pusta, Main Market, Sonia Vihar,
Near Post Office, Delhi-110094

Also at:
Deepak Singh Bhadouriya,
Village Bhadorian Ka Pura,
Post Vah, Distt. Agra, U.P.

Sir,
Under the instructions from and on behalf of my
client Sh. Rajkumar Singh Bhadoriya, S/o Sh. Surender
Singh, R/o B-94B, Udai Vihar (Chandra Vihar), Nilothi
Extn., Nangloi, Delhi-110041, I hereby serve upon you
with the following legal notice:

1. That you the addressee is well known to my client


as you are in relation of my client.

2. That you the addressee approached my client at


his aforementioned address in the first week of
January 2017 and requested him to advance you a
loan of Rs.2,00,000/- (Rupees Two Lacs only) for
a period of three months as at that time you
shown your financial crises.

3. That considering your financial problem and


keeping in mind the good relations with you the
addressee, my client agreed to advance you a sum
of Rs.2,00,000/- (Rupees Two Lacs only) as
interest free loan and after arranging the same
from his source, my l.client gave a sum of
Rs.2,00,000/- (Rupees Two Lacs only) to you in
cash on 09.01.2017 the same was borrowed by you
from my client for three months and at the time
of borrowing the said amount you assured my
client that entire borrowed amount of
Rs.2,00,000/- (Rupees Two Lacs only) shall be
returned by you to my client till 20.04.2017.

4. That on 20.04.2017 my client approached you and


demanded you to make the payment of Rs.2,00,000/-
(Rupees Two Lacs only) to my client but at that
time you failed to make the payment of said
amount in cash, but when my client raised
objection then you in discharging your admitted
liability in respect of payment of aforesaid loan
amount of Rs.2,00,000/- (Rupees Two Lacs only)
issued and handed over two cheques to my client,
out of which one cheque bearing NO.255900 of
dated 27.05.2017 for Rs.70,000/-, drawn on Canara
Bank, Branch at: Kashmere Gate, Delhi-110 006 and
also issued one cheque of Rs.76,000/- separately
(which has already been dishonoured and separate
proceedings are already initiated for the same),
the said cheques were issued by you in the name
of my client and at the time of issuance of said
cheque, you addressee assured my client that the
said cheque would honoured positively on its
presentation and also assured that remaining
amount of Rs.54,000/- shall be paid by you to my
client very soon.

5. That as per assurance given by you to my client,


my client presented the aforesaid cheque of
Rs.70,000/- in his banker i.e. IndusInd Bank Ltd.
Vikaspuri, Branch at Delhi but the same was
returned unpaid with the remarks “FUNDS
INSUFFICIENT” vide returning memo dated
30.05.2017.

6. That after dishonour of the aforesaid cheque, my


client became very much shocked and immediately
contacted you the addressee and requested you to
return the cheque amount in cash alongwith
remaining balance amount, but you the addressee
flatly refused to return the same and threatened
to my client that if he demanded his money again,
he will face dire consequences in future.

7. That you in discharge of your liabilities, in


respect of part payment of Rs.70,000/- issued the
above said cheque of Rs.70,000/- which was
dishonoured by your banker with the remarks
“FUNDS INSUFFICIENT”, while you intentionally and
deliberately issued the said cheque and did not
keep sufficient funds in your bank with an
ulterior motives to grab the cheque amount and
you the addressee cheated and deceived my client
and thus you committed an offence an offence
which is punishable under provision of section
138 of N.I. Act.

I, therefore call upon you through this legal


notice to make the payment of cheque amount of
Rs.70,000/- (Rupees Seventy Thousand only) to my
client within 15 days from the date of receipt of
this legal notice failing which my client shall
be constrained to initiate legal action against
you under appropriate provision of law, which
will be totally on your risks costs and
consequences, please note carefully.

You are also liable to pay a sum of Rs.5500/-


fee of this legal notice.

Copy kept in my office for further


references.

Arvind Kumar Bansal


Advocate
VISHWAS AHUJA CHAMBER No.D-619,
ADVOCATE D-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
Ref. No. DATED:

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH HIMANSHU,
PROP. OF M/S OM ENTERPRISES,
AT: X/271, GALI NO.9,
MAIN ROAD, RAM NAGAR,
GANDHI NAGAR, DELHI-110031

Sir,
Under the instructions from and on behalf of
my client M/S S.R. TRADING CO. THROUGH ITS PROP.
SH. AMIT KUMAR JAIN, AT: 9/1244, JURAB MANDI,
SUBHASH ROAD, GANDHI NAGAR, DELHI-110031, I
hereby serve upon you with the following legal
notice:

1. That my client is dealing in the business of


selling and supplying of various types of
fabrics and doing its business in the name
and style of M/s S.R. Trading & Co. and
having its office at: 9/1244, JURAB MANDI,
SUBHASH ROAD, GANDHI NAGAR, DELHI-110031.

2. That you noticee usually used to purchase


the fabrics from my client from time to time
and you noticee used to make the payment
accordingly as per the convenience and
mutual agreement between you noticee and my
client.

3. That consequently in the month January-2017,


you noticee purchased the fabric (L.T. Denim
Fresh and Denim) from my client against
Invoice No.49, dated 05.01.2017 for
Rs.50,000/- and another Invoice No.51, dated
11.01.2017 for Rs.50,000/- and the same were
duly received by you noticee.

4. That in discharge of his above said


liability, you noticee issued, signed and
delivered two post-dated cheques bearing No.
010838 of Rs.50,000/- of dated 26.01.2017
and cheque No.010837 of dated 30.01.2017 of
Rs.50,000/-, both drawn on Axis Bank Ltd.,
branch at Geeta Colony, Delhi (hereinafter
referred as the “Cheques in question” for
the ease of references) and at the time of
issuing the aforesaid cheques, you noticee
assured my client that the said cheques
would be honoured positively at the time of
its presentation.

5. That thereafter, as per the instructions of


you noticee, my client presented the said
both cheques in question with his banker
i.e. Punjab National Bank, Branch at Krishna
Nagar, Delhi, but the said cheques got
dishonoured by the banker of you noticee
with remarks “FUNDS INSUFFICIENT” vide
returning memos dated 28.03.2017
respectively.

6. That after dishonour of the above said


cheques in question, my client conveyed you
noticee about the dishonor of the cheques
and demanded his above said amount of Rs.1
Lac in cash, upon which you noticee
requested my client to present the said
cheques in question again with his banker
and assured that this time, the same will be
encashed definitely.

7. That thereafter, as per the instructions of


you noticee, my client had lastly/second
time presented the said both cheques in
question in question with his banker i.e.
Punjab National Bank, Branch at Krishna
Nagar, Delhi, but to the utter shock and
surprise for my client, as the said cheques
in question again got dishonoured with
remarks “FUNDS INSUFFICIENT” and my client
received the information through returning
memos dated 28.04.2017.

8. That thereafter, my client approached you


noticee to apprise you noticee about the
dishonour of the abovesaid cheques in
question, but you noticee showed his
inability and did not pay any heed to pay
back the abovesaid amount to my client and
since then you noticee kept passed the time
by one pretext or the other and now you
noticee instead of making the payment of the
abovesaid cheques in question, flatly
refused to make the aforesaid payment to my
client in any manner.

9. That you noticee issued, signed and


delivered the above said cheques in question
to discharge his liability and you noticee
has intentionally and deliberately couldn’t
arrange the sufficient amount and got
dishonoured the said cheques in question.

I, therefore call upon you through this


legal notice to make the payment of the
above said dishonoured cheques i.e. total
Rs.1,00,000/- (Rupees One Lac only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.11000.00


as fee of this legal notice.

Copy kept in my office for further


references.

Vishwas Ahuja
Advocate
VISHWAS AHUJA CHAMBER No.D-619,
ADVOCATE D-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
Ref. No. DATED:

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH VIPIN KUMAR @ VIPIN KUMAR AGGARWAL,
AT: X/271, GALI NO.9,
MAIN ROAD, RAM NAGAR,
GANDHI NAGAR, DELHI-110031

Sir,
Under instructions from and on behalf of my
client M/S S.R. TRADING CO. THROUGH ITS PROP.
SH. AMIT KUMAR JAIN, AT: 9/1244, JURAB MANDI,
SUBHASH ROAD, GANDHI NAGAR, DELHI-110031, I
hereby serve upon you through this following
legal notice, facts as under:-

17. That my client is dealing in the business

of selling and supplying of various types

of fabrics and doing its business in the

name and style of M/s S.R. Trading & Co.

and having its office at: 9/1244, JURAB


MANDI, SUBHASH ROAD, GANDHI NAGAR, DELHI-

110031.

18. That you notice usually used to purchase

the fabrics from my client from time to

time and you used to make the payment

accordingly as per the convenience and

mutual agreement between you noticee and

my client.

19. That consequently in the month February-

2017, you noticee purchased the fabric

(Bansal Denim & Denim respectively) from

my client against Invoice No.54, dated

06.02.2017 for Rs.50,000/- and another

Invoice No.63, dated 27.02.2017 for

Rs.50,000/- and the same were duly

received by you.

20. That in discharge of your above said

liability, you noticee issued, signed and

delivered two post-dated cheques bearing


No. 008498 of Rs.50,000/- of dated

16.04.2017 and cheque No.008501 of dated

22.04.2017 of Rs.50,000/-, both drawn on

ICICI Bank Ltd., branch at Parliament

Street, New Delhi-110001 and at the time

of issuing the aforesaid cheques, you

noticee assured my client that the said

cheques would be honoured positively at

the time of its presentation.

21. That thereafter, as per your instructions,

my client presented one of the said cheque

bearing No.008498 with his banker i.e.

Punjab National Bank, Branch at Krishna

Nagar, Delhi, but the said cheque got

dishonoured on two occasions with remarks

“FUNDS INSUFFICIENT” vide its returning

memos dated 21.04.2017 and 28.04.2017

respectively.
22. That after dishonour of the above said

cheque on two occasions, my client

conveyed you noticee about the dishonor of

the cheque and demanded his above said

amount in cash, upon which you noticee

requested my client to present the said

cheque again with his banker and assured

that this time, the same will be encashed

definitely.

23. That thereafter, as per your instructions,

my client had lastly presented the said

cheque bearing No.008498 with his banker

i.e. Punjab National Bank, Branch at

Krishna Nagar, Delhi, but to the utter

shock and surprise for my client, as the

said cheque again got dishonoured with

remarks “FUNDS INSUFFICIENT” and my client

received the information through returning

memo dated 17.05.2017.


24. That thereafter, my client also presented

the another cheque bearing No.008501 with

his banker i.e. Punjab National Bank,

Branch at Krishna Nagar, Delhi for its

encashment, but the said cheque also got

dishonoured with remarks “FUNDS

INSUFFICIENT” and my client received the

information through returning memo dated

23.05.2017.

25. That thereafter, my client approached you

noticee to apprise you about the dishonour

of the abovesaid cheques, but you noticee

showed your inability and did not pay any

heed to pay back the abovesaid amount to

my client and since then you noticee kept

passed the time by one pretext or the

other and now you noticee instead of

making the payment of the abovesaid

cheques, flatly refused to make the


aforesaid payment to my client in any

manner.

26. That in discharge of your legally

enforceable liability, you noticee issued,

signed and delivered the above said two

cheques which were dishonoured by the

banker of you noticee, as you noticee has

not arranged the sufficient amount in your

banker/ account and thus you noticee

breached the trust of my client and

committed an offence punishable under

section 138 of N.I. Act.

I, therefore call upon you through this


legal notice to make the payment of the
above said dishonoured cheques i.e. total
Rs.1,00,000/- (Rupees One Lac only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.
Copy kept in my office for further
references.

Vishwas Ahuja
Advocate

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
Ms. Shivani,
R/O H.No.184, Street No.6,
Jwala Nagar, Shahdara,
Delhi-110032

Sir,
Under the instructions from and on behalf of

my client M/s Vendor Plus Consultants Pvt. Ltd.

through its Director, at: SP-49A, Main Market,

Pandav Nagar, Delhi-110092, I hereby serve upon

you with the following legal notice:

10. That my client is the Director of the above

named company and running his office at the

above given address.

11. That you noticee was appointed on the post

of Operation Executive by virtue of


Appointment Letter dated 24.10.2016 which is

the date of your joining the above said

company of my client.

12. That as per the job profile of you noticee,

you noticee have to worked my client for a

minimum period of 09 months and if you fails

to comply the same, then my client shall

have the right to initiate legal action

against you noticee.

13. That it is also relevant to note here that

in the appointment letter duly accepted by

you noticee, it is clearly averred at para

no.8 by the heading “Company Property” that

“…You will always maintain in good

condition, company property, which may be

entrusted to you for official use during the

course of your employment and shall return

all such property to the company prior to

relinquishment of your charge, failing which


the cost of the same will be recovered from

you by the company…”. It is also needless to

say that all the electronic data of the

company of my client is also confidential

and you were not supposed to leak any of the

confidential electronic data of the company

of my client in any manner whatsoever,

either it is agreed or not, because all

these are the confidential and proprietary

information of the company of my client,

leaking of which may cause a grave loss and

harm to the company of my client in terms of

financial forfeiture of funds.

14. That you noticee was never appropriate and

regular towards your job and duties which

you had rendered towards the company of my

client and you noticee used to indulge

yourself in unwanted activities arguments,

which resulted into unnecessary

controversies in the company.


15. That not only this, you noticee have even

avoided the rules, regulations and norms of

the company during the working hours, as you

noticee have also committed cheating and

fraud with the company of my client by

steeling the electronic data of the company

of my client by way of copying the

electronic data into your electronic storage

devices viz. pendrives and hard drives etc.

and leaked the same to the rivals of my

client against receiving huge amount from

them with the intention to cause severe

financial loss to my client.

16. That it is also relevant to point out that

you have also not complied the guidelines

and norms for your appointment for working a

minimum period of 09 months, as you have

left your job on 20.05.2017 without any


prior intimation and notice, which is a

clear cut negligent act on your part.

17. That by virtue of your above said illegal

and unwarranted acts and conduct, you

noticee rendered yourself liable to be

prosecuted under legal viz. civil qua

criminal procedures code for your above said

conducts and my client is going to initiate

appropriate legal proceedings before the

court of law.

18. That you noticee is liable to pay a lump-sum

amount of Rs.10 Lacs to my client as damages

towards financial loss caused to the company

of my client as elaborated above. My client

reserves his right to produce appropriate

evidences regarding the loss caused to its

company at a relevant stage.

I, therefore call upon you through this

legal notice to pay a sum of Rs.10 Lacs to


my client within 15 days from the receipt of

this legal notice, failing which my client

shall be constrained to initiate appropriate

civil as well as criminal proceeding against

you totally on your costs, risks and

consequences.

You are also liable to pay Rs.11000.00

as fee of this legal notice.

Copy kept in my office for further

references.

Tarun Gautam
Advocate
REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH RAJBIR
S/o SH. CHADAMI LAL,
R/o D-3/51, DAYALPUR,
DELHI-110094

Sir,
Under the instruction from and on behalf of
my client SH RAJ KUMAR, S/o SH RAMESH CHAND, R/o
T-44, WARD No.6, ISLAM COLONY, MEHRAULI, NEW
DELHI-110030, I hereby serve upon you through
the following legal notice, which facts as
under:-

13. That my client is residing at abovesaid


address and he is the sole and absolute
owner of property bearing No. D-3/51,
Dayalpur, Delhi-110094.

14. That you noticee is the tenant under my


client in respect of One Room with
latrine/ bathroom on ground floor and one
room with kitchen on first floor i.e. the
Tenanted Premises/ Suit Property since
12th June, 2012 under the landlord-ship of
my client. A Rent Agreement was duly
executed between my client and you noticee
on 12.02.2012 and since then you noticee
and his family started residing at the
abovesaid address.

15. That as per the agreement, my client had


let out the built up property land area
measuring 25 Sq. Yds., out of Khasra
No.293 bearing property No.D-53 situated
at the area Mustafabad in the Abadi of
Gali No.4, D-Block Dayalpur Extn., Delhi-
110094 to you noticee on monthly rent of
Rs.3,000/- (Rupees Three Thousand only)
per month for a period of five years
commencing from 12.06.2012 to 11.05.2017.

16. That the terms and conditions were duly


explained in the rent agreement and it was
also made clear in the rent Agreement that
my client/owner has full right to get
vacate the said tenant premises before the
expiry of tenancy period by serving one
month advance notice to the tenant for
vacating the premises and the second
party/tenant may vacate the premises
without any delay.

17. That it was also settled that the tenant


will not do any illegal activity and by
receiving the notice he will vacate
premises peacefully.

18. That now my client is in need to get


vacated the abovesaid property from you
noticee, because he wants to sale out the
same and he required the possession of the
abovesaid property from you noticee.

19. That my client is not willing to keep you


noticee in the said tenanted premises/
suit property.

I, therefore call upon you through


this legal notice that my client does not
wants to keep you as tenant any more in
his premises and terminated your
tenancy/license with immediate effect,
hence I further call upon you kindly
handover the peaceful vacant physical
possession of the said premises within
stipulated period after receiving the
present legal notice otherwise my client
shall be constrained to take legal action
against you totally on your costs, risks
and consequences.
You are also liable to pay Rs.5,500/-
as legal expenses to my client.

Copy kept for further references in my


office.

A.K. BHATT
ADVOCATE

VISHWAS AHUJA CHAMBER No.D-619,


ADVOCATE D-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
Ref. No. DATED:

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH VIPIN KUMAR @ VIPIN KUMAR AGGARWAL,
AT: X/271, GALI NO.9,
MAIN ROAD, RAM NAGAR,
GANDHI NAGAR, DELHI-110031

Sir,
Under instructions from and on behalf of my
client M/S S.R. TRADING CO. THROUGH ITS PROP.
SH. AMIT KUMAR JAIN, AT: 9/1244, JURAB MANDI,
SUBHASH ROAD, GANDHI NAGAR, DELHI-110031, I
hereby serve upon you through this following
legal notice, facts as under:-

27. That my client is dealing in the business

of selling and supplying of various types

of fabrics and doing its business in the

name and style of M/s S.R. Trading & Co.

and having its office at: 9/1244, JURAB

MANDI, SUBHASH ROAD, GANDHI NAGAR, DELHI-

110031.

28. That you notice usually used to purchase

the fabrics from my client from time to

time and you used to make the payment

accordingly as per the convenience and

mutual agreement between you noticee and

my client.

29. That consequently in the month February-

2017, you noticee purchased the fabric

(Bansal Denim & Denim respectively) from

my client against Invoice No.54, dated


06.02.2017 for Rs.50,000/- and another

Invoice No.63, dated 27.02.2017 for

Rs.50,000/- and the same were duly

received by you.

30. That in discharge of your above said

liability, you noticee issued, signed and

delivered two post-dated cheques bearing

No. 008498 of Rs.50,000/- of dated

16.04.2017 and cheque No.008501 of dated

22.04.2017 of Rs.50,000/-, both drawn on

ICICI Bank Ltd., branch at Parliament

Street, New Delhi-110001 and at the time

of issuing the aforesaid cheques, you

noticee assured my client that the said

cheques would be honoured positively at

the time of its presentation.

31. That thereafter, as per your instructions,

my client presented one of the said cheque

bearing No.008498 with his banker i.e.


Punjab National Bank, Branch at Krishna

Nagar, Delhi, but the said cheque got

dishonoured on two occasions with remarks

“FUNDS INSUFFICIENT” vide its returning

memos dated 21.04.2017 and 28.04.2017

respectively.

32. That after dishonour of the above said

cheque on two occasions, my client

conveyed you noticee about the dishonor of

the cheque and demanded his above said

amount in cash, upon which you noticee

requested my client to present the said

cheque again with his banker and assured

that this time, the same will be encashed

definitely.

33. That thereafter, as per your instructions,

my client had lastly presented the said

cheque bearing No.008498 with his banker

i.e. Punjab National Bank, Branch at


Krishna Nagar, Delhi, but to the utter

shock and surprise for my client, as the

said cheque again got dishonoured with

remarks “FUNDS INSUFFICIENT” and my client

received the information through returning

memo dated 17.05.2017.

34. That thereafter, my client also presented

the another cheque bearing No.008501 with

his banker i.e. Punjab National Bank,

Branch at Krishna Nagar, Delhi for its

encashment, but the said cheque also got

dishonoured with remarks “FUNDS

INSUFFICIENT” and my client received the

information through returning memo dated

23.05.2017.

35. That thereafter, my client approached you

noticee to apprise you about the dishonour

of the abovesaid cheques, but you noticee

showed your inability and did not pay any


heed to pay back the abovesaid amount to

my client and since then you noticee kept

passed the time by one pretext or the

other and now you noticee instead of

making the payment of the abovesaid

cheques, flatly refused to make the

aforesaid payment to my client in any

manner.

36. That in discharge of your legally

enforceable liability, you noticee issued,

signed and delivered the above said two

cheques which were dishonoured by the

banker of you noticee, as you noticee has

not arranged the sufficient amount in your

banker/ account and thus you noticee

breached the trust of my client and

committed an offence punishable under

section 138 of N.I. Act.

I, therefore call upon you through this


legal notice to make the payment of the
above said dishonoured cheques i.e. total
Rs.1,00,000/- (Rupees One Lac only) to my
client within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Vishwas Ahuja
Advocate
MOHD. SHAHWAZ Chamber No.G-728,
ADVOCATE 7TH FLOOR, G-Block,
Lawyers Chambers,
DELHI HIGH COURT Karkardooma Courts
ENL. No.D-2636/08 Complex, Delhi-32.
e-mail: m.shahwaz@yahoo.com M: - 09891747269
Ref: Date: 19.04.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH BRIJ MOHAN
HEAD CONSTABLE No.58 COY-C,
R.A.C., 11 BATALIAN, NEAR CRPF CAMP,
POLICE TRAINING SCHOOL,
WAZIRABAD, DELHI-110094

Sir,
Under instructions from and on behalf of my
client SH HARISH KUMAR, S/o SH VINOD SINGH, R/o
B-931, GALI No.16, NEAR SHIV MANDIR, SUBHASH
MOHALLA, NORTH GHONDA, DELHI-110053, I hereby
serve upon you through this following legal
notice, facts as under:-

37. That my client is a peace loving and law


abiding citizen of India and is residing
at the above stated address and having
full faith over the due process of law.

38. That you noticee and father of my client


had friendly relationship as well as
visiting terms since long and you noticee
used to visit at the house of my client.

39. That you noticee in the month of January,


2016 approached my client at his address
and requested to arrange a sum of
Rs.80,000/- (Rupees Eighty Thousand only)
as a friendly loan and you noticee
disclosed that he was in dire need of
money for his urgent need and after 4-5
days my client handed over Rs.80,000/-
(Rupees Eighty Thousand only) in cash to
you noticee in January, 2016 and at the
time of borrowing the said amount you
noticee assured to my client that he will
return the abovesaid amount within 8-9
months by way of advance cheque, as it is
relevant to note here that at the same
time, in discharge of his liability, you
noticee issued a cheque bearing No.030916,
without dated for a sum of Rs.80,000/-
(Rupees Eighty Thousand only) drawn on
Axis Bank, Branch-Daryaganj, Delhi and
requested my client to present the said
cheque as per the instruction of you
noticee after filing the date on it and my
client accepted the same.
40. That after passing 8-9 months my client
contacted you noticee and asked from you
noticee for his permission to present the
said cheque in his banker for encashment,
but at that time, you noticee sought some
more time for repaying the said loan and
he assured to my client that he will
arrange the money till January, 2017 and
requested my client to reconfirm about the
presentation of the said cheque in
January, 2017.

41. That thereafter, in the month of January,


2017 you noticee directed my client to
present the said cheque in his banker for
its encashment after filling up date in it
and consequently as per the assurance of
you noticee, my client presented the said
cheque with his banker i.e. SBI, Branch
Ghonda, Delhi-110053, but the said cheque
got dishonoured with remarks “FUNDS
INSUFFICIENT” vide its returning memo
dated 02.02.2017.

42. That after dishonour of the abovesaid


cheque my client conveyed you noticee
about the dishonor of the cheque and
demanded his abovesaid amount in cash,
upon which you noticee requested my client
to present the abovesaid cheque again with
his banker and assured that this time, the
same will be encashed.

43. That as per the assurance of you noticee,


my client again presented the abovesaid
cheque with his banker i.e. SBI, Branch
Ghonda, Delhi-53, but the said cheque
again got dishonoured with the remarks
“FUNDS INSUFFICIENT” vide its returning
memo dated 21.03.2017.

44. That thereafter, my client approached you


noticee to apprise him about the dishonour
of the abovesaid cheque on second occasion
and demanded the abovesaid friendly loan
amount of Rs.80,000/- (Rupees Eighty
Thousand only) in cash, but you noticee
showed his inability and did not pay any
heed to pay back the abovesaid amount to
my client and since then you noticee kept
passed the time by one pretext or the
other and now you noticee instead of
making the payment of the abovesaid
cheque, flatly refused to make the
aforesaid payment to my client in any
manner.

45. That in discharge of his legally


enforceable liability, you noticee issued,
signed and delivered the above said cheque
which was dishonoured by the banker of you
noticee, as you noticee has not arranged
the sufficient amount in his banker/
account and thus you noticee breached the
trust of my client and committed an
offence punishable under section 138 of
N.I. Act.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.80,000/-
(Rupees Eighty Thousand only) to my client
within 15 days from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.
Mohd. Shahwaz
Advocate

Mamtesh Sharma Chamber No.F-709, F-Block


Advocate 7th Floor, Lawyers Chambers
Block, Kakardooma Courts
DELHI HIGH COURT Delhi-110032
E-mail: mmamtesh@gmail.com Ph: 09810322929, 08860077857
==================================================================
Ref: Date: 11.05.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S OMKAR NESTS PVT. LTD.
THROUGH ITS DIRECTOR/A.R.
CORPORATE OFFICE:
H-64, SECTOR-63,
NOIDA, U.P.

CORPORATE OFFICE ALSO AT:


PLOT NO.144/5, (G.F.)
GYAN KHAND-IV, INDIRAPURAM,
GHAZIABAD, U.P., 201 014

SITE OFFICE:
PLOT NO.GH-8B,
SECTR TECH ZONE-4,
GREATER NOIDA (WEST)
DISTT. G.B. NAGAR, U.P

Sir,
Under instructions from and on behalf of my
client M/S GOYAL SALES CORPORATION, THROUGH ITS
PROP. SH. SANJAY GOYAL, HEAD OFFICE AT: 357,
VARDHMAN GRAND PLAZA, MANGLAM PLACE, SECTOR-3,
ROHINI, NEW DELHI-110085, ALSO CORPORATE OFF:
SHOP NO.2, GROUND FLOOR, PLOT NO.28, GIRDHAR
ENCLAVE, SAHIBABAD, GHAZIABAD, U.P., I hereby
serve upon you through this following legal
notice, facts as under:-

1. That my client M/s Goyal Sales Corporation


is doing the work of POP Fall Ceiling,
Gypsum, Grid, Paint, White Wash etc. at the
above given address.

2. That on 06.11.2015, you noticee contacted my


client and placed a work order No.Roy/1024
for the Scope of Work “Paint Work” and
initially it was agreed between my client
and you noticee that my client shall do the
work of providing and applying OBD paint
viz. Two Coat Putty (J.K), One Coat Primer
(Berger), two more Coat OBD and besides this
providing and fixing gypsum board boxing in
fire fighting pipe.

3. That it is relevant to point out here that


the rates for the said work were duly agreed
between my client and you noticee as per
your work order dated 06.11.2015.

4. That it is also pertinent to mention here


that other works was also agreed to be done
by my client viz. Providing and apply POP
punning, providing and apply white wash in
three coat basement, providing and fixing
fall ceiling in toilet (4 mm thick Everest),
Samosum, but the same work was withdrawn by
you noticee without any intimation to my
client while the labourer of my client very
duly available and even they remained
without work for many days due to your above
said withdrawal from the said work and for
the said purpose my client duly asked the
reason from you noticee as to why the said
work was not sought by you noticee, but you
noticee always kept passed the time by one
pretext or the other.

5. That consequently my client has completed


the work which was assigned to him by you as
mentioned in the corresponding para upto the
total satisfaction of you noticee.

6. That it is important to note here that it


was agreed between my client and you noticee
that the payment will be made through cheque
and the monthly bill will be paid after 15
days of receiving the bill, but despite that
the said terms and conditions were not
complied by you noticee intentionally and
deliberately with the maalfide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.

7. That as per the statement of account and


records maintained by my client, my client
has raised various bills to you noticees
from time to time for the total amount of
Rs.11,26,384/- (Rupees Eleven Lacs, Twenty
Six Thousand, Three Hundred and Eighty Four
only) and out of which you noticee has made
various payments but not made the complete
payment to my client despite repeated
requests and demands made by my client.

8. That as per the records maintained by my


client, a sum of Rs.5,98,549/- (Rupees Five
Lacs, Ninety Eight Thousand, Five Hundred
and Fourty Nine only) are still due upon you
noticee, which are legally recoverable from
you, but despite repeated requests and
demands made by my client, you noticee have
failed to make the aforesaid due payment of
Rs.5,98,549/- (Rupees Five Lacs, Ninety
Eight Thousand, Five Hundred and Fourty Nine
only) to my client intentionally and
deliberately.

9. That it is also relevant to point out here


that you noticee only to avoid the aforesaid
payments to my client and with the intention
to grab the same, you started making false
and frivolous pretexts and started raising
question on the work, but it is made clear
that all the work was done in your regular
presence as well as under your whole
supervision and upto your total
satisfaction, but now only to avoid the
payment, you are plying ill tactics to grab
the hard earned money of my client.

10. That my client also reserves his right to


initiate separate criminal proceedings
against you noticee for cheating, criminal
breach of trust and misappropriation of
funds, which is a punishable offence under
the Indian Penal Code, 1860.

I, therefore call upon you through this


legal notice to make the payment of
Rs.5,98,549/- (Rupees Five Lacs, Ninety
Eight Thousand, Five Hundred and Fourty Nine
only) to my client alongwith interest at the
tune of 24% per annum to my client within 15
days, from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate civil as well
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Mamtesh Sharma
Advocate
REGD.A.D/SPEED POST
LEGAL NOTICE
To,
Sh. Jitender Pathak @ Deepak,
S/o Sh. Ram Swaroop Pathak,
R/O H.No.36, 3rd Floor, Gali No.4,
Bhagwati Niwas, Saroji Naidu Park,
Shastri Nagar, Delhi-110031

Sir,
Under the instruction from and on behalf of
my client Smt. Krishna Aggarwal, W/o Sh. Pradeep
Aggarwal, R/o H.No.R-284, Gali NO.13, Ramesh
Park, Laxmi Nagar, Delhi-110092, I hereby serve
upon you through the following legal notice,
which facts as under:-

1. That you notice are the brother of my client


in relation and you were maintaining good
familiar visiting terms with my client since
long.
2. That in the first week of December, 2013,
you approached my client and asked my client
to provide financial help as you had to pay
said amount to some person, to which, my
client became agreed considering the
familiar relations.

3. That thereafter in last week of December,


2013, you again approached my client and
said that you have to pay a total sum of
Rs.4,82,300/- to some persons and demanded
the said amount as loan from my client. My
client gave a sum of Rs.4,82,300/- to you
notice as loan for a period of 6 months only
and you assured my client to pay the same
within stipulated period of 6 months. In
this regard, an agreement was also executed
by you the noticee thereby acknowledgment
the receipt of Rs.4,82,300/- and assuring my
client that you would pay the said amount to
my client within 6 months. At the same time,
you noticee issued three post dated cheques
in favour of my client drawn upon one cheque
bearing No.340681 of Rs.2,07,300/-, drawn on
Karnataka Bank Ltd., Branch at Savita Vihar,
Delhi-110092 of dated 12.09.2014 and two
cheques are from SBI State Bank of India
Branch at Geeta Colony, Delhi-110031.

4. That in the month of November, 2014, when my


client presented the said cheque bearing
NO.340681 in her banker for encashment, but
the same was returned unpaid with remarks
“FUNDS INSUFFICIENT”.

5. That after receiving the returning memo my


client approached you noticee and demanded
her entire amount from you, but you lingered
on the matter rather threatened my client
for dire consequences and also refused to
make the payment of the cheque issued by you
noticee and till today not made the payment
to my client.

6. That by committing the above said act, you


noticee have made yourself liable to be
prosecuted under provisions of law, as you
have issued signed and delivered the said
cheque which was dishonoured by your banker.

I, therefore call upon you through this


legal notice to pay Rs.2,07,300/- (Rupees
Two Lacs, Seven Thousand and Three Hundred
only) towards the said cheque in question to
my client within 15 days, from the receipt
of this legal notice, failing which my
client shall be constrained to initiate
appropriate civil as well criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Sanjeev Kedwal
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: .05.2017

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
Sh. Pankaj Tripathi,
S/o Sh. Triveni Prasad Tripathi,
R/O Village Vinaika,
Post Pura Dhakwa,
Tehsil Patti, Distt. Pratapgarh,
U.P.,

Sir,
Under the instruction from and on behalf of

my client M/S SYNDICATE INNOVATIONS

INTERNATIONAL LIMITED, THROUGH ITS M.D. MR.

ASHOK RAI, HAVING ITS REGD. OFFICE AT: GULAB

BHAWAN, G-365, PREET VIHAR, DELHI-110092, ALSO

AT: SYNDICATE GROUP, E-16, SAHIBABAD INDUSTRIAL

AREA, SITE-IV, GHAZIABAD, U.P-201 010, I hereby

serve upon you through the following legal

notice, which facts as under:-


1. That my client is doing the business of

manufacturing and supply of sports shooting

goods in the name and style of M/s SYNDICATE

INNOVATIONS INTERNATIONAL LIMITED, duly

registered under the Companies Act, 2013.

2. That you noticee was the employee of my

client and you noticee used to do the job

for collecting the orders and in pursuant to

your job, on ____________ (Date) my client

company appointed you noticee at Jaipur

Fair, Jaipur for collecting the orders from

the customers/ clients of my client company.

3. That consequently you noticee while working

in Jaipur Fair has received various orders

from the customers/clients of my client and

also received total advance payment of

Rs.1,50,000/- (Rupees One Lac and Fifty

Thousand only) from various clients and you

noticee intentionally and deliberately got


deposited the said amount in your account as

well as in the account of your brother

namely Sandeep Kumar Tripathi, vide his

Account No.4007001500012682 with Punjab

National Bank branch at Jagriti Vihar,

Meerut, U.P.

4. That consequently after completion of the

Jaipur Fair, my client demanded the complete

details from you noticee, but you noticee

didn’t give any details to my client and

kept passed the time by one pretext or the

other that you are not prepared the complete

details and once you will finalize, you may

give the complete details to my client.

5. That thereafter my client has come to know

that you noticee has committed fraud with my

client, as the clients from which you have

received the advance payment against the

products of my client, have started


contacting my client and asked about the

products, then finding no other option, my

client contacted you noticee and asked about

the actual matter.

6. Than on 04.08.2015, you noticee made a

written Apology Letter thereby confession

all your misdeeds by mentioning that you are

responsible for fraudulent activities and

also your inappropriate behaviour and

criminal activities during your tenure which

was led to potential loss to my client.

7. That on 05.12.2016 you noticee have resigned

from your job intentionally and deliberately

only to escape yourself from the legal

liabilities and consequences, as you were

under legal liability to pay Rs.1,50,000/-

(Rupees One Lac and Fifty Thousand only) to

my client which was received by you noticee


from the clients of my client as advance

payments in Jaipur Fair.

8. That thereafter my client has also issued a

termination letter to you noticee on dated

09.12.2016 reasoning of committing fraud by

you noticee.

9. That on 06.04.2017 my client issued a letter

to you noticee regarding committing fraud by

you noticee and illegally withholding a sum

of Rs.1,50,000/- (Rupees One Lac and Fifty

Thousand only) of my client and requested

you noticee to settle the matter within 7

days.

10. That you noticee in response to the letter

dated 06.04.2017 made by my client, wrote a

false and frivolous reply dated 17.04.2017

only to create false evidence.


11. That from your above said acts and conduct,

it is crystal clear that you noticee have

played fraud with my client and you have

further illegally withheld/grabbed

Rs.1,50,000/- (Rupees One Lac and Fifty

Thousand only).

12. That you noticee are still liable to pay a

sum of Rs.1,50,000/- (Rupees One Lac and

Fifty Thousand only) to my client which was

received by you from the clients/ customers

of my client and didn’t return the same to

my client towards booking of goods/

products, for which my client reserves his

right to file appropriate proceedings for

the recovery of the above said amount from

you noticee.

13. That my client also reserves his right to

lodge criminal proceedings of fraud,

cheating, misappropriation of funds,


criminal breach of trust committed by you

noticee within the collusion of your

brother, as you noticee have also deposited

the amount in the account of your brother,

which amounts to commission of offence U/s

406/419/420/120-B/34 IPC, hence this notice.

I, therefore call upon you through this


legal notice to pay a sum of Rs.1,50,000/-
(Rupees One Lac and Fifty Thousand only) to
my client within 15 days, from the receipt
of this legal notice, failing which my
client shall be constrained to initiate
appropriate civil as well criminal
proceeding against you totally on your
costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

Pankaj Bhushan
Advocate
Ved Prakash Masih Chamber No.F-423, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1898/99 M. 9818613737
Ref: DATE: 01.05.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH. ANIL KUMAR GUPTA,
S/O SH. RAMESH CHAND GUPTA,
R/O 66, NEW LAYALPUR,
DELHI-110051

Sir,
Under instructions from and on behalf of my
client M/S SAT GURU ENTERPRISES, THROUGH ITS
PROP. SMT. MANJU BALA, W/O LATE SH. SHISHU PAL,
R/O 22, RADHEY SHYAM PARK, DELHI-110051 I hereby
serve upon you through this following legal
notice, facts as under:-

21. That you noticee and the husband of my


client were well known to each other being
in old business relationship and due to the
said reason, you noticee also well
acquainted with my client.
22. That you noticee approached to my client and
demanded a sum of Rs.30,00,000/- (Rupees
Thirty Lacs only) for your dire need of
money and you noticee disclosed that you are
the owner of one built up shop on ground
floor portion of property No.273,
measurement approx. 7’-10” X 30’ fitted with
Iron Shutter and Electricity upto the extent
of ceiling level, out of rect. No.12, Killa
No.11, situated at abadi of New Layalpur
Colony, in the area of Village Khureji Khas,
Illaqa Shahdara, Delhi-110051.

23. That consequently you noticee and my client


have entered into a Mortgage Agreement dated
23.07.2014 whereby you noticee had borrowed
a sum of Rs.30,00,000/- (Rupees Thirty Lacs
only) from my client against the physical
possession of the above said property. The
aforesaid mortgage agreement was duly signed
by both the parties in the presence of
marginal witnesses and duly notarized.

24. That since then my client is in the actual


physical possession of the said property.
25. That it is also relevant to point out here
that you noticee have also issued four
cheques bearing NO.272140 dated 15.01.2015
of Rs.7,00,000/-, cheque No.272141 of dated
15.01.2015 for Rs.8,00,000/-, cheque
No.272142 of dated 15.01.2015 of
Rs.10,00,000/- and cheque No.272148 of dated
15.01.2015 of Rs.5,00,000/-, all drawn on
Punjab & Sind Bank, Sidhartha Enclave,
Bhogal, New Delhi-110014 and you noticee
assured that till the date of the aforesaid
cheques, you will returned the said borrowed
amount to my client.

26. That you noticee failed to make the payment


of the aforesaid borrowed amount to my
client till the date of said cheques as you
noticee requested my client not to present
the said cheques for its encashment and then
my client approached to you noticee and
demanded his money, then you noticee issued
two fresh cheques bearing No.272116 of Sted
25.12.2016 of Rs.15,00,000/- and cheque
No.272117 of dated 20.05.2016 of
Rs.10,00,000/- both drawn on Punjab & Sind
Bank, branch at Sidhartha Enclave, Bhogal,
New Delhi-110014 and you noticee further
assured my client and promised to give one
further cheque of Rs.5,00,000/- for the
remaining balance amount after getting a
fresh cheque book from your bank.

27. That as per your assurance and instructions


my client had presented the said both
cheques in his banker i.e. Syndicate Bank,
Scope Minar, Laxmi Nagar, Delhi, but the
said cheques were dishonored by your banker.

28. That you noticee are still liable to pay a


sum of Rs.30,00,000/- (Rupees Thirty Lacs
only) to my client alongwith interest,
failing which you noticee are liable to
execute the registered sale documents of
your above said property, as you noticee has
already executed the notarized General Power
of Attorney and other concerned documents in
favour of my client in respect of the said
property at the time of said mortgage, as
assured by you noticee to my client, hence
this notice.

I, therefore call upon you through this

legal notice to pay a sum of Rs.30,00,000/-

(Rupees Thirty Lacs only) to my client


alongwith interest or to execute the

registered sale documents of your above said

property in favour of my client, within 15

days from the receipt of this legal notice,

failing which my client shall be constrained

me to initiate appropriate civil as well as

criminal proceedings against you, totally on

your risks, costs and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept for further references in my


office.

V.P. Masih
Advocate
REGD. A.D./SPEED POST
LEGAL NOTICE
To,
The Manager,
The New India Assurance Company Limited.
At: New India Assurance Building,
87, M.G. Road Fort,
Mumbai 400 001,
ALSO AT:
Unit 121403, 1st Floor,
New India Centre, 17/A,
Cooperage Mumbai, Maharashtra-400 001,

Sir,
Under the instructions from and on behalf of

my client Sh. Deepak, S/o Sh. Tilak Raj, R/O

H.No.65-B, Gali No.2, Behind Shamshan Ghat,

Jwala Nagar, Shahdara, Delhi-110032, I hereby

serve upon you with the following legal notice:

1. That my client had purchased a vehicle i.e.

Tata Indigo car bearing Regn. No.DL1RTA-2423

Model 2015.

2. That the said vehicle was duly insured with

you noticee vide Policy No. 12140431150


100177142 valid w.e.f. 25.01.2016 to

24.01.2017.

3. That on 21.10.2016 in the evening hours, at

Sector-157, Noida Express Way, Gautam Budh

Nagar, U.P while driving, the above said

vehicle of my client was set on fire because

of some technical defects and due to some

unavoidable circumstances under the

jurisdiction of P.s Knowledge Park, Gautam

Budh Nagar, U.P and in this regard a

complaint/ report was lodged at Fire

Station, P.s Knowledge Park, Gautam Budh

Nagar, U.P.

4. That my client has duly informed to your

concerned agent in regard of the said

incident with his vehicle within 24 hours of

the said incident.


5. That in the said fire, the above vehicle of

my client was 100% burnt from its body as

well as from its inner side.

6. That thereafter my client has applied to you

noticee for getting the insurance claim of

his said vehicle and accordingly my client

has completed all the formalities and

requirements for obtaining the insurance

claim, but despite that you noticee and your

concerned officials have not granted the

insurance claim to my client intentionally

and deliberately and kept passed the time by

one pretext or the other.

7. That consequently my client approached to

your concerned office for receiving the

insurance claim of his above said burnt

vehicle, then my client was told by your

concerned officials that the insurance claim

will be disbursed in favour of my client


after completion of some formalities, but

all went in vain.

8. That this is clear cut deficiencies on part

of you noticee and unfair trade practice, as

you noticee are not granting the insurance

claim to my client in respect of his burnt

vehicle.

9. That my client has been suffered from a

great mental harassments, pain and agony

only because of illegal and unwarranted

acts.

10. That you noticee is liable to compensate my

client in a sum of Rs.5 Lacs as compensation

for mental and physical torture pain and

agony, hence this notice.

I, therefore call upon you through this


legal notice to release the complete insurance
claim of the vehicle of my client and to
compensate my client in a sum of Rs.5 Lacs for
as compensation for mental and physical
torture pain and agony and to pay the same to
my client, within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

TARUN GAUTAM
ADVOCATE
SEEMA DOGRA Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1968/99 M:- 9810893021
Ref. No. DATED: 28.04.2017

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
Sh. Rajeev Pratap Singh
Advocate,
AT: Chamber No.E-212,
Karkardooma Courts,
Delhi-110032

Sir,
My client Sh. Ashish Aggarwal, S/o Sh.
Surender Aggarwal, R/o K-5/19, Gali No.5, West
Ghonda, Delhi-110053, has placed before me your
legal notice dated 13.04.2017 sent by you on
behalf of your client Sh. Akash Gupta, R/o K-
21/30, Gali No.14-A, West Ghonda, Delhi-110053,
and my clients instructed me to give the reply
of the same and brought true facts into your
knowledge, which facts are as under:-

PRELIMINARY OBJECTIONS:-
52. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.
53. That your client did not disclosed the
actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.
54. That the true fact is that my client has no
concerned with your client in any manner and
my client even doesn’t know your client in
any manner.
55. That my client having friendly relations
with one Sh. Pankaj Sharma, S/o Sh. Rakesh
Sharma, R/O K-21/29, Gali No.15, West
Ghonda, Delhi-110053 since long time and on
09.03.2017 my client alongwith the said Sh.
Pankaj Sharma was going to market and at
that time he was carried out his original
signed cheque book alongwith some other
important documents, but in the market, my
client had lost his original signed cheque
book which contained various blank signed
cheques by my client and my client was under
impression that whether it was lost in
market or somewhere in his house and finally
when he didn’t find his said cheque book,
then he lodged an NCR vide LR No.433787/2017
dated 28.03.2017 at P.s Crime Branch and
further he given written request to the
concerned Branch Manager of State Bank of
India, Branch at Gokulpuri, Delhi on the
same day i.e. on 28.03.2017 to stop the
payment of the lost cheques/cheque book.
56. That now my client has shocked to receive
the present legal notice, as he has come to
know that the above said cheque which was
blank signed and attached with his said lost
cheque book, has been misused by your client
and immediately after receiving the present
notice, my client approached to your client
personally and ask the genuine fact, then
your client disclosed that the said cheque
has been handed over to your client by the
said Sh. Pankaj Sharma, who was the friend
of my client and then only my client has
come to know about the all story that the
said original cheque book has been stolen by
the said Sh. Pankaj Sharma from my client
and misused the same by giving one of or
more cheques to your client with the
malafide intention and ulterior motives to
cause wrongful loss to my client and
wrongful gain to yourself and not only this,
your client has also hatched conspiracy with
the said Sh. Pankaj Sharma to support in his
illegal and unwarranted acts only to extort
money from my client, hence my client is
going to file separate criminal/ legal
complaint against your client and the said
Sh. Pankaj Sharma for their above said
illegal and unwarranted acts. My client
having sufficient proofs to prove his
contention, which may be produced at the
relevant stage.
57. That it is also relevant to point out here
that my client also having apprehension that
your client or the said Sh. Pankaj Sharma
within the collusion and conspiracy with
each other may misuse further blank signed
cheques of my client at any time in future.
58. That my client is not liable to pay even a
single penny to your client in any manner,
as neither he issued cheques in question to
your client in discharge of any liability,
nor any amount is due upon my client qua
your client.
REPLY ON MERITS:-
1. That the contents of Para No.1 of your legal
notice are wrong, false, and concocted,
hence denied. However, it is submitted that
your client and my client had/have never
been in any friendly relations with each
other at any point of time nor my client had
ever borrowed even a single penny from your
client at any point of time, the reason
thereby my client even doesn’t know to your
client in any manner.
2. That the contents of Para No.2 of your legal
notice are wrong, false, and concocted,
hence denied. However, it is submitted that
when my client has not borrowed even a
single penny from your client then the
question of issuing any cheques or
requesting to return any amount to your
client doesn’t arise at all in any manner.
3. That the contents of Para No.3 of your legal
notice are wrong, false, and concocted,
hence denied. However, it is submitted that
the cheques in question of my client have
been misused by your client within the
collusion and conspiracy of the said Sh.
Pankaj Sharma and therefore my client
reserves his right to initiate separate
legal proceedings against your client and
the said Sh. Pankaj Sharma.
4.5. That the contents of Para No.4 & 5 of
your legal notice are wrong, false, and
concocted, hence denied. However, it is
submitted that all the averments and
versions as alleged in the para under reply
are nothing but an ill tactics only to
create false evidence.
I, therefore request you through this
reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my clients
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.
Your clients are also liable to pay
Rs.5500/- as legal remuneration of this
reply.
Copy kept for further references in my
office.

Seema Dogra
Advocate
SANJAI PREMI E-419, 4th Floor, E-BLOCK
Advocate Lawyers Chambers
Karkardooma Courts,
Delhi -110032.
DELHI HIGH COURT M: - 9868436462
ENR No. D-3623/2009
Ref. No. DATED: 25.04.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH. RAM CHANDER


S/O SH CHHOTEY LAL,
R/O I-399, GROUND FLOOR,
I-BLOCK, SUNDER NAGRI,
DELHI-110093

2. SH. RAMESH
S/O SH CHHOTEY LAL,
R/O I-399, FIRST FLOOR,
I-BLOCK, SUNDER NAGRI,
DELHI-110093

3. SH. MUNESH
S/O SH CHHOTEY LAL,
R/O I-399, SECOND FLOOR,
I-BLOCK, SUNDER NAGRI,
DELHI-110093

Sir(s),

Under instructions from and on behalf of my

client namely SH. SANTOSH KUMAR, S/O SH. CHHOTEY

LAL, R/O I-399, SUNDER NAGRI, DELHI-110093, also


at: A-577, Rajiv Colony, Gali No.2, Bhopura,

Near DLF, Ghaziabad, U.P, I hereby serve upon

you through this following legal notice, facts

as under:-

30. That you noticees are the real brothers of

my client and residing in the property

bearing No.I-399, SUNDER NAGRI, DELHI-

110093 in the portion of ground floor,

first floor and second floor respectively.

31. That my client is the sole and absolute

owner of the property bearing No. I-399,

SUNDER NAGRI, DELHI-110093, measuring 22½

sq. yards by virtue of General Power of

Attorney, Agreement to Sell, Gift Deed,

Affidavit, Family Will and Possession

Letter all of dated 03.10.2012 executed by

Smt. Deep Wati, W/o Shri Chhotey Lal in

the presence of marginal witnesses and

since then my client became the sole and


absolute owner and in possession of the

said property.

32. That you noticees were already residing in

the said property since the day when my

client became lawful and sole owner of the

said property and on your request, my

client has permitted you noticees to

reside in the said property as licensees

in your above said respective portions.

33. That all of you noticees are regularly

harassing and humiliating my client by

your illegal, and incooperative acts and

activities and being real brothers, you

noticees are not respecting my client and

want to capture the property of my client

illegally and unlawfully without having

any right, title or interest.

34. That very often since beginning, you

noticees used to quarrel with my client on


minor issues. And you noticees have

threatened my client that you will

implicate my client and his family members

in any false criminal case.

35. That now my client does not wish to permit

you noticees to live in the said property

in respect of portion which is in your

possession. You are further required to be

noted that my client have terminated your

living capacity/locus standi in said

premises, therefore you noticees have no

right to stay in the property of my client

and you are liable to pay occupational

charges @ Rs.5,000/- per month each w.e.f.

25.05.2017 and now you are living in the

said property as unauthorized occupants.

36. That despite several oral requests for

vacating of the portion of the above said

property in your possession, you noticees


did not pay any heed and also not bothered

to vacate the portion in your possession

till date, hence this notice.

I, therefore call upon you through this

legal notice that you noticees to vacate the

premises of my client i.e. I-399, SUNDER

NAGRI, DELHI-110093, ground floor, first

floor and second floor respectively, which

is in your possession, within 15 days from

the date of receipt of this legal notice,

failing which my client instructed me to

initiate appropriate legal action against

you noticees totally on your costs, risks

and consequences and you noticees will be

liable to pay all the expenses of

litigations to my client.

You are also liable to pay the use and

occupation charges @ Rs.5,000/- per month

each to my client i.e. total Rs.15,000/-


jointly by all of you noticees in respect of

the said premises w.e.f. 25.05.2017 till the

vacation of the same.

You noticees are liable to pay Rs.5500/-

towards the cost of present legal notice.

Copy kept for further references in my

office.

Sanjai Premi
Advocate
M.A. ASHRAF G-505, 5th Floor, G-BLOCK
Advocate Lawyers Chambers
Karkardooma Courts,
Delhi -110032.
DELHI HIGH COURT M: - 9868649795
ENR No. D-355/1998
Ref. No. DATED: 15.04.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH. SANDEEP @ SONU
S/O SH. BABU SINGH @ BABU RAM,
R/O QR. NO.401, WHITE HOUSE,
MADHU VIHAR, NEAR KHODA SHARAB THEKA,
KHODA COLONY, NEAR MAYUR VIHAR,
PHASE-III, DELHI-110096

ALSO AT:
PLOT NO.226, KHASRA NO.275/1,
RAJDHANI ENCLAVE, NEAR SIDH BABA MANDIR,
THAKUR SAHAB BHAINS WALE,
LONI, DISTT. GHAZIABAD, U.P-201102,

Sir,
Under instructions from and on behalf of my
client namely SMT. ANGOORI DEVI, W/O SH. GIRI
RAJ SINGH, R/O D-381, GALI NO.14, SHIV VIHAR,
KARAWAL NAGAR, DELHI-110094, I hereby serve upon
you through this following legal notice, facts
as under:-
29. That you noticee was initially residing in
front of the complainant with his family.

30. That by passing the time, you noticee and


your family members have established
friendly as well as visiting terms with my
client and his family.

31. That it is relevant to point out here that


you noticee is running your business of R.O.
Filter Water and consequently in the month
of August-2012, you noticee approached to my
client and requested to lend a sum of
Rs.6,00,000/- (Rupees Six Lacs only) as a
friendly loan, as you noticee disclosed that
you wanted to increase /enhance your above
said business and you noticee disclosed that
if my client will pay you Rs.6 Lacs, then
your income will be increased to approx.
Rs.50,000/- per month.

32. That initially, my client felt uneasiness to


pay such a huge amount of Rs.6 Lacs to you
as friendly loan, but you noticee and your
family members regularly insisted my client
and his family for the same and you noticee
also assured that you will pay the interest
on the aforesaid amount at the tune of 3%
per month. Accordingly, due to regular
insistence, my client became agreed with you
noticee and in last week of September, 2012
my client withdrew Rs.7,40,000/- (Rupees
Seven Lacs and Fourty Thousand only) for
paying Rs.6 Lacs to you noticee and for his
some other requirements.

33. That consequently in the last week of


September, 2012 itself, you noticee had
borrowed a sum of Rs.6,00,000/- (Rupees Six
Lacs only) from my client in the presence of
witnesses and at the time of borrowing the
said amount, you noticee assured to my
client that the said amount would be
returned positively within 2 years and you
noticee also assured that you will pay the
interest at the tune of 3% per month to my
client till you may not return the aforesaid
amount to my client.

34. That you noticee had paid the interest to my


client only for initial five months and
thereafter you noticee had shifted to
another accommodation, as you were residing
in a rental accommodation.
35. That thereafter my client contacted with you
noticee on several occasions, then you
noticee always kept passed the time by one
pretext or the other and you also disclosed
that you also bear a great financial loss in
your business, hence on humanitarian ground
and for the sake of previous relations, my
client didn’t compel you to make the payment
of interest as well as the principal amount.

36. That since then you noticee got passed all


the period, but didn’t make any payment to
my client either towards interest or towards
the principal amount to my client despite
repeated requests and demands.

37. That finally with the intervention of the


witness and respectable persons of the
locality, my client finally exempted you
noticee from paying the interest on the
aforesaid principal amount and requested you
noticee to pay only the principal amount, on
showing pity condition by you and
consequently on 20.03.2017 you noticee in
discharge of your above said liability has
issued, signed and delivered a post-dated
cheque bearing No.908205 of dated 27.03.2017
for Rs.6,00,000/- (Rupees Six Lacs only)
drawn on Punjab & Sind Bank, branch at
Noida, Distt. G.B. Nagar, U.P. and at the
time of issuing the aforesaid cheque you
assured to my client that the said cheque
would be honoured positively at the time of
its presentation.

38. That as per your assurance and instructions


my client had firstly presented the said
cheque in his banker i.e. Punjab National
Bank, Branch at Yamuna Vihar, Delhi, but the
said cheque was dishonored by your banker
with the remarks “FUNDS INSUFFICIENT” and my
client has received the returned memo
received of dated 27.03.2017.

39. That immediately my client contacted to you


and disclosed the fact about the dishonor of
said cheque, then you noticee apologized
your guilt and requested my client to give
some more time and assured that this time
you will definitely arrange the sufficient
amount in your bank account for honouring
the said cheque.
40. That consequently my client again presented
the said cheque in his banker as per your
commitment and instructions, but it was
utter shocking for my client when the said
cheque got again dishonored by your banker
with the remarks “FUNDS INSUFFICIENT” and my
client has received the returned memo of
dated .04.2017.

41. That thereafter my client again contacted


you and revealed the reality about the
dishonor of said cheque, but you have flatly
refused to pay the said cheque amount to my
client in any manner.

42. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.6,00,000/-
(Rupees Six Lacs only) to my client within
15 days from the receipt of this legal
notice, failing which my client shall be
constrained to initiate appropriate civil as
well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.

M.A.Ashraf
Advocate
DIPESH KUMAR CHAMBER No. G-614,
ADVOCATE G-BLOCK, SIXTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
ENL. NO.D-2799/16 MOB: 9818721912
Ref. No. DATED: 15.04.2017
LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SMT. PUSHPA DEVI,
W/O LATE SH. ANIL KUMAR,
R/O 62-A, MADLYA BAGDI,
& TELI PATTI, JAFARPUR,
KALLAN VILLAGE, DELHI,

Sir,
Under instructions from and on behalf of my
client namely SH. BIJENDER KUMAR, S/O SH MANGE
RAM, R/O H.NO.41, GALI NO.3, AMBEDKAR COLONY,
NEAR DAYAL MARKET, ALIPUR, DELHI-110036, I
hereby serve upon you through this following
legal notice, facts as under:-

1. That your husband namely Late Sh. Anil Kumar


was a very good friend of my client since
long time.

2. That my client is working as Beldar in


Municipal Corporation of Delhi and your
husband was also a Govt. employee i.e.
working as Chowkidar in Government School,
Delhi under Directorate of Education, Delhi.

3. That your husband namely late Sh. Anil Kumar


was the member of Ashirwad Cooperative Urban
T/C Society Ltd., Delhi vide his Society
Account No.812 and my client is also a
member of the said society vide his Society
Account No.259.

4. That on 14.02.2004 your husband had borrowed


a loan of Rs.50,000/- (Rupees Fifty Thousand
only) from the aforesaid society namely
Ashirwad Cooperative Urban T/C Society Ltd.
And at that time your husband approached to
my client and requested him to be the
witness of the concerned documents for
obtaining loan from the said society and my
client for the sake of old friendly
relations became agreed with your husband.

5. That it is also relevant to point out here


that two other persons namely Ram Kumar, S/O
sh. Kanwal Singh and Sh. Rajender Kumar, S/O
Sh. Balkishan were stood as guarantor to the
aforesaid loan borrowed by your husband.
6. That on 11.09.2013, your husband had expired
and since then my client has no visiting
terms at your house.

7. That in the month of June-2016 my client


shocked to receive a notice from the said
society regarding non payment of loan
borrowed by your husband and my client was
cited as a guarantor instead of witness.

8. That since July-2016 the aforesaid society


i.e. Ashirwad Cooperative Urban T/C Society
Ltd. Started deducting Rs.7,000/- per month
from the salaried account of my client
illegally and unlawfully towards the
liability of your husband instead of
recovering the said amount from youyou’re
your children who are also the legal heirs
of late Sh. Anil Kumar.

9. That from July-2016 to March-2017, a sum of


Rs.63,000/- have been deducted from the
salaried account of my client by the said
society, for which you noticee is liable as
well as legally bound to repay the same to
my client, as you noticee being wife of late
Sh. Anil Kumar is liable to pay and clear
the said loan borrowed by late Sh. Anil
Kumar on his behalf.

I, therefore call upon you through this


legal notice to pay Rs.63,000/- (Rupees Sixty
Three Thousand only) to my client towards
deduction of loan borrowed by late SH. Anil
Kumar, within 15 days from the receipt of this
legal notice, failing which my client shall be
constrained to initiate appropriate civil as
well as criminal proceeding against you totally
on your costs, risks and consequences.

A copy of this legal notice has been kept in


my office for future references and records.

You are also liable to pay Rs.5500/- as


legal remuneration of this legal notice.

Dipesh Kumar
Advocate
VISHWAS AHUJA CHAMBER No.D-619,
ADVOCATE D-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
Ref. No. DATED:
LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH. DEVENDER PURI,
S/O SH. SUDERSHAN KUMAR,
R/O K-1, NEW GOBIND PURA,
GALI NO.35, NEAR SOM BAZAR,
DELHI-110051

Sir,
Under instructions from and on behalf of my
client namely SH. HARBHAJAN SINGH, S/O SH. KEWAL
SINGH, R/O J-6, NEW GOBIND PURA EXTN., DELHI-
110051, I hereby serve upon you through this
following legal notice, facts as under:-

1. That my client is engaged in the business


of promotion, development and construction
of the real estate and is well established
in this line of business.

2. That you noticee contacted my client in


the month of July-2013 and disclosed that
you are the lawful owner of the property
bearing No. K-1, Area measuring 22 sq.
yards, situated at New Gobind Pura, Gali
No.35, Near Som Bazar, Delhi-110051 by
virtue of Regd. Gift Deed dated 01.08.2013
executed by Sh. Anil Kumr, S/o Sh.
Sudershan Kumar i.e. your brother in your
favour, which is duly registered before
the office of Sub-Registrar concerned vide
Regn. No. 12,439, in Book No.1, Vol.
No.7,551 on dated 01.08.2013.

3. That you noticee was desirous to develop


and construct the your above said
property, but you were not in a position
to bear the burden of the construction,
development and supervise the construction
work at the above said property, because
of personal constraints and lack of
knowledge and experience of the
construction.

4. That it is also relevant to point out here


that you noticee have also assured that
the said property is free from all sorts
of encumbrances such as sale, gift,
mortgage, lien, loan, decree from any
court, attachment with any court etc.,
whatsoever there is no defect in its
title. If proved otherwise then you
noticee shall be responsible for all the
consequences at his own cost and risk.

5. That consequently you noticee approached


to my client to carry out the development
and construction over your aforesaid
property after demolishing the existing
structure of the said property on your
behalf.

6. That consequently an Agreement of


Collaboration dated 31st July, 2013 was
executed between you noticee and my
client.

7. That it was agreed between both the


parties that my client shall demolish the
existing construction of the above said
property and after demolition, my client
will construct the STILT PARKING, ON
GROUND FLOOR, UPPER GROUND FLOOR, FIRST
FLOOR, SECOND FLOOR, THIRD FLOOR WITH
ROOF, STAIRS FROM GROUND FLOOR TO TOP
FLOOR within a fixed period of Five Months
w.e.f. 05.08.2013.

8. That it is also relevant to point out here


that it has been agreed between the
parties specifically in para No.3 of the
Agreement of Collaboration that after the
completion of the construction work, my
client will keep the First Floor portion
upto the extent of ceiling level, area
measuring 22 sq. yards & half portion of
the second floor alongwith common stairs,
passage, entrance, and parking space on
ground floor and alongwith all common
facilities/ amenities are provided in the
building with proportionate share in the
land underneath, bearing part of the above
said property.

9. That it had also been agreed in the


aforesaid agreement of collaboration that
after the completion of two lentre work on
the above said property, you noticee will
execute and registered the transfer
documents in respect of the first floor
portion upto the extent of ceiling level
of said property in favour of my client or
his nominee/s in the office of S.R.
Concerned.

10. That it had also been agreed in the


aforesaid agreement of collaboration that
during the construction period, my client
shall have full right to re-sell his
proposed portion to the third party, and
you noticee will be bound to execute and
Regd. the transfer documents is in the
name of intending purchaser, in the office
of S.R. concerned.
11. That as per the terms of agreement, my
client approached to the concerned MCD
office for obtaining the sanction site
plan of the said property, but the same
couldn’t be completed because of some
technical difficulties and then finding no
other option, my client approached to you
noticee and disclosed the said fact to you
noticee and requested you noticee to
obtain the sanction site plan, but all
went in vain despite your own efforts,
then it has been orally agreed between you
noticee and my client that the
construction will be raised by my client
without any sanctioned site plan and all
the construction work was done in the
presence and under the supervision of you
noticee.

12. That it is also relevant to point out here


that you noticee has also told my client
that the ground floor portion of the said
property will be left as hall instead of
parking space and my client being already
spent a huge amount had no other option,
but to accept your proposal.
13. That the construction work was going on in
full swing and my client spent his hard
earned money over the construction work,
but you noticee failed to perform your
part of contract as agreed in para no.5 of
the aforesaid collaboration agreement i.e.
you noticee have failed to execute the
Regd. Sale documents in favour of my
client in respect of complete first floor
upto the extent of ceiling level after
completion of two lentre work and when my
client requested to you noticee for the
same, as my client entered into an
agreement to sell/bayana dated 21.10.2013
in respect of first floor with some buyers
namely Manvinder Singh, Rakesh Chauhan and
Smt. Nirmal Arora, then you noticee told
my client that you will execute the final
sale deed directly in favour of the said
buyers and my client again agreed with
you.

14. That it is also important to note here


that your brother namely Anil Kumar was
duly remained present at the said
construction site alongwith you for the
purpose of supervision etc. and he didn’t
raise any objection at any point of time.

15. That consequently you noticee executed a


Regd. Sale Deed directly in favour of
Manvinder Singh, Rakesh Chauhan and Smt.
Nirmal Arora in respect of the first floor
portion of the said property, which was
under the lawful right of my client and
consequently the possession of the first
floor was handed over to the said buyers.

16. That thereafter when the 99% of the


construction work was completed, my client
has shocked to know that a Civil suit
titled as “Anil Kumar Vs. Devender Kumar
Puri”, was filed by the brother of you
noticee namely Sh. Anil Kumar against you
noticee and EDMC concerned with the
malafide intention and ulterior motives to
get the order of stay of construction work
on the said property on the basis of
falsely and frivolous facts and averments.

17. That consequently the Hon’ble court has


pleased to passed an order thereby
granting stay on the aforesaid property
and due to the aforesaid reason, the said
buyers, who have purchased the first
floor, have lodged an FIR No.522/2015, U/s
420/506/34 IPC, at P.S. Jagatpuri, Delhi
against my client and you noticee, while
the fact remains that your brother namely
Anil Kumar was always present during the
whole construction work but had never
raised any objection, but when he saw the
almost 99% of construction has been done,
then you noticee within the collusion of
your brother got filed a civil suit only
curtail the legal right of my client and
the same resulted into a huge financial
loss to my client, as my client has
settled the matter with the said buyers in
a sum of Rs.12 Lacs and my client has
already paid Rs.9 Lacs to them.

18. That despite completion of construction


work you noticee has also failed to
execute the final sale documents of the
half portion of the second floor of the
said property nor you have handed over the
possession of the same till date, which
you are legally liable as well as bound to
perform your part.
19. That my client has also suffered a great
financial loss because he has invested his
hard earned money over the construction of
the said property in question.

I, therefore call upon you through this


legal notice to handover the peaceful vacant
possession of the second floor of the said
property in favour of my client and also to
execute the Regd. Sale documents in favour
of my client in respect of first floor and
second floor portion of the said property
for performing the part of your contract,
within 15 days from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.

This is further informed for your kind


notice that my client is also reserves his
right to claim damages from you noticees in
the competent court of law.
A copy of this legal notice has been
kept in my office for future references and
records.

You are also liable to pay Rs.11,000/-


as legal remuneration of this legal notice.

J.P. SINGH Seat No.E-43, E-Block, G.Floor


Advocate Karkardooma Courts,
Delhi-110032.
ENR No.UP3539/2000 M: - 9971178128
Ref: Date: .04.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH SONU
S/O SH KISHAN,

2. SH. AJAY,
S/O SH. KISHAN,

3. SMT. MEENA,
W/O SH. SONU,

4. SMT. SHIVANI,
W/O SH. AJAY,

ALL R/O H.NO.252, NEW NO.B-38,


2ND FLOOR, GALI NO.6,
NEW SABHAPUR GUJRAN, DELHI
Sir/Madam,
Under instructions from and on behalf of my
client namely SH KISHAN, S/O SH. TARIF, R/O
H.NO.252, NEW NO.B-38, GALI NO.6, NEW SABHAPUR
GUJRAN, DELHI, I hereby serve upon you through
this following legal notice, facts as under:-

37. That you noticee No.1 & 2 are the real son
of my client and you noticee No.3 and 4
are the daughter-in-laws of my client,
being wife of noticee No.1 & 2
respectively.

38. That you both the noticees are regularly


harassing and humiliating my client by
your illegal, and incooperative acts and
activities and being real sons and
daughter-in-laws, you noticees are not
caring and helping my client and want to
capture the property of my client within
the collusion and by hatching the
conspiracy with the family members of the
noticee No.3 & 4 respectively.

39. That very often since beginning, you


noticee No.1 to 4 used to quarrel with my
client on minor issues or the others. And
you noticee No.1 to 4 have threatened my
client that you will implicate my client
and his family members in any false
criminal case and since then my client
always remained in great tension.

40. That on 02.04.2017, at about 8:00 PM you


all the notices have come to my client and
started abusing my client in filthy and
abusive language by saying that “BUDDHE
TUJHE HAM ZINDA NAHIN CHHODENGE AUR TUJHE
KISI JHUTE CASE MEIN FANSAKAR JAIL MEIN
SADWA DENGE”, which clearly reflects that
you noticees have established ill
intention to grab the above said property
of my client illegally and unlawfully.

41. That my client is the owner of the


property bearing No. 252, NEW NO.B-38,
GALI NO.6, NEW SABHAPUR GUJRAN, DELHI,
measuring 85 sq. yards, and the said
property is the self-acquired by my client
from his own funds, sources and earnings
and status of you all the noticees in the
said property is only as a licencees.

42. That you all the noticees No.1 to 4 due to


dishonest intention humiliating and
torturing to my client by one pretext and
another at every moment, due to all these
circumstances and seeing the behaviour of
you noticee No.1 to 4, my client have
debarred you all noticees No.1 to 4 by way
of publication of public notice in daily
Newspaper Rashtriya Sahara dated
04.03.2017. The copy of said publication
is enclosed herewith.

43. That after publishing the said debarred


notice, my client have broken all the ties
and relations with you addressee No.1 to 4
and hence you noticee No.1 to 4 have no
right to stay in the above said property
of my client any more in any manner.

44. That my client do not wish to permit you


addressees No.1 to 4 to live in the said
property No.252, NEW NO.B-38, 2nd FLOOR,
GALI NO.6, NEW SABHAPUR GUJRAN, DELHI in
respect of portion which is in your
possession i.e. second floor. You are
further required to be noted that my
client have terminated your living
capacity/locus standi in said premises,
therefore you noticee No.1 to 4 have no
right to stay in the property of my client
and you Noticee no.1 and 2 on your behalf
as well as on behalf of notice No.3 and 4
are liable to pay occupational charges @
Rs.5,000/- per month each i.e. Rs.10,000/-
per month w.e.f. 15.05.2017 and now you
are living in the said property as
unauthorized occupants.

45. That it is relevant to mention here that


when you noticees came to know that my
client have debarred you noticees from
their all moveable and immoveable
properties, then you noticees have abused
my client in filthy and abusive language
and threatened my client to implicate them
in some false criminal cases and due to
the said reason, my client are under great
terror and fear from you noticees.

46. That despite knowledge and information


regarding debar publication and several
oral requests for vacating of the portion
of the above said property in your
possession, you both did not pay any heed
and also not bothered to vacate the
portion in your possession till date,
hence this notice.
I, therefore call upon you through this
legal notice that you noticee No.1 to 4 to
vacate the premises of my client i.e. 252,
NEW NO.B-38, GALI NO.6, NEW SABHAPUR GUJRAN,
DELHI in respect of portion which is in your
possession, within 15 days from the date of
receipt of this legal notice, failing which
my client instructed me to initiate
appropriate legal action against you noticee
No.1 and 2 totally on your costs, risks and
consequences and you noticee No.1 and 2 will
be liable to pay all the expenses of
litigations to my client.

You noticee No.1 and 2 on your behalf


and on behalf of noticee No.3 and 4 are also
liable to pay the use and occupation charges
@ Rs.5,000/- per month each i.e. total
Rs.10,000/- to my client in respect of the
said premises w.e.f. 15.05.2017 till the
vacation of the same.

You noticees are liable to pay Rs.5500/-


towards the cost of present legal notice.

Copy kept for further references in my


office.
J.P. Singh
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: 13.04.2017

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
M/S S.K. TYRE HOUSE
Through its Prop./A.R.
Mr. Sanjay Kumar,
AT: C-184, Aram Park,
Khureji Main Road, Delhi-110031

Sir,
Under instructions from and on behalf of my
client M/s SOAMI POWER SOLUTIONS, THROUGH ITS
PROP. SMT RAJNI NAGPAL, W/o SH. O.P. NAGPAL, AT:
25/6, OPP. MUTHOOT FINANCE, VISHWAS NAGAR,
DELHI-110032, I hereby serve upon you through
this following legal notice, facts as under:-

8. That my client is doing the business of


supply of tyres in the name and style of
M/s Soami Power Solutions and running its
office at the above given address.
9. That you noticee is the regular customer
of my client and you noticee used to
purchase two wheeler tyres from my client
against various invoices/bills from
01.04.2016 to 31.03.2017 from my client.

10. That as per the statement of account


maintained by my client, you noticee have
purchased the two wheeler tyres in the
aforesaid period i.e. 01.04.2016 to
31.03.2017 for a sum total of
Rs.1,18,055/-, out of which Rs.58,228/-
are still outstanding on you noticee.

11. That in discharge of your above said part


liability against the purchase of
abovesaid two wheeler tyres, you noticee
have issued two cheques bearing No.000180
of dated 22.12.2016 of Rs.25,800/-, and
cheque bearing No.000208 of dated
23.03.2017 for Rs.30,250/- both drawn on
HDFC Bank Ltd., branch at Priyadarshani
Vihar, New Delhi and at the time of
issuing the aforesaid cheques, you noticee
assured to my client that the said cheques
would be honoured positively at the time
of its presentation in its banker.
12. That consequently as per your assurances
and as per your instructions, my client
has lastly deposited the said cheques in
its banker i.e. Kotak Mahindra Bank Ltd.
Branch at Aditya Mall, CBD, Shahdara,
Delhi-110032, but the said both cheques
were dishonoured by your banker with the
remarks “FUNDS INSUFFICIENT”, and my
client received the information through
returning memos dated 18.03.2017 and
27.03.2017 respectively.

13. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheques and my client
demanded the said cheques amount in cash
from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment
of the said cheques, you have flatly
refused to pay the said cheques amount to
my client in any manner.

14. That you for discharging your part


liability, issued, signed and delivered
the abovesaid cheques, which was
dishonored by your banker and thus you
breached the trust of my client and
committed an offence punishable under
Section 138 of N.I. Act.

I, therefore call upon you through


this legal notice to make the payment of
the aforesaid dishonoured cheque i.e.
Rs.56,050/- (Rupees Fifty Six Thousand and
Fifty only) to my client within 15 days
from the receipt of this legal notice,
failing which my client shall be
constraint to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/-


as fee of this legal notice.

Copy kept in my office for further


references.

PANKAJ BHUSHAN
ADVOCATE
Ajay Kumar Bansal Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1072/2000 M:- 9811251442
Ref. No. DATED: 11.04.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
The Manager,
TATA AIG General Insurance Company Ltd.
At: 301-308, Third Floor,
Aggarwal Prestige Mall,
Plot No.2, Road No.44,
Near M2K Cinema, Rani Bagh,
Pitampura, New Delhi-110034

Sir,
Under the instructions from and on behalf of

my client Sh. Mohd. Talha, S/O Sh. Mohd. Nazir,

R/O B-139, Welcome Colony, Seelampur, Delhi-

110053, I hereby serve upon you with the

following legal notice:

11. That my client had purchased a vehicle i.e.

Motorcycle Yamaha R15 bearing its

Registration No.DL5SAQ-9571 Model 2016.


12. That the said vehicle was duly insured with

you noticee vide Policy/Cover Note No.

0120029678 valid w.e.f. 01.01.2016 to

31.12.2016.

13. That on 03.10.2016 in the noon, the above

vehicle of my client was theft under the

jurisdiction of P.s GTB Enclave and in this

regard an E-FIR vide No.029113 dated

03.10.2016 was registered at P.s E-Police

Station, Distt. Crime Branch.

14. That my client has duly informed to your

concerned agent in regard of the theft of

the said vehicle just on the next day of the

said incident.

15. That my client as well as the concerned

police officials have tried their level best

to somehow trace the said vehicle, but all

went in vain.
16. That thereafter my client has applied to you

noticee for getting the insurance claim of

his said vehicle and accordingly my client

has completed all the formalities and

requirements for obtaining the insurance

claim and accordingly the insurance claim

was passed and my client was called for

receiving the aforesaid insurance claim.

17. That consequently my client approached to

your concerned office for receiving the

insurance claim of his above said vehicle,

then my client was told by your concerned

officials that the insurance claim will be

disbursed in favour of my client only after

some deduction and when my client opposed

the same that why your concerned officials

are deducting the money from the insurance

claim of my client illegally and unlawfully,

then they have flatly told my client to


approach to the concerned court for taking

the complete insurance claim. It is also

relevant to point out here that the ill

intention of you noticee is clearly reflects

from the fact that you noticee have sent a

letter dated 08.12.2016, which does not

relates to my client in any manner and even

facts are contradictory.

18. That this is clear cut deficiencies on part

of you noticee and unfair trade practice, as

you noticee are deducting the amount from

the insurance claim of my client

intentionally and deliberately without

having any right, title or interest.

19. That my client has been suffered from a

great mental harassments, pain and agony

only because of illegal and unwarranted

acts.
20. That you noticee is liable to compensate my

client in a sum of Rs.2 Lacs as compensation

for mental and physical torture pain and

agony, hence this notice.

I, therefore call upon you through this


legal notice to release the complete insurance
claim of the vehicle of my client and to
compensate my client in a sum of Rs.2 Lacs for
as compensation for mental and physical
torture pain and agony and to pay the same to
my client, within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

Ajay Kumar Bansal


Advocate
Ajay Kumar Bansal Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1072/2000 M:- 9811251442
Ref. No. DATED: 11.04.2017

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
Sh.Sunil Kumnar Sharma
Advocate,
AT: Seat Behind Court #31,
Near Police Post,
Tis Hazari Courts, Delhi-110054

Sir,
My clients (1) Mrs. Nafisa, W/o Mr. Fahim
Ahmed, (2) Mr. Fahim Ahmed, S/o Late Shafiq
Ahmed, Both R/o H.No.E-49/D-57, Janta Colony,
Welcome, Shahdara, Delhi-110053 has placed
before me your legal notice dated 22.03.2017
sent by you on behalf of your client Mr. Atiq
Ahmed, S/o Late Shafiq Ahmed, R/O H.No.2427,
Ejaj Building, Ballimaran, Baradari, Delhi-
110006, and my clients instructed me to give the
reply of the same and brought true facts into
your knowledge, which facts are as under:-

At the outset, it is respectfully submitted


that the contents of whole of your legal notice
are denied specifically until and unless the
same are not being specifically admitted in the
present reply.

PRELIMINARY OBJECTIONS:-
59. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.

60. That your client did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

61. That the true fact is that before the year


1983, my clients and one Mr. Anil Kumar have
jointly taken the possession of the above
said property bearing No. E-49/D-57, Janta
Colony, Welcome, Shahdara, Delhi-110053 and
since then they were residing in the said
property. However thereafter in the year
1991 my clients have made a cash payment of
Rs.22,000/- (Rupees Twenty Two Thousand
only) from their own funds, earnings and
savings to the said Sh. Anil Kumar towards
his share in the said property and since
then my clients are in the sole and absolute
uninterrupted possession of the said
property.

62. That it is also relevant to point out here


that from time to time my clients have duly
raised construction over the said property
and built the same upto 3rd floor from their
own funds and expenses till 2014.

63. That it is also pertinent to mention here


that all the other family members of my
clients were already residing separately
from my clients and have no right, title or
interest over the said property in any
manner, as my clients have lawfully acquired
the said property with their own funds,
earnings and savings.

64. That your client got sent the present false


and frivolous legal notice only to extort
money from my clients and if any documents
in regard to the ownership of the said
property in favour of your client, the same
are forged and fabricated, as your client is
involved in fabricated false documents of
properties by illegal means.
REPLY ON MERITS:-
1-2. That the contents of Para No.1 & 2 of your
legal notice are wrong, false, and
concocted, hence denied. However, it is
submitted that your client is neither
earning since the age of 13 years nor the
said property was purchased in the year
1999. It is submitted that your client or
any other person have no right, title or
interest in the said property in any manner.
It is further submitted that your client
even does not knows that in which year the
said property was purchased.

3-4. That the contents of Para No.3 & 4 of


your legal notice are wrong and denied.
However, it is submitted that all the
averments and versions as alleged in the
paras under reply are nothing, but an ill
tactics only to create false evidences
against my client, and the same is total
bunch of lies nothing else. It is further
submitted that if any documents in regard to
the ownership of the said property in favour
of your client, the same are forged and
fabricated, as your client is involved in
fabricated false documents of properties by
illegal means. The contents of whole
Preliminary Objections may be read as part
and parcel as reply of this Para, same are
not being reproduced herein for the sake of
brevity.

5-6. That the contents of Para No.5 & 6 of


your legal notice are wrong and denied.
However it is submitted that when the mother
of my client no.2 was not the owner of the
said property, then the question of
permitting by her to my clients to reside in
the said property as licensee does not arise
at all in any manner. It is further
submitted that this story is nothing, but to
create false evidence. It is further
submitted that when the mother of my client
no.2 as well as your client have no right,
title or interest over the said property,
then the question of termination of license
of my client does not arise at all in any
manner.

I, therefore request you through this


reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my clients
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.

Your clients are also liable to pay


Rs.5500/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

Ajay Kumar Bansal


Advocate
SEEMA DOGRA Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1968/99 M:- 9810893021
Ref. No. DATED: 06.04.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH YOGESH KUMAR,
S/O SH. HARI RAM,
R/O 148, VILLAGE GHONDLI,
NEAR VALMIKI MANDIR, KRISHNA NAGAR,
DELHI-110051

Sir,
Under instructions from and on behalf of my
client SH. PARVEEN VAID, S/O SH. SOHAN PAL, R/O
K-14, BLOCK-K, KRISHNA NAGAR, DELHI-110051, I
hereby serve upon you through this following
legal notice, facts as under:-

43. That you and my client having good


friendly relations with each other since
long time.
44. That consequently in the month of
October-2016, you approached to my client
and requested to arrange a cash of
Rs.25,000/- (Rupees Twenty Five Thousand
only) as a friendly loan by showing your
urgent need of money, and my client could
have only arranged a sum of Rs.22,500/-
(Rupees Twenty Thousand Five Hundred only)
and accordingly my client had handed over to
the sum of Rs.22,500/- (Rupees Twenty
Thousand Five Hundred only) to you noticee
and at the time of borrowing the aforesaid
amount, you assured to my client that the
said amount would be returned positively
within two months.
45. That thereafter my client has approached
to you noticee in the mid of January-2016,
and demanded the said friendly loan amount
of Rs.22,500/- (Rupees Twenty Thousand Five
Hundred only), then in discharge of your
above said liability, you issued, signed and
delivered a cheque bearing No.912161 of
dated 06.02.2017 of Rs.22,500/- drawn on
State Bank of India, Branch at: Krishna
Nagar, Delhi, and at the time of issuing the
aforesaid cheque you assured to my client
that the said cheque would be honoured
positively at the time of its presentation.
46. That as per your assurance and
instructions my client had firstly presented
the said cheque in his banker i.e. Union
Bank of India, Branch at Chander Nagar,
Delhi, but the said cheque was dishonored by
your banker with the remarks “FUNDS
INSUFFICIENT” and my client has received the
returned memo received of dated 08.02.2017.
47. That immediately my client contacted to
you and disclosed the fact about the
dishonor of said cheque, then you noticee
apologized your guilt and requested my
client to give some more time and assured
that this time you will definitely arrange
the sufficient amount in your bank account
for honouring the said cheque.
48. That consequently on 29.03.2017 my
client again presented the said cheque in
his banker as per your commitment and
instructions, but it was utter shocking for
my client when the said cheque got again
dishonored by your banker with the remarks
“FUNDS INSUFFICIENT” and my client has
received the returned memo of dated
29.03.2017.
49. That thereafter my client again
contacted you and revealed the reality about
the dishonor of said cheque, but you have
flatly refused to pay the said cheque amount
to my client in any manner.
50. That for discharging your liability, you
issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.22,500/-
(Rupees Twenty Thousand Five Hundred only)
to my client within 15 days from the receipt
of this legal notice, failing which my
client shall be constrained to initiate
appropriate civil as well as criminal
proceeding against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Seema Dogra
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: 06.04.2017

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
SH R.S. JUNEJA
ADVOCATE,
AT: D-516, LAWYERS CHAMBERS,
KARKARDOOMA COURTS, DELHI

Sir,
My clients (1) Sh. N.K. Pahuja, S/O Late Sh.
T.C. Pahuja, (2) Smt. Suman Pahuja, W/O Sh N.K.
Pahuja, Both R/o 235, Surya Niketan, Delhi-
110092 has placed before me your legal notice
dated 30.03.2017 sent by you on behalf of your
clients Sh. Sunil Sood, S/O Late Sh. J.K.L. Sood
and Smt. Sanjla Sood, W/O Sh. Sunil Sood, both
R/o 15-D, MIG Flats, Shivam Enclave, Pocket-C,
Jhilmil, Delhi-110095, and my clients instructed
me to give the reply of the same and brought
true facts into your knowledge, which facts are
as under:-
PRELIMINARY OBJECTIONS:-
65. That the legal notice sent by you is based
on wrong and false information, supplied by
your clients to you, therefore the present
notice is liable to be withdrawn.

66. That your clients did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my clients through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

67. That the true fact is that my clients and


your clients have entered into a Lease Deed
on dated 17.06.2015 in respect of the
property bearing No.235, Surya Niketan,
Delhi-110092.

68. That consequently your clients have


deposited with my clients a sum of
Rs.1,26,000/- as interest free advance/
security which was agreed to be refunded at
the time of vacation of the said tenanted
premises after deduction of any dues,
charges etc. if any occurred.
69. That consequently your clients have vacated
the said tenanted premises and at that time
my clients have paid Rs.26,000/- (Rupees
Twenty Six Thousand only) in cash to your
clients which was duly received by your
clients in the presence of one Sh. Prateek
and at the same time, my clients have also
issued a cheque bearing No.265456 dated
08.03.2017 of Rs.50,000/-, drawn on Axis
Bank Ltd. branch at Krishna Nagar, Delhi,
which was duly honoured in your account.

70. That it is also relevant to note here that


at the same time, it was also agreed between
your clients and my clients that your
clients are also liable to pay Rs.7,000/- to
my clients towards maintenance and charges
of fittings and fixtures which was duly
agreed by your clients and by virtue of
which a sum of Rs.43,000/- (Rupees Fourty
Three Thousand only) are liable to be paid
by my clients to your clients which my
clients are still ready and willing to pay
to your clients, but it is your clients, who
instead of receiving the same amount from my
client, has sent the present false legal
notice through your good self only to extort
more money from my clients, which is illegal
and unwarranted.

REPLY ON MERITS:-
1-2. That the contents of Para No.1 & 2 of your
legal notice are matter of records. However,
it is submitted that the contents of whole
Preliminary Objections may be read as part
and parcel as reply of this Para, same are
not being reproduced herein for the sake of
brevity.

3. That the contents of Para No.3 of your legal


notice are matter of records. However, it is
submitted that the contents of whole
Preliminary Objections may be read as part
and parcel as reply of this Para, same are
not being reproduced herein for the sake of
brevity.

4. That the contents of Para No.4 of your legal


notice are partly matter of records and rest
of the para is wrong and denied upto the
extent of Rs.76,000/- is due upon my
clients. However, it is submitted that my
clients are only liable to pay Rs.43,000/-
to your clients as per the above schedule of
payments, as detailed in the corresponding
paras of the preliminary objections and the
contents of whole Preliminary Objections may
be read as part and parcel as reply of this
Para, same are not being reproduced herein
for the sake of brevity.

5. That the contents of Para No.5 of your legal


notice are wrong and denied. It is
specifically denied that my clients have
committed a breach of trust of your clients
while not returning the amount of
Rs.76,000/- immediately at the time of
handing over the possession which is
punishable under the criminal law. However,
it is submitted that your clients by sending
the present false and frivolous legal
notice, rendered themselves liable to be
prosecuted for fraud and cheating with my
clients by claiming excess amount despite
receiving the same, for which my clients
reserved their rights to initiate
appropriate legal action against your
clients in the competent court of law. The
contents of whole Preliminary Objections may
be read as part and parcel as reply of this
Para, same are not being reproduced herein
for the sake of brevity.

I, therefore request you through this


reply to advise your clients to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my clients
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your clients totally on
the costs, risks and consequences of your
clients.

Your clients are also liable to pay


Rs.5500/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

Pankaj Bhushan
Advovcate
CC:
1. Sh. Sunil Sood,
S/O Late Sh. J.K.L. Sood

2. Smt. Sanjla Sood,


W/O Sh. Sunil Sood,
Both R/o 15-D, MIG Flats,
Shivam Enclave, Pocket-C,
Jhilmil, Delhi-110095

Vijaya Tyagi Resi-Cum-Off: 1020, Janta Flats


ADVOCATE GTB Enclave, Dilshad Garden
Delhi-110095
DELHI HIGH COURT
EN. No. D-1459/2007 M:- 9990698323
Ref. No. DATED: 02.03.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SMT NEELAM
W/o SH ABHISHEK KUMAR,
D/o SH GHUREY LAL,
R/o H.No.E-18 B/633, E-BLOCK,
AMAR COLONY, EAST GOKALPUR,
DAYALPUR, DELHI-110094

Sir,
Under instructions from and on behalf of my
client SH ABHISHEK KUMAR, S/o SH RAMANAND
CHAUHAN, R/o H.No.110, GALI No.4, AMBEDKAR
VIHAR, JOHRIPUR, DELHI-110094, I hereby serve
upon you through this following legal notice,
facts as under:-

1. That the marriage between my client and


you noticee was solemnized in the month of
26.08.2013 and the said marriage of the
parties was a love marriage registered
with the Registrar of Marriage.
Thereafter, the mother of my client after
knowing about the said fact got solemnized
the marriage of the parties publically on
15.12.2013 and brought you noticee to the
matrimonial home.

2. That the marriage was duly consummated


between the parties but no child was born
out from the said wedlock.

3. That after one month of the marriage, you


noticee started residing separately
alongwith my client at the upper floor of
the matrimonial house.

4. That since August, 2016 you noticee is


residing separately at her parental home
and my client as well as his parents made
several efforts to bring back you noticee
to her matrimonial home, but all went in
vain.

5. That you noticee and her family members


started making pressure upon my client and
his family members to give Rs.5 Lac in
cash, due to which my client and his
family members started following the
directions of you noticee and her family
members, so that all the things would
remain normal.

6. That due to the threats given by you


noticee and her family members, my client
and his family members are under great
fear and my client is having every
apprehension that you noticee and his
family members may implicate my client or
his family members in any false Criminal
case or may kill them at any point of
time. If any such incident may takes place
in future at any point of time with my
client or his family members, then you
noticee and her family members shall be
entirely responsible for the same.

7. That you noticee is running your own


beauty parlour in Dilshad Garden and
earning handsome amount to maintain
yourself.

8. That my client is still in a great love


and affection with you noticee and my
client is living alone without you and has
no hope of his life, except to bring back
you noticee and the life of my client
became hell without you noticee.

9. That my client visited at your parental


home to bring you back and requested you
to join the society of my client, but you
have flatly refused to join the
matrimonial life with my client, despite
my client tried his level best to sort out
the matter on several occasion, but all
gone in vain.

I, therefore call upon you through this


legal notice that kindly join the society of
my client, within 07 days from the receipt
of this legal notice, failing which my
client shall be constrained to initiate
appropriate legal action against you in the
competent court of law.

Copy kept for further reference in my


office.

VIJAYA TYAGI
ADVOCATE
JAGDISH CHANDRA Seat No.D-9,
ADVOCATE Saraswati Hall, First Floor,
Delhi High Court Karkardooma Court
Enrl. No.D-1106/99 Complex, Delhi-110032
(M) No.9810741639
Ref. No. DATED: 01.03.2017

REPLY TO LEGAL NOTICE


REGD. A.D./SPEED POST
To,
SH R.K. SHARMA
ADVOCATE
CH. No.516A, WESTERN WING,
TIS HAZARI COURTS, DELHI-110054

Sir,
Under the instructions from and on behalf of
my client (1) SH VIPIN KUMAR, S/o SH ASHOK
KUMAR, R/o A-15, GALI No.2, MANDOLI EXTN.,
DELHI-110093, (2) SMT DURGESH, W/o SH VIPIN
KUMAR, R/o A-15, GALI No.2, MANDOLI EXTN.,
DELHI-110093, I do hereby serve upon you reply
to your Legal Notice dated 14.02.2017, which was
served to my client through this following legal
notice, true facts and the reply are as under:-

PRELIMINARY OBJECTIONS:-
1. That Ashok Kumar is the father and father-
in-law of addressee No.1 & 2, who is Govt.
Servant doing his service in DTC, Delhi.
2. That your client given false and wrong
information and also mislead and concealed
all the true, correct and actual facts
before you including the relationship
between your client and my clients no
dealing has ever been done between your
client and father of my client No.1 at any
point of time, hence the notice is not
maintainable in the eyes of law, therefore
your client is liable to be prosecuted
under the penalized law of IPC
accordingly.
3. That on 05.05.1989 a dealing has been done
between father of my client No.1 namely
Ashok Kumar and Smt. Kaushalya Devi about
the land measuring area 100 Sq. Yds., out
of Kh. No.381 situated at Village Mandoli,
Illaqa Shahdara, Delhi (now MCD No.A-15,
Gali No.2, Mandoli Extn., Delhi-110093),
in the consideration amount of
Rs.20,000/-. After receiving a sale
consideration amount of Rs.20,000/- by
said Kushalya Devi, W/o Sh. Veerpal Singh
from Ashok Kumar then said Kaushalya Devi
executed all relevant documents of said
land in favour of said Ashok Kumar before
concerned Sub-Registrar-IV, Seelampur,
Delhi vide registration No.21813, Volume
No.2227 on page No.160 dt. 05.05.1989.
After completion of all formalities about
the property in question said Smt.
Kaushalya Devi handed over all documents,
peaceful possession as well as all rights
and title of the said land to buyer Sh.
Ashok Kumar.
4. That the father of my client No.1
constructed/built up 3 rooms, toilet,
bathroom & kitchen from his own funds and
earnings on the said land. Being the
absolute owner above said Ashok Kumar has
been started to live alongwith his family
members on the said property. Mr. Ashok
Kumar also installed a electricity meter
on the property in question in his name
and also regularly paid the electricity
bill, house tax etc. to the concerned
authority. The family member and Ashok
Kumar also got prepared old Aadhar Card,
Voter I.D. Card, Gas Connection etc. at
the address of the said property in
question and the same are in possession of
my clients for kind perusal of the record.
5. That from the date of purchase i.e.
05.05.1989 the father of my client No.1
was and is the absolute owner and has
every right, title and interest/possession
in the said property in question till
date, hence no question arise about the
selling out the property in question to
Satish Kumar or to any person in any
manner. It is pertinent to mention here
that Ashok Kumar (father of my client
No.1) never sell out the said property to
anyone or to your client at any point of
time. In this regard, neither any single
penny had ever been received nor any
documents have ever been executed at any
point of time in favour of your client. If
any paper has been prepared by your client
in his favour in respect of the same are
forged, fabricated, vogue and concocted
one only to create false evidence.
REPLY ON MERITS:-
1.That the contents of Para No.1 of the legal
notice need no reply being matter of
record.
2.That the contents of Para No.2 of the legal
notice are admitted except the
consideration amount of Rs.2 Lac. It is
submitted that the father of my client
No.1 namely Sh. Ashok Kumar had purchased
the abovesaid property in a total sale
consideration of Rs.20,000/- from Smt.
Kaushalya Devi on 05.04.1989, your client
intentionally and deliberately given the
false sale consideration of Rs.2 Lac and
also given false statement in Para No.5 of
the legal notice about the relationship,
hence your client is liable to be
prosecuted before the competent Court of
law in respect of giving false and
fabricated information during the course
of judicial proceedings under the
penalized law. It is further submitted
that the preliminary objections may kindly
be read as part and parcel of this Para
under reply, which are not being repeated
herein for the sake of brevity.
3.That the contents of Para No.3 of the legal
notice are wrong and vehemently denied. It
is submitted that the relationship between
my client No.1 and your client, so that
the father of my client namely Ashok Kumar
allowed to remain your client for time
being at the property in question, because
your client was unemployed, due to good
and family relations, your client is very
well known everything about the family of
my clients. During the stay period of your
client, your client took the original
papers of the property in question without
the knowledge and consent of the father of
my client No.1 and other. Subsequently,
the father of my client No.1 asked,
enquired and demanded his original
documents from your client on several
occasions, but your client intentionally
and deliberately avoided the same. Finding
no other alternative, the father of my
client No.1 being the absolute owner lodge
the written complaints to the concerned
higher Police authorities for the
misconduct, misappropriation, cheating,
extortion, forgery etc. against your
client, hence your client is liable to be
prosecuted and punished under the penalize
of IPC. It is further submitted that the
preliminary objections may kindly be read
as part and parcel of this Para under
reply, which are not being repeated herein
for the sake of brevity.
4.That the contents of Para No.4 of the legal
notice are wrong and denied. It is
submitted that your client has no
knowledge about the date, month and year
for the construction and other things etc.
It is further submitted that the
preliminary objections may kindly be read
as part and parcel of this Para under
reply, which are not being repeated herein
for the sake of brevity.
5.That the contents of Para No.5 of the legal
notice are wrong and denied. It is
submitted that your client given a bogus
relationship in the present notice
fraudulently and deliberately. It is
further submitted that the preliminary
objections may kindly be read as part and
parcel of this Para under reply, which are
not being repeated herein for the sake of
brevity.
6.That the contents of Para No.6 of the legal
notice are wrong and denied. It is
submitted that my clients are residing at
the property in question alongwith their
other family members since more than 4
years and in this regard my clients are
having their Election Cards, Aadhar Cards
& Ration Card of the said address. It is
further submitted that the preliminary
objections may kindly be read as part and
parcel of this Para under reply, which are
not being repeated herein for the sake of
brevity.
7.10. That the contents of Para No.7-10 of the
legal notice are wrong and denied. It is
submitted that all the portion of the
property in question except one room in
the continuous possession since 05.05.1989
to till date except one room, which is
used by your client only as licensee/
permissive user for time being only. It is
further submitted that as and when the
father of my client No.1 asked to vacate
the said room, but your client kept on
passing the time on one pretext or the
other. It is further submitted that the
preliminary objections may kindly be read
as part and parcel of this Para under
reply, which are not being repeated herein
for the sake of brevity.

Thus, your client committed the


offences of criminal conspiracy to extort
the money and grab the property in
question by making the false, bogus,
forged documents in respect of the
property in question in his favour by way
of malafide intention, dishonestly and
fraudulently.

I, therefore request you through this


reply to advise your client to withdraw
the present false, fabricated and
concocted notice immediately from the
receipt of this reply of your notice,
otherwise my client will defend the same
with all possible measures laid down in
law and shall also be constrained to
initiate appropriate separate legal action
against your client totally on the costs,
risks and consequences of your client.

Copy kept in my office for further


future references.

JAGDISH CHANDRA
ADVOCATE
SEEMA DOGRA Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1968/99 M:- 9810893021
Ref. No. DATED:

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SH MAHESH CHAND YADAV,
S/O LATE SH NATHU SINGH YADAV,
R/O E-1/309, GALI NO.6,
NEHRU VIHAR, DELHI-110094

Sir,
Under instructions from and on behalf of my
client SMT. KIRAN YADAV, W/O SH. PUNIT YADAV,
R/O E-1/309, GALI NO.6, NEHRU VIHAR, DELHI-
110094 I hereby serve upon you through this
following legal notice, facts as under:-

71. That my client got married with Sh. Punit


Yadav (son of you noticee) on 02.12.2010
according to Hindu rites and customs and in
the said marriage, the parents of my client
have spent a huge amount in the marriage,
but despite that you noticee and the husband
of my client were not happy with the same
and they used to harass and humiliate my
client even on petty issues.

72. That you noticee and your other family


members usually used to harass and humiliate
my client and taunted her on petty issues
even the husband of my client used to abuse
the parental family members of my client by
sending vulgar messages to them and also
extended threats to face dire consequences.

73. That despite all these, my client kept on


living only in the hope that after the birth
of child, all will be fine, but all the
hopes and dreams of my client were ruined,
because despite the birth of two children
namely Divya @ Mahi, aged about 5½ years and
Vansh @ Himanshu aged about 02 years, the
attitude and behavior of you noticee and his
other family members were not changed.

74. That you noticee and your family members


have raised the demand from my client to pay
cash and due to the said continuous threats
and compelling circumstances, the parental
family members of my client have paid
various cash amount to you noticee time to
time.

75. That a mediation was held between both the


parties on 11.07.2013 before the Delhi Govt.
Mediation & Conciliation Centre, Delhi,
wherein it was agreed that you noticee and
his other family members will keep my client
happily and will not cause and mental and
physical tortures to her, but all went in
vain.

76. That thereafter in the month of May-2016 an


oral Agreement to Sell cum oral settlement
was held between my client and you noticee
and it was agreed that my client or her
parental family members shall pay a total
sum of Rs.7 Lacs to you noticee and you
noticee will execute the sale documents of
the property bearing No. E-1/309, Gali No.6,
Nehru Vihar, Delhi-110094 in favour of my
client.

77. That consequently the parental family


members of my client had paid Rs.5 Lacs in
cash to you noticee and you noticee has
handed over the original property documents
in favour of my client and it was agreed
that as and when my client shall pay the
remaining amount of Rs.2 Lacs, then you
noticee will execute the final sale
documents of the said property in favour of
my client, but now instead of executing the
sale documents in favour of my client, you
noticee sent the present false and frivolous
legal notice to my client only to grab the
hard earned money of my client. It is
pertinent to mention here that my client is
still ready to pay the above said remaining
amount of Rs.2 Lacs to you noticee, but you
noticee kept passing the time by or pretext
or the other, hence this notice.

I, therefore call upon you through this


legal notice to execute the Regd. Sale
Documents of the said property in question
in favour of my client after receiving the
remaining amount of Rs.2 Lacs from my
client, within 07 days from the receipt of
this legal notice, failing which my client
shall be constrained me to initiate
appropriate civil as well as criminal
proceedings against you, totally on your
risks, costs and consequences.
You are also liable to pay Rs.11,000/-
as fee of this legal notice.

Copy kept for further references in my


office.

Seema Dogra
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date:

REGD.A.D/SPEED POST

LEGAL NOTICE

To,
The District Magistrate,
Nalanda Collectorate,
Bihar Shariff,
District Nalanda-803101,

Sir,
Under the instruction from and on behalf of

my client M/S SYNDICATE INNOVATIONS

INTERNATIONAL LIMITED, THROUGH ITS DIRECTOR/A.R.

______________, HAVING ITS REGD. OFFICE AT:

GULAB BHAWAN, G-365, PREET VIHAR, DELHI-110092,

I hereby serve upon you through the following

legal notice, which facts as under:-


14. That my client is doing the business of

manufacturing and supply of

______________________ in the name and style

of M/s SYNDICATE INNOVATIONS INTERNATIONAL

LIMITED, duly registered under the Companies

Act, 2013, and having its Regd. Office AT:

GULAB BHAWAN, G-365, PREET VIHAR, DELHI-

110092

15. That Nalanda Collectorate, Bihar Sharif had

published a Short Tender Notice on dated

________ for the purpose of shooting weapon

of international standards from registered

manufacturers/ firms for Kalyan Bigha

Shooting Range, Harnaul, Nalanda with the

following descriptions, which is tabulated

below for the ease of references:

Sr.No. Items Description Quantity


01. Air Rifle FEINWERKBAU, Cal. 4.5
mm/0.177 06(six)
Model- P.800, AL,U
Made in Germany
(With Rifle case and
all the accessories)

02. Air STEYR SPORT, Cal 4.5


Pistol mm/0.172
Model – LP 10 06(six)
Made in Austria
(With Rifle case and
all the accessories)

16. That it is also relevant to point out here

that as per the Tender published by Nalanda

Collectorate, Bihar Sharif various other

terms and conditions were duly imposed and

mentioned in the Short Tender Notice dated

_______.

17. That as per the terms and conditions, my

above said client had deposited the Security

Deposit (Refundable) by way of two Demand

Drafts of Rs.10,000/- each i.e. total

Rs.20,000/- vide its No.038131 and 038130

both of dated 18.06.2014 favouring to


District Magistrate, Nalanda, Payable at

Biharsharif.

18. That consequently the tenders were released

to another company and as per the terms and

conditions of the Short Tender Notice, the

security deposit amount of total Rs.20,000/-

have to be returned to my client being it

was a refundable security deposit and in

this regard my client had wrote a request

letter dated ___________ to you noticee,

requesting to refund the aforesaid security

deposit amount of Rs.20,000/-, but you

noticee didn’t bother to respond the same.

19. That subsequently, my client again sent a

final notice dated 07.03.2015 to you noticee

with the same request to refund its security

deposit of Rs.20,000/-, but all went vain,

hence this notice.


20. That you noticee as per the terms and

conditions of the Short Tender Notice, is

required to refund the security amount of

Rs.20,000/- to my client with immediate

effect and as you have failed to refund the

same as per the terms and conditions of the

short tender notice, therefore, now you have

also rendered yourself liable to pay the

interest on the aforesaid amount of

Rs.20,000/- w.e.f. 18.06.2014.

I, therefore call upon you through this


legal notice to refund the aforesaid
security amount of Rs.20,000/- (Rupees
Twenty Thousand only) to my client alongwith
interest at the tune of 24% p.a. w.e.f.
18.06.2014 within 15 days, from the receipt
of this legal notice, failing which my
client shall be constrained to initiate
appropriate civil as well criminal
proceeding against you totally on your
costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.
Pankaj Bhushan
Advocate
Kapil Singhal CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: 06.02.2017

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH. ANIL MAHAJAN
S/o SH. OM PRAKASH,
R/o X/1242, STREET No.1,
RAJGARH COLONY, GANDHI NAGAR,
DELHI-110031

ALSO AT:-
M/s A.G. GARMENTS
F-8/10, KRISHNA NAGAR,
DELHI-110051

ALSO AT:-
M/s ANIL PROPERTIES
F-5/10, KRISHNA NAGAR,
DELHI-110051

Sir,
Under the instruction from and on behalf of
my client SMT SUMAN PAHUJA, W/O SH. NARENDER
KUMAR PAHUJA, R/O 235, SURYA NIKETAN, DELHI-
110092, I hereby serve upon you through the
following legal notice, which facts as under:-

20. That my client is the lawful owner of the


property bearing No.F-8/10, MEASURING AREA
22.22 SQ. YARDS (8 FT. X 25 FT.), SITUATED
AT KRISHNA NAGAR, DELHI-110051, WITH ALL
FIXTURES AND FITTINGS THEREON, VIDE
I.G.P.A. as Regd. No.11200 Book No.IV,
Volume No.1576 on pages 183 to 187 and
Regd. on 06.06.2005 in the office of Sub-
Registrar-VIII, Delhi.

21. That in the month of December-2013, you


noticee contacted to my client and
requested them to let out the protion of
the aforesaid property consisting of
GROUND and FIRST FLOOR.

22. That consequently my client has let out


the abovesaid portion of her above
property to you noticee for a period of
three years and it has been agreed between
you noticee and my client that the monthly
rent of the said tenanted premises shall
be Rs.12,000/- per month for first year
and for the second year, the monthly rent
of the said tenanted premises shall be
Rs.13,200/- per month and for the third
year, the monthly rent of the said
tenanted premises shall be Rs.14,520/- per
month excluding electricity charges for
the whole period.

23. That in this regard a Regd. Lease Deed


dated 30.12.2013 was executed between you
noticee and my client before the Sub-
Registrar-VIII, Geeta Colony, Delhi.

24. That as per the aforesaid Lease Deed dated


30.12.2013 the tenancy was started from
19.12.2013 to 18.12.2016. Since, the
aforesaid lease deed was expired and my
client is not interested to extend the
lease deed in future with you noticee.

25. That it is relevant to point out here that


you noticee have neither paid nor tendered
the arrears of rent to my client since
September-2016, despite repeated requests
and demands made by my client and the rent
of the aforesaid property is Rs.14,520/-
per month.

26. That now you noticee is not entitled to


keep further as tenant in the aforesaid
premises in future, and you are required
to handover the peaceful vacant possession
of the said tenanted premises to my client
within the stipulated period after
receiving the present legal notice.

27. That since the aforesaid lease deed has


been expired in the month of December,
2016 and my client has terminated your
tenancy by way of present legal notice,
hence you are the unauthorized occupant in
the said tenanted premises, hence you
noticee are also liable to pay Rs.1,000/-
per day as damages to my client till the
vacation of the said premises, hence this
notice.

I, therefore call upon you through


this legal notice that my client does not
wants to keep you as tenant any more in
her premises and terminated your license
with immediate effect, hence I further
call upon you kindly handover the peaceful
vacant physical possession of the said
premises within stipulated period after
receiving the present legal notice
otherwise my client shall be constrained
to take legal action against you totally
on your costs, risks and consequences.

You are also liable to pay the arrears


of rent for the period of September 2016,
till December 2016 at the rate of
Rs.14,520/- per month to my client i.e.
total Rs.58,080/- with immediate effect
after receiving the present legal notice.

You are also liable to pay the


damages/ mesne profits being the
unauthorized occupant in the said property
to my client @ Rs.1,000/- per day w.e.f.
18.12.2016 till the vacation of the same.

You are also liable to pay Rs.5,500/-


as legal expenses to my client.

Copy kept for further references in my


office.

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
1. SH. RAJU,
S/O LATE Sh. CHHOTE LAL,
R/O B-273, GROUND FLOOR, NAND NAGRI,
DELHI-110093

2. SMT. LAJJO DEVI,


W/O SH RAM SINGH,
R/O B-477, RASGULLE WALI GALI,
GALI No.16, NEAR SHIVANI DAIRY,
GAGAN VIHAR, GHAZIABAD, U.P.,

3. SMT. RAJO DEVI,


W/O Sh. PRAKASH
R/O B-2/72, NAND NAGRI,
DELHI-110093

4. SMT. SHEELA DEVI,


W/O LATE Sh. RAJVEER SINGH,
R/O B-2/139, NAND NAGRI,
DELHI-110093

5. SMT GEETA
W/O Sh. ISHWAR,
R/O U-25, WELCOME COLONY,
SEELAMPUR-III, DELHI-110053

Sir,
Under the instruction from and on behalf of
my client SH LALU RAM, S/O LATE Sh. CHHOTE LAL,
R/O B-273, 1ST FLOOR, NAND NAGRI, DELHI-110093, I
hereby serve upon you through the following
legal notice, which facts as under:-

1. That you noticees are the real brother and


sisters of my above said client
respectively and the deceased father of my
client namely Late Sh. Chhote Lal was the
sole and absolute owner of the property
bearing No. B-273, NAND NAGRI, DELHI-
110093 measuring about 22½ sq. yards.

2. That the father of my client had expired


in the year-1980 and the mother of my
client had expired on 14.07.2005, leaving
behind total six legal heirs i.e. you all
noticees and my client. And my client is
having 1/6th share in the said property.

3. That it is also relevant to point out here


that you noticee is living on the ground
floor and the electricity connection of
the said property is in the name of my
client for first floor and one electricity
connection is in the name of you noticee
No.1 for ground floor and the water
connection is still in the name of the
deceased mother of my client namely Late
Smt.Chameli Devi.

4. That you noticee No.1 has intentionally


and deliberately disconnected the water
connection of my client and for which my
client has filed a complaint before the
concerned S.D.M., Delhi for restoration of
his water connection and you noticee No.1
has also mercilessly beaten my client and

his other family members and in this


regard a criminal complaint case filed by
my client is pending before the concerned
court/M.M. at Karkardooma Courts, Delhi.

5. That a mutual settlement was also arrived


between my client and noticee No.1 before
the respectable persons of the locality,
but the noticee No.1 again failed to
comply the same, despite putting his
signature on the family settlement
executed on Rs.20/- stamp paper dated
18.12.2016.

6. That now my client has come to know that


you noticees have established the malafide
intention and ulterior motives to grab the
said property of my client.

7. That now you noticees having bad eye on


the above said property of my client and
you noticees want to dispose off/sell the
said property without determining the
proportionate share of my above said
client in the said property.

8. That my above said client on several times


approached to you noticees and requested
for partition the above said property and
to determine the respective share of all
the children/legal heirs, but you didn’t
pay any heed and you have even threatened
to kill my client if he again approached

to you noticees for demanding his share in


the aforesaid property.
9. That you have no right to sell the said
property in question in any manner without
the consent and permission of my above
said client.

I, therefore call upon you through this


legal notice not to sell, mortgage,
alienate, and create any third party
interest in the said property in question
illegally and unlawfully without determining
the share of my above said client and you
may give the proportionate share to my
client in the above said property, after
partitioning the same or to give the
possession of the said property to my client
within 15 days, from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

V.P. Masih
Advocate
Ved Prakash Masih Chamber No.F-423, F-Block,
Advocate Karkardooma Court Complex,
Shahdara, Delhi -110032.
DELHI HIGH COURT
EN. No. D/1898/99 M. 9818613737
Ref: DATE: 08.02.2017

LEGAL NOTICE
REGD.A.D./SPEED POST
To,
SMT. KIRAN,
W/O SH. MOHAN KUMAR,
R/O 716B-1/6, GOVIND PURI,
KALKAJI, NEW DELHI-110019

Sir,
Under instructions from and on behalf of my
client SH JATIN MITTAL, S/O LATE SH. RAM DHARI
MITTAL, R/O 535/6, GOVIND PURI, KALKAJI, NEW
DELHI-110019 I hereby serve upon you through
this following legal notice, facts as under:-

51. That an agreement to sell/bayana dated


29.06.2016 was executed between my client
and you noticee whereby you were agreed to
sell your property bearing No.716B-1/6,
GOVIND PURI, KALKAJI, NEW DELHI-110019,
measuring 42 sq. yards consisting of ground
floor, first floor, second floor and third
floor, each floor comprises two room,
kitchen, and Toilet and one room and kitchen
and bathroom and common passage for approach
and staircase etc. and proportionate land
beneath the same of the said property,
carved out of Khasra No.600/93, situated at
Govind Puri, Kalkaji, New Delhi-110019 and
it was agreed between you and my client that
the said property shall be sold to my client
in a total consideration amount of Rs.30
Lacs and out of which my client had paid
Rs.3 Lacs to you noticee in presence of your
husband, who is also the confirming party to
the said agreement.

52. That it has been agreed that between you


noticee and my client that my client shall
get execute the final sale documents of the
said property on or before 31st May, 2017
after making the payment of the balance
amount of Rs.27 Lacs.

53. That now my client has arranged the


balance amount of sale consideration i.e.
Rs.27 Lacs and my client has given various
intimations to you noticee to receive the
balance amount of sale consideration and to
execute the final sale documents of the said
property in favour of my client, but on each
and every occasions, you noticee kept passed
the time by one pretext or the other with
the malafide intention and ulterior motives
to cause wrongful loss to my client and
wrongful gain to yourself.

54. That now you noticee has flatly refused


to execute the final sale documents of the
said property in favour of my client with
the sole motive to grab the hard earned
money of my client, hence this notice.

55. That as per clause 13 of the aforesaid


Agreement to Sell, it is agreed between you
noticee and my client that if you noticee
fails to execute the proper transfer
documents in the name of my client, or its
nominee or its nominated third party, then
you shall be liable to pay the double of the
amount of earnest money, hence this notice.

I, therefore call upon you through this


legal notice either to execute the Regd.
Sale Documents of the said property in
question in favour of my client or to pay
the double amount of the received money i.e.
total Rs.6,00,000/- (Rupees Six Lacs only)
to my client, within 15 days from the
receipt of this legal notice, failing which
my client shall be constrained me to
initiate appropriate civil as well as
criminal proceedings against you, totally on
your risks, costs and consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept for further references in my


office.

V.P. Masih
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date: 06.02.2017

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH. ANIL MAHAJAN
S/o SH. OM PRAKASH,
R/o X/1242, STREET No.1,
RAJGARH COLONY, GANDHI NAGAR,
DELHI-110031

ALSO AT:-
M/s A.G. GARMENTS
F-8/10, KRISHNA NAGAR,
DELHI-110051

ALSO AT:-
M/s ANIL PROPERTIES
F-5/10, KRISHNA NAGAR,
DELHI-110051

Sir,
Under the instruction from and on behalf of
my client SMT SUMAN PAHUJA, W/O SH. NARENDER
KUMAR PAHUJA, R/O 235, SURYA NIKETAN, DELHI-
110092, I hereby serve upon you through the
following legal notice, which facts as under:-

28. That my client is the lawful owner of the


property bearing No.F-8/10, MEASURING AREA
22.22 SQ. YARDS (8 FT. X 25 FT.), SITUATED
AT KRISHNA NAGAR, DELHI-110051, WITH ALL
FIXTURES AND FITTINGS THEREON, VIDE
I.G.P.A. as Regd. No.11200 Book No.IV,
Volume No.1576 on pages 183 to 187 and
Regd. on 06.06.2005 in the office of Sub-
Registrar-VIII, Delhi.

29. That in the month of December-2013, you


noticee contacted to my client and
requested them to let out the protion of
the aforesaid property consisting of
GROUND and FIRST FLOOR.

30. That consequently my client has let out


the abovesaid portion of her above
property to you noticee for a period of
three years and it has been agreed between
you noticee and my client that the monthly
rent of the said tenanted premises shall
be Rs.12,000/- per month for first year
and for the second year, the monthly rent
of the said tenanted premises shall be
Rs.13,200/- per month and for the third
year, the monthly rent of the said
tenanted premises shall be Rs.14,520/- per
month excluding electricity charges for
the whole period.
31. That in this regard a Regd. Lease Deed
dated 30.12.2013 was executed between you
noticee and my client before the Sub-
Registrar-VIII, Geeta Colony, Delhi.

32. That as per the aforesaid Lease Deed dated


30.12.2013 the tenancy was started from
19.12.2013 to 18.12.2016. Since, the
aforesaid lease deed was expired and my
client is not interested to extend the
lease deed in future with you noticee.

33. That it is relevant to point out here that


you noticee have neither paid nor tendered
the arrears of rent to my client since
September-2016, despite repeated requests
and demands made by my client and the rent
of the aforesaid property is Rs.14,520/-
per month.

34. That now you noticee is not entitled to


keep further as tenant in the aforesaid
premises in future, and you are required
to handover the peaceful vacant possession
of the said tenanted premises to my client
within the stipulated period after
receiving the present legal notice.
35. That since the aforesaid lease deed has
been expired in the month of December,
2016 and my client has terminated your
tenancy by way of present legal notice,
hence you are the unauthorized occupant in
the said tenanted premises, hence you
noticee are also liable to pay Rs.1,000/-
per day as damages to my client till the
vacation of the said premises, hence this
notice.

I, therefore call upon you through


this legal notice that my client does not
wants to keep you as tenant any more in
her premises and terminated your license
with immediate effect, hence I further
call upon you kindly handover the peaceful
vacant physical possession of the said
premises within stipulated period after
receiving the present legal notice
otherwise my client shall be constrained
to take legal action against you totally
on your costs, risks and consequences.

You are also liable to pay the arrears


of rent for the period of September 2016,
till December 2016 at the rate of
Rs.14,520/- per month to my client i.e.
total Rs.58,080/- with immediate effect
after receiving the present legal notice.

You are also liable to pay the


damages/ mesne profits being the
unauthorized occupant in the said property
to my client @ Rs.1,000/- per day w.e.f.
18.12.2016 till the vacation of the same.

You are also liable to pay Rs.5,500/-


as legal expenses to my client.

Copy kept for further references in my


office.

PANKAJ BHUSHAN
ADVOCATE
SEEMA DOGRA Chamber No.F-428, F-Block,
ADVOCATE Fourth Floor, Lawyers Chamber
Karkardooma Courts Complex
Shahdara, Delhi-110032.
DELHI HIGH COURT
EN. No. D-1968/99 M:- 9810893021
Ref. No. DATED:

REGD.A.D.
REPLY OF LEGAL NOTICE
To,
SH. DEVENDER KUMAR SHARMA
ADVOCATE,
AT: CH.NO.D-323, KARKARDOOMA COURTS,
SHAHDARA, DELHI-110032

Sir,
My client SMT. KIRAN YADAV, W/O SH. PUNIT
YADAV, R/O E-1/309, GALI NO.6, NEHRU VIHAR,
DELHI-110094, has placed before me your legal
notice dated 09.01.2017, which was placed before
me on 27.01.2017 sent by you on behalf of your
client SH MAHESH CHAND YADAV, S/O LATE SH NATHU
SINGH YADAV, R/O E-1/309, GALI NO.6, NEHRU
VIHAR, DELHI-110094, and my client instructed me
to give the reply of the same and brought true
facts into your knowledge, which facts are as
under:-

PRELIMINARY OBJECTIONS:-
78. That the legal notice sent by you is based
on wrong and false information, supplied by
your client to you, therefore the present
notice is liable to be withdrawn.

79. That your client did not disclosed the


actual facts to your good self and has
concealed the material facts from you and
had sent the present legal demand notice to
my client through your good self, hence the
notice sent by you is liable to be withdrawn
with immediate effect at the outset.

80. That the present notice is nothing, but the


result of collusion between your client and
the noticee No.1, as both are in collusion
of each other and the noticee No.1 is in
regular and continuous contact with your
client and the present legal notice has been
sent by your client only to create false
evidence and to somehow take revenge from my
client and to curtail her all rights, title
and interests qua her marriage with the
noticee No.1.

81. That the true fact is that my client got


married with noticee No.1 on 02.12.2010
according to Hindu rites and customs and in
the said marriage, the parents of my client
have spent a huge amount in the marriage,
but despite that your client and the husband
of my client were not happy with the same
and they used to harass and humiliate my
client even on petty issues.

82. That your client and his other family


members usually used to harass and humiliate
my client and taunted her on petty issues
even the husband of my client used to abuse
the parental family members of my client by
sending vulgar messages to them.

83. That despite all these, my client kept on


living only in the hope that after the birth
of child, all will be fine, but all the
hopes and dreams of my client were ruined,
because despite the birth of two children
namely Divya, aged about ___ years and Vansh
aged about ___ years, the attitude and
behavior of your client and his other family
members were not changed.

84. That your client and his family members have


raised the demand from my client to pay cash
and due to the said continuous threats and
compelling circumstances, the parental
family members of my client have paid
various cash amount to your client time to
time.

85. That a mediation was held between both the


parties on 11.07.2013 before the Delhi Govt.
Mediation & Conciliation Centre, Delhi,
wherein it was agreed that your client and
his other family members will keep my client
happily and will not cause and mental and
physical tortures to her, but all went in
vain.

86. That thereafter in the month of May-2016 an


oral settlement was held between my client
and your client and it was agreed that my
client or her parental family members shall
pay a total sum of Rs.7 Lacs to your client
and your client will execute the sale
documents of the property bearing No.
E-1/309, Gali No.6, Nehru Vihar, Delhi-
110094 in favour of my client.

87. That consequently the parental family


members of my client had paid Rs.5 Lacs in
cash to your client and your client has
handed over the original property documents
in favour of my client and it was agreed
that as and when my client shall pay the
remaining amount of Rs.2 Lacs, then your
client will execute the final sale documents
of the said property in favour of my client,
but now instead of executing the sale
documents in favour of my client, your
client sent the present false and frivolous
legal notice to my client only to grab the
hard earned money of my client.

REPLY ON MERITS:-
1. That the contents of Para No.1 of your legal
notice are matter of records. However, it is
submitted that the contents of whole
Preliminary Objections may be read as part
and parcel as reply of this Para, same are
not being reproduced herein for the sake of
brevity.

2. That the contents of Para No.2 of your legal


notice are matter of records.

3. That the contents of Para No.3 of your legal


notice are wrong and denied. However, it is
submitted that the contents of whole
Preliminary Objections may be read as part
and parcel as reply of this Para, same are
not being reproduced herein for the sake of
brevity.

4. That the contents of Para No.4 of your legal


notice are wrong and denied. However, it is
submitted that your client has no right to
debar my client in any manner and the
contents of whole Preliminary Objections may
be read as part and parcel as reply of this
Para, same are not being reproduced herein
for the sake of brevity.

5. That the contents of Para No.5 of your legal


notice are wrong and denied in Toto.
However, it is submitted that my client is
having all right, title and interest over
the said property.

I, therefore request you through this


reply to advise your client to withdraw the
present false, fabricated and concocted
notice immediately from the receipt of this
reply of your notice, otherwise my client
will defend the same with all possible
measures laid down in law and shall also be
constrained to initiate appropriate separate
legal action against your client totally on
the costs, risks and consequences of your
client.

Your client is also liable to pay


Rs.5500/- as legal remuneration of this
reply.

Copy kept for further references in my


office.

SEEMA DOGRA
ADVOCATE
Mamtesh Sharma Chamber No.F-709, F-Block
th
Advocate 7 Floor, Lawyers Chambers
Block, Kakardooma Courts
DELHI HIGH COURT Delhi-110032
E-mail: mmamtesh@gmail.com Ph: 09810322929, 08860077857
==================================================================
Ref: Date: 03.02.2017

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH ABHINAV,
R/O C-1/87A, FIRST FLOOR,
PLOT NO.55A, MADHU VIHAR-II,
UTTAM NAGAR, DELHI-110059

ALSO AT:
H.NO.29, VILLAGE & POST PARSHIPUR
(KURWAR), DISTT. SULTANPUR,
U.P-228 155,

Sir,
Under instructions from and on behalf of my
client SH MUKESH GUPTA, S/O SH. DULI CHAND, R/O
232, DAYANAND VIHAR, DELHI-110092, I hereby
serve upon you through this following legal
notice, facts as under:-
56. That you and my client having good
friendly and familiar/visiting terms with
each other from the last many years.

57. That consequently in the month of March-


2016, you approached to my client and
requested to arrange a cash of Rs.80,000/-
(Rupees Eighty Thousand only) as a friendly
loan by showing your urgent need of money,
and my client arranged a sum of Rs.80,000/-
(Rupees Eighty Thousand only) and
accordingly my client had handed over to the
sum of Rs.80,000/- (Rupees Eighty Thousand
only) to you noticee and at the time of
borrowing the aforesaid amount, you assured
to my client that the said amount would be
returned positively within 2-3 month.

58. That thereafter my client has approached


to you noticee in the mid week of July-2016,
and demanded the said friendly loan amount
of Rs.80,000/- (Rupees Eighty Thousand
only), then in discharge of your above said
liability, you issued, signed and delivered
a cheque bearing No.186219 of dated
03.11.2016 of Rs.80,000/- drawn on Axis
Bank, Branch at Tilak Nagar, Delhi, and at
the time of issuing the aforesaid cheque you
assured to my client that the said cheque
would be honoured positively at the time of
its presentation. It is relevant to point
out here that you have promised for
returning the aforesaid amount only in 2-3
months, but at the time of issuing the said
cheque, you sought time upto March-2016, on
pretext that you have not arranged the
sufficient amount in your banker and my
client being no other option, became agreed
with you.

59. That as per your assurance and


instructions my client had firstly presented
the said cheque in his banker i.e. Yes Bank
Ltd. Branch at Chawri Bazar, Delhi, but the
said cheque was dishonored by your banker
with the remarks “Funds Insufficient” and my
client has received the returned memo
received of dated 19.11.2016.

60. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque, then you noticee
apologized your guilt and requested my
client to give some more time of two months
and assured that this time you will
definitely arrange the sufficient amount in
your bank account for honouring the said
cheque.

61. That consequently my client again


presented the said cheque in his banker i.e.
Axis Bank, Branch at Chawri Bazar, Delhi as
per your commitment and instructions, but it
was utter shocking for my client when the
said cheque got again dishonored by your
banker with the remarks “FUNDS INSUFFICIENT”
and my client has received the returned memo
of dated 21.01.2017.

62. That thereafter my client again


contacted you and revealed the reality about
the dishonor of said cheque, and then my
client demanded the said cheque amount in
cash from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment of
the said cheque, you have flatly refused to
pay the said cheque amount to my client in
any manner.

63. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act R/W section 406/420
of Indian Penal code.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.80,000/-
(Rupees Eighty Thousand only) to my client
within 15 days from the receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate civil
as well as criminal proceeding against you
totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Mamtesh Sharma
Advocate
ZAKIR RAZA F-424, 4th Floor, F-BLOCK
Advocate Lawyers Chambers
Karkardooma Courts,
Delhi -110032.
DELHI HIGH COURT M: - 9810424351
ENR No. D-819/1997(R)
Ref. No. DATED: 24.01.2017

LEGAL NOTICE
REGD. A.D./SPEED POST
TO,
SH RASHID
S/O SH SHAHID,
AT: 147, GROUND FLOOR, GALI No.7-B,
JAFRABAD, DELHI-110053

Sir,
Under the instructions from and on behalf of
my client namely Mr. ATA UR REHMAN, S/o LATE Mr.
HABIB UR REHMAN, R/o 147, GALI No.7-B, JAFRABAD,
DELHI-110053, I hereby serve upon you through
this following legal notice facts, as under:-

1. That my client is the owner in respect of


property bearing No.147, GALI No.7-B,
JAFRABAD, DELHI-110053.

2. That your uncle namely Late Pyare Khan


Sheeshe Wale, was inducted as Tenant in
the said premises in respect of two rooms
on ground measuring 30 Sq. Yds., with open
area on 17.10.2006 at the monthly rent of
Rs.1,200/- for godown purpose and the
tenancy started from 17th day of each
Calendar month and ends in the 16th day of
the following month.

3. That, thereafter, your uncle fell ill and


ultimately died in on 13.04.2015 and since
then you on the instructions and collusion
with Mst. Shabnam @ Guddo are under the
possession of the said tenanted shop which
is illegal and unwarranted, as you are an
unlawful occupant of the said premises and
your possession therein is illegal.

4. That you are also liable to pay the use


and occupation charges at the tune of
Rs.5,000/- per month to my client from
01.03.2015 till the vacation of the said
premises.

I hereby call upon you through this


legal notice to handover the peaceful,
physical and vacant possession of the
tenanted premises i.e. two rooms on the
ground floor alongwith open area of the
property bearing No.147, GALI No.7-B,
JAFRABAD, DELHI-110053 alongwith use and
occupation charges from 01.03.2015 till the
vacation of the said shop at the tune of
Rs.5,000/- within 15 days from the date of
receipt of this notice, failing which I
have clear instructions to take legal
action against you in the competent Court
of law that too at your risk, cost and
consequences which please note. Please also
remit a sum of Rs.2,500/- as the
professional fee of this legal notice.

Copy kept for further references in my


office.

ZAKIR RAZA
ADVOCATE
Arpit Jain E-401, E-Block, 4TH Floor
Advocate Lawyers Chambers Block
Karkardooma Courts Complex,
Delhi-110032.
DELHI HIGH COURT
EN. No. D-1803/15 M. 9811595800
Ref. No. DATED: 22.12.2016
LEGAL NOTICE
REGD.A.D./SPEED POST
To,
1. SH SANJAY DUA

2. Ms. SARYU DUA


W/o SH SANJAY DUA

BOTH R/o:- C-71, 2ND FLOOR,


SURAJMAL VIHAR, DELHI-110092

Sir,
Under the instruction from and on behalf of
my client SH VIPIN JAIN, S/o SH PAVAN KUMAR
JAIN, R/o K-28, 1ST FLOOR, NAVEEN SHAHDARA,
DELHI-110032, I hereby serve upon you through
the following legal notice, which facts as
under:-
1. That you noticee No.1 and 2 are Architects
by profession and you both are doing the
work of furnishing and interior decoration
at the above given address.

2. That in the month of May 2016, my client


placed an order to you noticees for the
work of furnishing and interior decoration
at his abovesaid house i.e. K-28, 1ST
FLOOR, NAVEEN SHAHDARA, DELHI-110032.

3. That it was settled between my client and


you noticees on oral basis that you shall
provide my client with the following goods
on a total payment of Rs.4 Lacs within
three months i.e. upto August 2016. The
details of the goods/items are as under:-

(i) Two Beds with side Tables and Couch


costing to Rs.60,000/- each i.e.
Rs.1,20,000/- in total.
(ii) One Sofa Set 07 seater costing
Rs.70,000/-.
(iii) One Center Table costing Rs.15,000/-.
(iv) Study table for children alongwith 02
Wooden Almirah costing Rs.50,000/-.
(v) One dining table alongwith 05 chairs
costing to Rs.70,000/-.
(vi) 2 LED Panels costing Rs.10,000/-.
(vii) 5 wall wood panelling.
(viii) Wallpapers for 3 walls.
(ix) LED lights on roof.
(x) Full Kitchen furnishing.

4. That as per the settlement, you noticees


assured my client that good quality of wood
shall be used in the abovesaid goods/items.
It was also agreed between you and my client
that any goods/items if not found of good
quality and upto the satisfaction of my
client, then the same shall be replaced
immediately by you noticees.

5. That as per the demands and requirements,


you noticees received part-payments from my
client time to time as per the below
mentioned details:-

Date Payment (in Rs.)

15.05.2016 50,000/- Cash


23.05.2016 49,000/- vide cheque
No.161083 drawn on OBC,
Gandhi Nagar, Delhi
05.06.2016 50,000/- Cash
15.06.2016 50,000/- Cash
16.07.2016 40,000/- vide cheque
No.148481 drawn on Axis
Bank, Geeta Colony, Delhi
25.07.2016 25,000/- Cash
05.08.2016 50,000/- Cash
25.09.2016 50,000/- Cash
23.10.2016 15,000/- Cash
TOTAL Rs.3,80,000/-

6. That it is relevant to note here that out of


total Rs.4 Lacs, a sum of Rs.3,80,000/- has
already been paid by my client to you
noticees.

7. That it is also pertinent to mention here


that you noticees have not done the work as
aforestated as per the complete satisfaction
of my client and even you noticees have used
inferior quality of goods and items in the
aforesaid furnishing work and you noticees
have failed to deliver the goods to my
client in proper and adequate quality with
poor finishing and incomplete work. Both the
beds are of very inferior quality, sofa set
is incomplete, center table is also of very
inferior quality, one chair of dining table
had already been broken, LED Panels are of
inferior quality, wooden panelling is
incomplete, LED lights are not been
installed on the roof as on date as agreed.
8. That you the noticees have failed to provide
goods quality items within agreed period as
promised by you noticees and also the
items/goods received are even left
incomplete and are of very inferior quality.

9. That due to this irresponsible and


deficiencies in services on part of you
noticees, my client has suffered a huge
mental pain, financial loss and has become a
matter of laugh amongst the relatives and
friends.

10. That you noticee has caused a financial loss


to my client by not fulfilling your part of
contract as agreed by you noticee and
despite receiving the amount of
Rs.3,80,000/- you noticee have failed to
discharge your obligations towards your
commitment and caused a loss, for which you
noticees are liable to compensate my client
in a sum of Rs.4 Lacs as damages.

I, therefore call upon you through this


legal notice to complete the pending work of
furnishing as incomplete left by you
noticees after replacing the inferior
quality items/goods and also to compensate
my client in a sum of Rs.4 Lacs, within 15
days from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate proceedings for
breach of trust, recovery of said amount,
Criminal & Civil Defamation, consumer’s
Court etc. against you truly, totally on
your costs, risks and consequences.

You noticees are further liable to pay


Rs.5,500/- as fee of this legal notice.

Copy kept in my office for further


references.

ARPIT JAIN
ADVOCATE
Yogendra Kumar Office at: G-612, 6th Floor,
ADVOCATE G-Block, Karkardooma
Courts
DELHI HIGH COURT Complex Delhi-110032
EN. No. D-408-E/03 M: 09312498900
================================================================================
Ref: Date: 21.12.2016

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
The Manager,
HDFC ERGO General Insurance Co. Ltd.
At: Ambadeep Building, Ground Floor,
Kasturba Gandhi Marg, New Delhi,

Sir,
Under the instructions from and on behalf of

my client Sh. Krishna Prasad, S/O Late Sh.

Omkar, Resident of H.No.9/154-155, Trilokpuri,

Delhi-110091, I hereby serve upon you with the

following legal notice:

21. That my client had purchased a vehicle i.e.

Eicher 1059XP bearing its Registration

No.DL1LV-1596 Model 2014 for Commercial


purpose vide Chassis No.MC2B2ERC0EK302569

and Engine No.E413CDEK005051.

22. That the said vehicle was duly insured with

you noticee vide Policy/Cover Note No.

231520091719300000 valid w.e.f. 22.10.2014

to 21.10.2015.

23. That on 10.05.2015 at about 2:00 AM to 2:30

AM in the night, my client was going from

Noida Phase-II to Taj Hotel Delhi for taking

the Tent articles and at about 2:30 AM when

he reached at AIIMS Hospital, then the said

vehicle/Eicher Canter of my client was

robbed by four unknown robbers and they have

even taken away the above said vehicle

/Eicher canter of my client with them.

24. That thereafter the police of P.s Safdarjung

Enclave, Delhi has lodged an FIR No.455 of

2015, U/s 392/365/34 IPC on dated

10.05.2015.
25. That my client has duly informed to your

concerned agent in regard of the

theft/robbery of the said vehicle just on

the next day of the said incident.

26. That my client as well as the concerned

police officials have tried their level best

to somehow trace the said vehicle/Eicher

Canter, but all went in vain.

27. That thereafter my client has applied to you

noticee for getting the insurance claim of

his said vehicle/Eicher and accordingly my

client has completed all the formalities and

requirements for obtaining the insurance

claim and accordingly the insurance claim

was passed and my client was called for

receiving the aforesaid insurance claim.

28. That consequently my client approached to

your concerned office for receiving the


insurance claim of his above said vehicle,

then my client was told by your concerned

officials that the insurance claim will be

disbursed in favour of my client only after

some deduction and when my client opposed

the same that why your concerned officials

are deducting the money from the insurance

claim of my client illegally and unlawfully,

then they have flatly told my client to

approach to the concerned court for taking

the complete insurance claim.

29. That this is clear cut deficiencies on part

of you noticee and unfair trade practice, as

you noticee are deducting the amount from

the insurance claim of my client

intentionally and deliberately without

having any right, title or interest.

30. That my client has been suffered from a

great mental harassments, pain and agony


only because of illegal and unwarranted

acts.

31. That you noticee is liable to compensate my

client in a sum of Rs.5 Lacs as compensation

for mental and physical torture pain and

agony, hence this notice.

I, therefore call upon you through this


legal notice to release the complete insurance
claim of the vehicle of my client and to
compensate my client in a sum of Rs.5 Lacs for
as compensation for mental and physical
torture pain and agony and to pay the same to
my client, within 15 days from the receipt of
this legal notice, failing which my client
shall be constrained to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.
Copy kept in my office for further
references.

YOGENDRA KUMAR
ADVOCATE
To,

The Arbitrator

______________

______________

SUB: NOTICE/INTIMATION/OBJECTION U/S 7/11/12

OF THE ARBITRATION AND CONCILIATION ACT,

1996 FOR DISMISSAL OF THE CLAIM, IF ANY,

FILED BY ALLEGED CLAIMANT

Sir,

Under the instructions from and on behalf of

my client _______________________, I am serving


the present notice/intimation/objection as

follows:

1. That the above noted alleged proceedings

are intended to be filed before your good

self and is fixed for 26.11.2016.

2. That the alleged claimant has preferred a

false and frivolous claim before your good

self after concealing the true and

material facts from your good self.

3. That the alleged claimant has not taken

the consent of my client for the purpose

of appointment of the Arbitrator in this

matter and even no any prior notice has

been served by the alleged claimant to my

client for filing the alleged claim after

appointment of the arbitrator.


4. That it is also relevant to point out here

that the alleged agreement, on which basis

the false claim is to be filed by the

alleged claimant to your good self, is not

valid and the copy of the same has even

not been supplied to my client by the

alleged claimant before the appointment of

the arbitrator.

5. That the arbitrator appointed by the

alleged claimant in the present matter is

solely supportive and in collusion of the

alleged claimant and my client has high

objection in the appointment of the

present arbitrator in the present matter.

6. That no such terms and conditions had ever

been agreed between the alleged claimant

and my client that my client shall pay


such highly excessive litigation cost of

Rs.10,000/-.

7. That in view of the above, the present

claim, if any, filed by the alleged

claimant is liable to be

dismissed/rejected out rightly and

whatever the order passed by the

Arbitrator in the present subject matter

shall have no legal binding and

enforcement upon my client in future in

any manner.

I, therefore requested to your good self

that that the claim, if any, filed by the

alleged claimant may kindly be

dismissed/rejected out rightly, in the

interest of justice.
Copy kept in my office for future

references and records.

Advocate

SUKHBIR SINGH & ASSOCAITES


(ADVOCATE)
CHAMBER NO: T-19, TIS HAZARI COURTS, DELHI-110032
M: 9971452626
====================================================
Dated: 08.11.2016

LEGAL NOTICE
REGD.AD/SPEED POST

To
1. M/s SUPER REALTECH PVT.LTD.
THROUGH ITS M.D/DIRECTOR

2. SH. YATENDER GUPTA


DIRECTOR/PREMOTOR OF
SUPER REALTECH PVT.LTD.

3. SH. HIRDESH AGGARWAL


DIRECTOR/PREMOTOR OF
SUPER REALTECH PVT.LTD.

ALL ADDRESSEES AT: 4,SAVITA VIHAR,


MAIN ROAD, DELHI-110092

Sir,
Under the instructions from and on behalf
of my clients (1) Smt. Anita Tripathi and (2)
Arun Tripathi, all R/o 143, Karampura, Shivaji
Marg, New Delhi-110015, I do hereby serve upon
you the following legal notice:-
1. That you all the addressees had launched a
project to construct and allot to
potential buyer/purchaser and through that
you had offered to allot the apartments to
the various people and your project name
was “Oxy Homez”, situated at New Dilshad
Extension, Loni Bhopura Road, Near Koyal
Enclave, Ghaziabad, U.P.

2. That on your invitation my client had


booked a flat/apartment bearing No.107, at
first floor, area measuring 1125 Sq. Ft.
on 28.11.2012 and entered into an
agreement with you the addressees through
your representative Sh. B.K. Arora who was
duly authorized vide board resolution
dated 17.03.2012 and as per the rates, you
have charged a total sum of Rs.29,013,75/-
including floor charges i.e. Rs.95,625/-
and my client had booked the unit no.107,
in block-7 on first floor, measuring area
1125 sq. ft. @ Rs.2399/- per Sq. Ft..
3. That my clients had paid the entire
construction charges till date including
interest for making the late payment. Said
payment was made late since you had
delayed issuing NOC on your part and
accordingly bank has not granted the loan
in time to my clients due to your act.
Said amount of interest is factually your
liability and our clients had paid said
interest under protest, while reserving
their rights, against you, the addressees.

4. That my clients had already cleared all


the dues regarding construction being
Rs.29,99,216/- + Rs.1,6806/- as such my
clients have paid a sum of
Rs.30,016,022/-, to you/your company.

5. That you, the addressees, have further


demanded a sum of Rs.5,71,302/- under
various heads through your letter dated
28.06.2016 at serial no.7. wherein you
have demanded for the external increase
are i.e. Rs.2,7,741/- for increasing the
external area.
6. That as per clause 14 of the agreement you
have entered with my clients, you were
supposed to hand over the above said
apartment, latest by 31.12.2013 and as per
the clause 15 if any delay is there on
your part, you would be liable to pay
Rs.5/- per sq. ft. per month for the
period of delay in handing over the
possession of the apartment to the
apartment owner i.e. my clients.

7. That you had issued the possession letter


in the month of April, 2016 to my clients
and the period of delay on your part in
completing and handing the over the
possession of the flat to my client is
almost 28 month, hence you are also
liable to compensate and pay my clients,
for said period of delay a sum of
Rs.1,57,000/-.

8. That my clients have been trying to


contact at your telephone numbers i.e.
011400088888 (having the hundred line),
but could not contact on telephone, since
you/your officials are not responding to
such telephonic calls of my clients.
9. That my clients have contacted at your
office on 12.08.2016, with your officials
i.e. Neeraj Gupta and Neeraj Gupta further
directed my client to another official Sh.
Abdul and when it has been asked regarding
the outside increase area payment, Sh.
Abdul replied that there is increase of
area around 200 Sq. Ft. and that is to be
paid by my clients. It is relevant to note
here that after that two meetings were
again held by my clients at your office,
but all went in vian.

10. That my clients have sought clarification


as to whether GDA has sanctioned the plan
for increasing the claimed area and also
asked your official that such increased
must be mentioned in registered sale
documents, to be registered at the office
of Sub-registrar, by your company, but the
Sh. Abdul showed his inability to do so
and further refused to adjust the delay
period charges i.e. Rs.5/- per Sq. Ft. for
per month totling to an amount of
Rs.1,57,000/-.
11. That your company has already charged my
clients for making the delayed payment but
you/your company is trying to evade your
liability to pay for the delay caused for
handing over the possession to my clients.
However you/your company can not escape
from your liability as per the terms and
conditions mentioned in the para 15 in
agreement executed by your company with my
clients.

12. That my clients had already tried to


resolve the matter, mutually and amicably
but you have flatly refused to do so and
Sh. Neeraj Gupta has extended threats to
our clients that you will force our
clients to approach the court of law to
seek the remedies. In execution of your
threats you paying no heed to the requests
of our clients and our clients have been
harassed, mentally, physically and
financially.

13. That Sh. Abdul further refused to mention


the increase area in the registration/sale
deed and further showed his inability to
attach the sanction plan with the sale
deed to be executed by your company in
favour of my clients, which is absolutely
illegal and you/your company is solely
responsible.

14. That my client is ready to make the


payment and also tendered the amount for
the increased area provided the same is
under the sanctioned plan of the building
as approved by GDA and must be written in
the sale deed and further demand
damages/penalty to be paid by you for
delaying the construction/handing over the
possession. In case you/your company is
further delaying in handing over the
possession of said apartments, the damages
shall be charged for the entire period,
till you are handing over the possession.
It is also evident, out of the above said
conduct, that you all are playing fraud
upon my clients as well as upon the
Government, since you have raised illegal
construction but you are denying to get
the same regularized and further
committing illegality and offence by way
of denying Revenue to the Govt., since you
are denying to mention the claimed
increased area in the Registered Sale
Deed. Moreover, you had never informed my
clients about the claimed increase in
area. As such FIR in this regard is liable
to be registered against you/you company.
At the same time under the fresh
Notification by the Govt. of India and
State Govts., besides the newly enacted
Act to regulate the acts and deeds of
Builders.

15. That my client has also served two


intimations to you noticees for holding
the proceedings of Arbitrations, but
despite receiving the same, no response
has been given from your part and even
despite several reminders and written
intimation, you noticees failed to appoint
any Arbitrator in the present matter,
hence you have breached the terms and
clauses of the aforesaid agreement.

16. That it is pertinent to mention here that


now you noticees are threatening my client
for imposing the interest for delaying in
possession which is illegally and
arbitrary.
17. That my clients have no other option but
to live on rent and they are facing very
hardships and crises because of your
illegal and unwarranted acts.

I, therefore, call upon you all


addressees to adjust the penalty i.e.
Rs.1,57,000/- in your demand letter dated
28.06.2016 and further execute the sale deed
in favour of my clients while attaching the
sanctioned plan regarding increased outer
area of apartment allotted to my clients and
to mention the said increased area in the
sale deed to be executed by you/your company
and not to impose any interest upon my
client, failing which my clients shall be
constrained to initiate legal proceedings
against you before the competent courts of
law, entirely at your own costs, risks and
consequences. My clients would also seek
stay against handing over the illegally
raised building/apartment to all the buyers
and the entire apartments are liable to be
sealed.

You are also liable to pay a sum of


Rs.25000/-as the cost of this legal notice.
Copy kept in my office for further
reference and record.

Sukhbir Singh & Associates


Advocates

A.Ali Khan F-1, F-Block, 1st Floor,


Advocate Karkardooma Courts,
Delhi-110032.
DELHI HIGH COURT M:- 09312493952
Ref: Date: 09.11.2016
INTIMATION
REGD.A.D./SPEED POST
To,
Sh. Pulkit Dandona
Sole Arbitrator,
At: Sadhna House, 570, P.B. Marg,
Worli, Mumbai-18

Sir,
Under instructions from and on behalf of my
client Sh. Gaurav Jain, R/O M-94-95, Panchsheel
Garden, Navin Shahdara, Delhi-110032, I hereby
serve you through this following legal notice,
facts as under:-

1. That my above said client has recently


received an Interim Order vide No.
SLA/08/11/16/0038 dated 14.10.2016 through
post in respect of alleged Arbitration
matter between “M/s Mahindra & Mahindra
Financial Services Ltd. v. Gaurav Jain &
Anr”.

2. That in response to above, it is submitted


for your kind consideration that my client
has not received any notice for appointment
of arbitrator either from your good self or
from Mahindra & Mahindra Financial Services
Ltd., which is a mandatory requirement for
holding any arbitration proceedings and
therefore your appointment as arbitrator in
the present matter is not admissible as per
law and all the above alleged proceedings of
arbitration have no legal authenticity in
the eyes of law.

3. That when your appointment as arbitrator is


already in dispute as the same has been
appointed without the consent and permission
of my client, then the alleged interim order
passed by your good self is having no legal
validity and sanctity in the eyes of law in
any manner.

4. That it is respectfully submitted without


prejudice to the rights and contentions of
my client that my client is still ready and
willing to pay the remaining balance EMIs as
per the EMIs as fixed between my client and
M/s Mahindra & Mahindra Financial Services
Ltd. and because of some financial crises
and heavy loss in business, my client
couldn’t pay some of the instalments.

I am therefore intimating you on behalf


of my client to immediately withdraw your
Arbitratorship from the aforesaid alleged
arbitration proceedings as the same is not
valid and legal as per law and direct the
claimant company to continue to receive the
EMIs from my client as per the agreement
clauses.

Copy kept in my office for ready


references.

A.Ali Khan
Advocate
Momin Khan F-416, F-Block, 4TH Floor
Advocate Lawyers Chambers Block
Karkardooma Courts Complex,
Delhi-110032.
DELHI HIGH COURT
EN. No. D-300/98 (R) M. 9891158390
Ref. No. DATED: 18.10.2016

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
SH SHAKEEL AHMED
S/o SH HASAN ALI,
R/o A-4/689, AMAR COLONY,
EAST GOKALPUR, NEAR MASJID,
SHAHDARA, DELHI-110094

Sir,
Under instructions from and on behalf of my
client SH DINESH AGGARWAL, S/o SH RADHEY SHYAM
AGGARWAL, R/o HOUSE No.68, GALI No.7, BANK
COLONY, VILLAGE MANDOLI, DELHI-110093, I hereby
serve you through this following legal notice,
facts as under:-

1. That my client inducted you noticee as a


Tenant in the premises bearing No.A-4/689,
measuring area 100 Sq. Yds., Amar Colony,
East Gokalpur, Near Masjid, Shahdara,
Delhi-110094 on a monthly rent of
Rs.10,000/- including electricity and
water charges and in this regard a Rent
Agreement was also executed between you
noticee and my client on 07.02.2014 for a
period of 11 months in the presence of
marginal witnesses.

2. That as per the Rent Agreement the period


of tenancy has been expired on 06.01.2015,
but despite that you noticee residing in
the said property and on your request my
client extended the period of tenancy
orally without executing any new Rent
Agreement in this regard.

3. That you noticee had lastly paid the rent


to my client for the month of July, 2015,
but thereafter, you noticee did not pay
even a single penny towards the arrears of
rent from August, 2015 till August 2016
i.e. for a period of one year.

4. That after several repeated requests by my


client for paying the rent of period of
one year i.e. August, 2015 to August, 2016
consequently, then in discharge of your
abovesaid liability of rent for the period
August, 2015 to August, 2016 i.e. 12
months, you noticee issued a cheque
bearing No.021037, dated 04.08.2016,
amounting to Rs.1,20,000/- drawn on IDBI
Bank, Branch at Orchit Square, Sector
Road, B-Block, Sushant Lok, Gurgaon,
Haryana-122002, in favour of my client.

5. That 03.09.2016 as per your assurances, my


client had presented the aforesaid cheque
with his banker i.e. Bank of Baroda,
Mandoli, Delhi-110093, but the said
cheques were dishonored by your banker
with the remarks “FUNDS INSUFFICIENT” vide
returning memo dated 06.09.2016.

6. That immediately my client contacted to


you and disclosed the fact about the
dishonour of the said cheque and my client
demanded the said cheque amount in cash
from you, but since then you are kept on
passing the time by one pretext to another
and now you instead of making the payment
of the said cheque, you have flatly
refused to pay the said cheque amount to
my client in any manner.
7. That thereafter my client has sent a legal
notice for filing a criminal complaint
case U/s 138 of N.I. Act to you noticee,
but despite receiving the said legal
notice, you noticee neither replied nor
complied the same till date.

8. That you noticee has neither paid nor


tendered the whole of the arrears of rent
to my client w.e.f. August-2015 to till
date despite repeated requests and demands
made by my client.

9. That now my client is not willing to keep


more you noticee as tenant in his premises
as your tenancy is now been terminated by
my client from the date of sending the
present legal notice.

10. That my client requested you noticee on


several occasions to vacate and hand over
the peaceful and vacant possession of the
said tenanted premises to my client, but
you noticee never given any heed to the
requests made by my client, so the
possession of the said accommodation which
is in your possession is illegal and now
you noticee have no right to live in this
premises any more.

11. That you are required to handover the


peaceful vacant possession of the said
tenanted premises to my client within the
stipulated period after receiving the
present legal notice.

12. That you noticee are also liable to pay


the use and occupation charges/damages at
the tune of Rs.20,000/- per month w.e.f.
18.11.2016 to my client till the vacation
of the said tenanted premises, as after
termination of your tenancy, you become
the unauthorized occupant.

I, therefore call upon you through this


legal notice that my client do not wants to
keep you as tenant any more in her premises
and terminated your tenancy with immediate
effect, hence I further call upon you kindly
handover the peaceful vacant physical
possession of the tenanted premises within
30 days after received the said legal notice
otherwise my client shall be constrained to
take legal action against you totally on
your costs, risks and consequences.

You are further called upon to pay the


whole of the arrears of rent to my client
and you are also liable to pay the use and
occupation charges/damages w.e.f 18.11.2016
@ Rs.20,000/- (Rupees Twenty Thousand only)
per month, till the vacation of the said
tenanted premises, as after termination of
your tenancy, you become the illegal
occupant in the said tenanted premises.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.

Copy kept for further references in my


office.

MOMIN KHAN
ADVOCATE
A.Ali Khan F-1, F-Block, 1st Floor,
Advocate Karkardooma Courts,
Delhi-110032.
DELHI HIGH COURT M:- 09312493952
Ref: Date: 27.09.2016

LEGAL NOTICE
REGD.A.D./SPEED POST
To,

1. SH SANJAY @ SONU
S/O SH RADHEY SHYAM,

2. SMT. GAURI,
W/O SH. SONU,

BOTH R/O C-283, 1ST FLOOR, STREET NO.9


NEW USMANPUR, DELHI-110053

Sir/Madam,
Under instructions from and on behalf of my
client namely SH. RADHEY SHYAM, S/O LATE SH.
SURAJ PAL, R/O H.NO.E-283, GALI NO.4, SHRI RAM
COLONY, KHAJURI, DELHI-110094, I hereby serve
upon you through this following legal notice,
facts as under:-

47. That you noticee No.1 are the real son of


my client and you noticee No.2 are the
daughter-in-law of my client, being wife
of noticee No.1.
48. That you both the noticees are regularly
harassing and humiliating my client by
your illegal, and incooperative acts and
activities and being real son and
daughter-in-law, you noticees are not
caring and helping my client and want to
capture the property of my client within
the collusion and by hatching the
conspiracy with the family members of the
noticee No.2.

49. That very often since beginning, you


noticee No.1 and 2 used to quarrel with my
client on minor issues or the others. And
you noticee No.1 and 2 have threatened my
client that you will implicate my client
and his family members in any false
criminal case and since then my client
always remained in great tension.

50. That my client is the owner of the


property bearing No.C-283, STREET
NO.9, NEW USMANPUR, DELHI-110053,
measuring 43½ sq. yards, and the said
property is the self acquired by my client
from his own funds, sources and earnings
and status of you both noticees in the
said property were/are only as a licencee.

51. That you both noticees No.1 & 2 due to


dishonest intention humiliating and
torturing to my client by one pretext and
another at every moment, due to all these
circumstances and seeing the behaviour of
you noticee No.1 & 2, my client have
debarred you both noticees No.1 & 2 by way
of publication of public notice in daily
Newspaper Rashtriya Sahara. The copy of
said publication is enclosed herewith.

52. That after publishing the said debarred


notice, my client have broken all the ties
and relations with you addressee No.1 & 2
and hence you noticee No.1 & 2 have no
right to stay in the above said property
of my client any more in any manner.

53. That my client do not wish to permit you


addressees No.1 & 2 to live in the said
property No. C-283, 1ST FLOOR, STREET NO.9,
NEW USMANPUR, DELHI-110053 in respect of
portion which is in your possession i.e.
complete first floor. You are further
required to be noted that my client have
terminated your living capacity/locus
standi in said premises, therefore you
noticee No.1 and 2 have no right to stay
in the property of my client and both of
you are liable to pay occupational charges
@ Rs.10,000/- per month w.e.f. 01.11.2016
and now you are living in the said
property as unauthorized occupants.

54. That it is relevant to mention here that


when you noticees came to know that my
client have debarred both of you noticees
from their all moveable and immoveable
properties, then you both noticees have
abused my client in filthy and abusive
language and threatened my client to
implicate them in some false criminal
cases and due to the said reason, my
client are under great terror and fear
from you noticees.

55. That despite knowledge and information


regarding debar publication and several
oral requests for vacating of the portion
of the above said property in your
possession, you both did not pay any heed
and also not bothered to vacate the
portion in your possession till date,
hence this notice.

I, therefore call upon you through this


legal notice that you noticee No.1 and 2 to
vacate the premises of my client i.e. C-283,
1ST FLOOR, STREET NO.9, NEW USMANPUR, DELHI-
110053 in respect of portion which is in
your possession, within 15 days from the
date of receipt of this legal notice,
failing which my client instructed me to
initiate appropriate legal action against
you noticee No.1 and 2 totally on your
costs, risks and consequences and you
noticee No.1 and 2 will be liable to pay all
the expenses of litigations to my client.

You are also liable to pay the use and


occupation charges @ Rs.10,000/- per month
to my client in respect of the said premises
w.e.f. 01.11.2016 till the vacation of the
same.

You noticees are liable to pay Rs.5500/-


towards the cost of present legal notice.

Copy kept for further references in my


office.

A.Ali Khan
Advocate
REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SH. PRAHALLAD AGARWALA,
S/O SH. PURANMAL AGARWALA,
R/O RAJBATI, SUNDARGARH TOWN,
P.O. SUNDARGARH, P.S TOWN SUNDARGARH,
DISTT. SUNDARGARH, ODISHA

Sir,
Under the instruction from and on behalf of

my client Sh. Girdhari Lal Gupta, S/O Late Shri

Durga Prasad Agarwal, R/O D.P. Mahajan, A-27,

Sector-27, Noida, U.P, I hereby serve upon you

through the following legal notice, which facts

as under:-

1. That my client is a peace loving and law

abiding citizen of India and he is a

Chartered Accountant by profession and is

having full faith over the due process of

law.
2. That on 19.01.2013 you noticee executed a

Registered Sale Deed in favour of my client

vide E.Registration ID No.741300073,

Document No.11741300069, Book No.I, Volume-2

dated 21.01.2013, in respect of the

following properties/land, the details of

which are tabulated below for the ease of

references:

(i) Full Plot No.160, Kisam-Berna Sa, area

Ac.0.690, decimils, bounded by North-

Ratha Ganda & South: Nij.

(ii) Full Plot No.162, Kisam-Berna Sa, area

Ac.1.370, decimils, bounded by North-

Nij & South: Nij.

(iii) Full Plot No.163, Kisam-Bahal

Sadharan, area Ac.1.84, decimils,

bounded by North & South: Nij.


(iv) Full Plot No.757, Kisam-Goda-II, area

Ac.0.670, decimils, bounded by North &

South: Nij, total area Ac. 4.570, out

of Hal Khata No.33 of Mouza-

Jamujharda, Ps/Tehasil; Hemgir, Distt;

Sundargarh within the jurisdiction of

S.R.(O). Hemgir, Distt. Sundargarh,

under Thana No.35, annual rent of

Rs.30.00 covered under Sale Deed

No.11701100714 of 2011, dt.

05.04.2011, duly Registered and

entered at the office of the D.S.R

Sundargarh, in Book No.I, Volume

No.15.

(v) Full Plot No.65, Kisam-Berna Sa, area

Ac. 0.070 decimils, bounded by North:

Sadhu Lohara & South: Dharma Singh

Dhanuar.
(vi) Full Plot No.177, Kisam-Bahal

Sadharan, area Ac. 0.120 decimils,

bounded by North: Nij, South-Chaitan

Bhuyanr.

(vii) Full Plot No.330, Kisam-Berna Sa, area

Ac. 0.200 decimils, bounded by North:

Nij & South: Nij.

(viii) Full Plot No.333, Kisam-Mal

Sadharan, area Ac. 0.220 decimils,

bounded by North: Badjungal & South:

Badjungal.

(ix) Full Plot No.337, Kisam-Goda-I, area

Ac. 0.840 decimils, bounded by North:

Nij, South: Jungal.


(x) Full Plot No.378, Kisam-Patit, area

Ac. 0.480 decimils, bounded by North:

& South: Nij.

(xi) Full Plot No.757, Kisam-Goda-II, area

Ac. 0.120 decimils, bounded by North:

Nij & South: Chaitan Bhuyan, total

area Ac. 2.720, of Hal Khata No.33, of

Mouza Jamujharia, Ps/Tehasil:Hemgir,

Distt. Sundargarh, under Thana No.35,

annual rent of Rs.20.00 only, covered

under Sale Deed No.11701101097 of

2011, dt 23.05.2011 duly registered

and entered at the office of the D.S.R

Sundargarh in Book No.I, Volume No.23.

The measurement of total land as purchased

by my client from you noticee is area 7.290

acres as already detailed above.


3. That after purchasing the aforesaid lands

from you noticee, my client approached to

the concerned authority for the purpose of

mutation of the aforesaid lands in his

favour.

4. That consequently after filing his

application for mutations of the said lands,

it was utter shock and surprise for my

client when the concerned department of

mutation has only permitted mutation the

land measuring 3.810 acre out of total 7.290

acre. The details of the lands which are to

be mutated in favour of my client are

tabulated below for the ease of references:-

____________________

5. That my client finding no other option

approached to you noticee and apprised you

noticee from the aforesaid fact and my

client requested you noticee to remove any


discrepancies and objections for the purpose

of mutation of the remaining land measuring

3.480 acre in favour of my client from the

concerned department, but you noticee didn’t

give any optimistic response to the said

grievances of my client.

6. That you noticee has sold out the aforesaid

lands in favour of my client after receiving

an agreed and valuable sale consideration,

hence it is your legal and lawful

responsibility to get mutated the aforesaid

all the lands in favour of my client, hence

this notice.

I, therefore call upon you through this

legal notice to cooperate my client to get

mutated the aforesaid remaining lands in

favour of my client from the concerned

authority within 15 days from the date of

receipt of this legal notice otherwise my


client shall be constrained to take legal

action against you totally on your costs,

risks and consequences.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.

Copy kept for further references in my


office.

Ravi Kumar
Advocate

Gopesh Tripathi

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
1. SH SUKHPAL
S/O SH.
2. SH RADHEY SHYAM,
S/O SH.

BOTH AT:
SHOP NO.G-1, MAIN MARKET,
SHAKARPUR, DELHI-110092

Sir,
Under the instruction from and on behalf of

my client MS BHAWNA SINGH, D/O SH. S.P. SINGH,

RESIDENT OF C-62, UG-1, GANESH NAGAR, PANDAV

NAGAR COMPLEX, DELHI-110092, I hereby serve upon

you through the following legal notice, which

facts as under:-

13. That you both the notices have been

jointly inducted as tenants in respect of

one shop viz. SHOP NO.G-1, MAIN MARKET,

SHAKARPUR, DELHI-110092 by the father of

my client namely Sh. S.P. Singh w.e.f

30.07.1992 on a monthly rent of Rs.500/-

per month excluding electricity charges.

The said tenancy is on oral basis.

14. That it is relevant to point out here that

previously the mother of my client namely

Smt. Satya Bhama Devi was the owner of the

aforesaid Shop/tenanted premises and Smt


Satya Bhama Devi was expired on

__________________.

15. That after the death of Smt. Satya Bhama

Devi, all the legal heirs, including my

client had executed a Relinquishment Deed

in favour of their father i.e. Sh. S.P.

Singh in respect of the said shop.

16. That consequently on 13.04.2013, Sh. S.P.

Singh transferred the aforesaid shop in

favour of my client by virtue of

___________________ (please give details

of ownership documents).

17. That since 13.04.2013 my client had been

stepped into the shoes of her father and

became the sole and absolute owner of the

said tenanted shop as well as the landlady

and your tenancy has been automatically

transferred under the landlady-ship of my

client.
18. That it is also an admitted fact that the

rate of rent continued to be revised time

to time and presently the rent is

Rs.1100/- per month excluding electricity

charges.

19. That it is relevant to point out here that

since the date of death of the mother of

my client, you notices became negligent

and careless in making the payment of the

monthly rent of the said tenanted premises

and you noticees always used to make the

payment of the rent to my client or her

father always in delaying manner after a

lot of requests and demands.

20. That you noticees have neither paid nor

tendered the whole of the arrears of rent

at the tune of Rs.1100/- to my client

since January-2016 despite repeated

requests and demands with the malafide


intention and ulterior motives to cause

wrongful loss to my client and wrongful

gain to yourself.

21. That not only this, said tenanted shop is

situated in the main market of Shakarpur,

Delhi and you noticees used to charge

monthly or weekly amount from Fruit and

Vegetable sellers who used to park their

Rehdi in front of the said the said

tenanted shop’s entrance and you used to

receive money from them in lieu of

permitting them to sell their vegetables

and fruits from the front of the said

shop, the same is also amounts to be a

sub-letting, without the permission and

consent of my client, which is illegal and

unwarranted.

22. That my client requested to you noticees

on number of occasion for not doing such


illegal and unwarranted acts and

activities, but all went in vain because

of your rude and aggressive behaviour.

23. That now my client is not willing to keep

more you noticees as tenant in her

premises/shop and my client has terminated

your tenancy with immediate effect.

24. That my client requested you noticees on

several occasions to vacate and hand over

the peaceful and vacant possession of the

said tenanted premises/shop, but you

noticees never given any heed to the

requests made by my client, so the

possession of the said accommodation/shop

which is in your possession is illegal and

now you noticees have no right to live in

the said shop any more.

25. That you are required to handover the

peaceful and vacant possession of the said


tenanted premises/shop to my client within

the stipulated period after receiving the

present legal notice.

I, therefore call upon you through this

legal notice that my client do not wants to

keep you as tenant any more in her premises

and terminated your tenancy with immediate

effect, hence I further call upon you kindly

handover the peaceful vacant physical

possession of the tenanted premises within

15 days from the date of receipt of this

legal notice otherwise my client shall be

constrained to take legal action against you

totally on your costs, risks and

consequences.

You are further called upon to pay the

whole of the arrears of rent to my client

and you are also liable to pay the use and

occupation charges/damages w.e.f 10.11.2016

@ Rs.10,000/- (Rupees Ten Thousand only) per


month, till the vacation of the said

tenanted premises, as after termination of

your tenancy, you become the illegal

occupant in the said tenanted premises.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.
Copy kept for further references in my
office.

Gopesh Tripathi
Advocate

REGD.A.D./SPEED POST
LEGAL NOTICE
To,
SMT. SALMA BEGUM
W/O SH. SHAMIM,
C/O Sh. BIJENDER SINGH GUJAR,
PLOT No.16, VILLAGE KOTLA,
NEAR GUJAR BHAWAN, MAYUR VIHAR,
PHASE-I, DELHI-110092

Sir,
Under instructions from and on behalf of my
client SH. ABDUL WAHID, S/O SH. JAIS MOHAMMED,
R/O 34/36, DDA MINI MARKET, TRILOKPURI, DELHI-
110091, I hereby serve upon you through this
following legal notice, facts as under:-

64. That you and my client having good


friendly and familiar/visiting terms with
each other from the last many years.

65. That consequently in the month of June-


2016, you approached to my client and
requested to arrange a cash of Rs.50,000/-
(Rupees Fifty Thousand only) as a friendly
loan by showing your urgent need of money,
but my client could have arranged a sum of
Rs.32,000/- (Rupees Thirty Two Thousand
only) from her savings and handed over to
you noticee and at the time of borrowing the
aforesaid amount, you assured to my client
that the said amount would be returned
positively within one month.
66. That thereafter my client has approached
to you noticee in the last week of July-
2016, and demanded the said friendly loan
amount of Rs.32,000/- (Rupees Thirty Two
Thousand only), then in discharge of your
above said liability, you issued, signed and
delivered a cheque bearing No.681255 of
dated 07.08.2016 of Rs.32,000/- drawn on
Indian Bank, Branch at Mayur Vihar, Phase-I,
Delhi-110091 and at the time of issuing the
aforesaid cheque you assured to my client
that the said cheque would be honoured
positively at the time of its presentation.

67. That as per your assurance and


instructions my client had presented the
said cheque in his banker i.e. Bank of
India, Branch at Mayur Vihar, Delhi, but the
said cheque was dishonored by your banker
with the remarks “_________________” and my
client has received the returned memo
received of dated 24.05.2016.

68. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque, then you noticee
apologized your guilt and requested my
client to give some more time of two months
and assured that this time you will
definitely arrange the sufficient amount in
your bank account for honouring the said
cheque.

69. That consequently my client again


presented the said cheque in his banker as
per your commitment and instructions, but it
was utter shocking for my client when the
said cheque got again dishonored by your
banker with the remarks “FUNDS INSUFFICIENT”
and my client has received the returned memo
received of dated 19.07.2016.

70. That thereafter my client again


contacted you and revealed the reality about
the dishonor of said cheque, and then my
client demanded the said cheque amount in
cash from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment of
the said cheque, you have flatly refused to
pay the said cheque amount to my client in
any manner.
71. That for discharging your liability, you
issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act R/W section 406/420
of Indian Penal code.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.1,00,000/-
(Rupees One Lac only) to my client within 15
days from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Seema Dogra
Advocate

ARPIT JAIN CHAMBER No.E-401,


ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
ENL.NO.D-1803/2015 M: 9811595800
REF: Date: 07.09.2016
LEGAL NOTICE
REGD.A.D./SPEED POST
To,
THE CHAIRMAN/MANAGING DIRECTOR,
CENTRAL BANK OF INDIA,

HEAD OFFICE AT:


CHANDER MUKHI, NARIMAN POINT,
MUMBAI–400021

ZONAL OFFICE:
THROUGH ITS ZONAL MANAGER/A.R.,
LINK HOUSE, PRESS AREA,
3, BAHADURSHAH JAFAR MARG,
NEW DELHI-110002

REGIONAL OFFICE:
THROUGH ITS REGIONAL MANAGER /A.R.,
1ST FLOOR, 1398, CHANDNI CHOWK,
DELHI-110006

BRANCH OFFICE:
THROUGH ITS CHIEF MANAGER/A.R.,
1398, CHANDNI CHOWK,
DELHI-110006
Sir,

Under instructions from and on behalf of my

client SH. PAWAN JAIN, S/O LATE SH. BAL KISHAN

JAIN, R/O 79, RAJDHANI NIKUNJ APARTMENTS, PLOT

NO.94, I.P. EXTN., DELHI-110092, I hereby serve

upon you through this following legal notice,

facts as under:-

72. That my client is a peace loving and law

abiding citizen of India and is residing at

the above given address and having full

faith over the due process of law.

73. That my above said client is maintaining

a Current Account vide No.1041811470 as well

as the OD Limit for the last more than 25

years back. Besides the above, my client is

also holding the following Current Accounts


with your bank, details of which are

tabulated below for the ease of reference :

(i) A/c No.3287410804 in the joint names

of Pawan Jain & Sonia Jain.

(ii) A/c No.3287293576 in the joint names

of Sonia Jain & Pawan Jain.

(iii) A/c No.3287410189 in the name of

Pawan Jain-H.U.F (Karta of H.U.F is

Pawan Jain i.e. my client).

74. That all the above said FDR’s are in the

name of my client and the same are being

operated by my client’s signature and you

noticee was charging only 1% higher interest

on my client’s OD limit than the FDR’s.

75. That it is very surprising for my client

when on 30.01.2016, a sum of Rs.1731/- were

debited from the account of my client on the

pretext that HUF is a different entity and a


higher rate of interest must be charged for

the OD limit of my client’s account. And

after that you noticee started charging the

11.75% p.a. of interest instead of 9.75%

p.a. from the account of my client.

76. That it is very shocking and unexpected

for my client that after about 25 years,

suddenly you noticee has changed the system

of charging interest in such an arbitrary

manner, which is clear cut deficiencies in

services and unfair trade practice.

77. That my client sent a number of request

letters as well as its reminders through e-

mails, post and personally to you noticee,

being aggrieved from your above said illegal

and unwarranted conduct, but all the efforts

went in vain because of the ignorant

attitude on part of you noticee and your

concerned officials.
78. That last on 26.03.2016, my client has

withdrawn all his FDR’s of Rs.9 Lacs and

surrendered the OD facilities of Rs.8 Lacs

approx. From you noticee’s bank, which does

not cause even a single breath break either

to you noticee or any of your officials,

which clearly shows that you have no regard

and consideration to your loyal and

trustworthy customers.

79. That from your above said illegal and

unwarranted acts, it is crystal apparent

that you are playing with the law from your

own hands and you have no consideration

regarding the guidelines, directions and

norms passed from time to time by the

Reserve Bank of India i.e. the principal

authority which controls banking affairs and

guidelines in our country.


80. That my client has suffered a great

mental tension, pain and agony because of

your deficiencies in services and unfair

trade practice and most specifically on your

non-responsive attitude to the

correspondences of my client.

81. That my client reserves his right to

file separate complaint before the Ombudsman

against you noticee and responsible officers

for their illegal and unwarranted acts.

82. That the above said action of you

noticee is illegal, unjustified, vindictive,

victimizing and against the principles of

natural justice.

83. That you noticee is liable to compensate

my client in a sum of Rs.5 Lacs for

illegally charging the excess amount of

interest from the account/deposits of my

client, hence this notice.


I, therefore call upon you through this

legal notice to compensate my client in a sum

of Rs.5 Lacs for your above said deficiencies

in services and unfair trade practice and for

causing mental harassments, pain and agony to

my client by illegally deducting the excess

amount of interest from the deposits/ account

of my client, within 15 days from the receipt

of this legal notice, failing which my client

shall be constraint to initiate appropriate

civil as well as criminal proceeding against

you totally on your costs, risks and

consequences.

You are also liable to pay Rs.5500/- as

fee of this legal notice.

Copy kept in my office for further


references.

ARPIT JAIN
ADVOCATE
COPY TO:

1. BANKING OMBUDSMAN,
RESERVE BANK OF INDIA,
6, SANSAD MARG,
SANSAD MARG ROAD AREA,
NEW DELHI-110001
Vijaya Tyagi Resi-Cum-Off: 430, Janta Flats
ADVOCATE GTB Enclave, Dilshad Garden
Delhi-110095
DELHI HIGH COURT
EN. No. D-1459/2007 M:- 9990698323
Ref. No. DATED: 06.09.2016

REGD. A.D./SPEED POST


LEGAL NOTICE
To,
M/S PICCADILY NEW DELHI
THROUGH ITS DIRECTOR/M.D/A.RS.
AT: JANAKPURI DISTRICT CENTRE COMPLEX,
DELHI-110 058,

Sir,
Instructions received from and on behalf of
my client Sh. Lalit Singh Rana, S/O Sh. Shankar
Singh Rana, R/O 1205, Janta Flats, GTB Enclave,
Dilshad Garden, Delhi-110095, I hereby serve
upon you through this following legal notice
facts as under:-

17. That my client was appointed by you


noticee as “COMMIS” since 01.10.2013 as
per your assurance that the services of my
client was regularized by you and you have
paid the last drawn salary to my client as
Rs.1,96,140/- (Rupees One Lac Ninety Six
Thousand, One Hundred and Fourty only).

18. That my client has never given any chance


of complaint to you and worked all along
to the satisfaction of you noticee and my
client has never given any chance of
complaint towards his duty at any point of
time.

19. That on 14th August-2016, one of the


employee namely Shyam who is posted on
same post, picked quarrel with my client
on some minor issues and he even scolded
my client without any rhyme and reason and
he insulted my client publically.

20. That it is pertinent to mention here that,


on this, you noticee without confirming
the actual and true facts, started
manhandling my client and rather
threatened my client to expel him from his
services without any prior notice.

21. That since then you noticee and your


concerned official have started harassing
and humiliating my client on his job and
started pressurizing my client to give his
resignation.

22. That since 17.08.2016, you noticee have


not permitted my client to enter into your
hotel to join his services illegally and
unlawfully. The termination of my client
is quite illegal, unjustified and without
sufficient cause and reason.

23. That it is also relevant to point out here


that you noticee have not paid the salary
of my client for the months of July and
August, 2016 and you have illegally
withheld the same without any right.

24. That the action of you noticee of


terminating the services of my client, is
illegal, unjustified, vindictive,
victimizing and against the principles of
natural justice and fair play and my
client is entitled to reinstatement in
services with full back wages and other
service benfits and due salary according
to Minimum Wages Act.
25. That even you noticee have taken the
signatures of my client on various blank
papers.

I, therefore call upon you through this


legal notice to reinstate the services of my
client with full back/earned wages and
overtime and other service benefits/
consequential benefits of my client and
continuity of services, within 07 days from
the date of receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate legal proceedings
against you totally on your costs, risks and
consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Vijaya Tyagi
Advocate
PANKAJ BHUSHAN CHAMBER No.E-401,
ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date:

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SHRI GIRI RAJ,
S/O LATE SHRI DEVI RAM,
R/O X/1758, GALI NO.10,
RAJGARH COLONY, DELHI-110031
Sir,
Under the instruction from and on behalf of
my client SMT SUMAN PAHUJA, W/O SH. NARENDER
KUMAR PAHUJA, R/O 235, SURYA NIKETAN, DELHI-
110092, I hereby serve upon you through the
following legal notice, which facts as under:-

26. That my client is the lawful owner/


Landlord of the property bearing
No.X/1758, GALI NO.10, RAJGARH COLONY,
DELHI-110031 and on 16.02.2015 my client
had let out the portion of said property
i.e. ONE SHOP on the ground floor to you
noticee on a monthly rent of Rs.10,000/-
per month excluding electricity and water
charges.

27. That it is relevant to point out here that


the said tenancy was on written basis, as
a rent agreement dated 16.02.2015 was duly
executed between you noticee and my client
for a period of three years commenced
w.e.f. 16.02.2015 to 15.02.2018.

28. That it has been agreed in column No.13 of


the said rent agreement that “...the
landlord shall give One Month notice to
the tenant for vacating the said premises
before the expiry of the tenancy period,
and if the tenant wishes to vacant the
said premises before the expiry of the
tenancy he shall have give the notice of
One month to the landlord, or a rent of
one month to the landlord...”

29. That it has been further agreed in column


No.18 of the said rent agreement that
“...if the tenant shall fail to pay the
rent for any two months consecutively or
default in any terms and conditions of
this rent deed then the owner shall have
full right to terminate the tenancy of the
said tenant and evict him from the said
Property...”

30. That since May-2016, you noticee has not


paid even a single penny towards the
arrears of rent to my client till date
despite repeated requests and demands made
by my client.

31. That now my client is not willing to keep


more you noticee as tenant in his premises
as your tenancy has terminated w.e.f.
01.09.2016.

32. That you are required to handover the


peaceful vacant possession of the said
tenanted premises to my client within the
stipulated period after receiving the
present legal notice.

33. That it is pertinent to mention here that


you noticee are harassing, humiliating and
torturing my client by your illegal and
unwarranted acts without any sufficient
cause and reason.
I, therefore call upon you through this
legal notice that my client do not wants to
keep you as tenant any more in her premises
and terminated your tenancy with immediate
effect, hence I further call upon you kindly
handover the peaceful vacant physical
possession of the tenanted premises within
15 days after received the said legal notice
otherwise my client shall be constrained to
take legal action against you totally on
your costs, risks and consequences.

You are further called upon to pay the


whole of the arrears of rent to my client
and you are also liable to pay the use and
occupation charges/damages w.e.f 01.10.2016
@ Rs.20,000/- (Rupees Twenty Thousand only)
per month, till the vacation of the said
tenanted premises, as after termination of
your tenancy, you become the illegal
occupant in the said tenanted premises.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.

Copy kept for further references in my


office.
PANKAJ BHUSHAN
ADVOCATE

PANKAJ BHUSHAN CHAMBER No.E-401,


ADVOCATE E-BLOCK, FOURTH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-
110032.
ENL.NO.D-325/1996 M: 9810227708
REF: Date:

REGD.A.D/SPEED POST
LEGAL NOTICE
To,
SMT RAJWATI @ RAJ BIRI,
W/O LATE SHRI DEVI RAM,
R/O X/1758, GALI NO.10,
RAJGARH COLONY, DELHI-110031

Sir,
Under the instruction from and on behalf of
my client SMT SUMAN PAHUJA, W/O SH. NARENDER
KUMAR PAHUJA, R/O 235, SURYA NIKETAN, DELHI-
110092, I hereby serve upon you through the
following legal notice, which facts as under:-

36. That my client is the lawful owner of the


property bearing No.X/1758, GALI NO.10,
RAJGARH COLONY, DELHI-110031 and my client
has purchased the said property from you
noticee by virtue of Regd. General Power
of Attorney vide Regn. NO.187, in Book
No.4, Vol. No.59, on pages 89 to 93 dated
25.02.2016 before the office of Registrar
SR IVb, Vivek Vihar, Delhi executed by you
noticee, being the erstwhile owner of the
said property in a sum of Rs.9.25 Lacs and
you noticee also executed Agreement to
Sell, Affidavit, Receipt, WILL etc.

37. That it is relevant to point out here that


at the time of selling out the said
property, you noticee told my client to
permit you noticee to reside in the said
property as a licensee in the said
property, as you noticee disclosed that
you are arranging a suitable residential
accommodation for yourself and you need
two months to arrange and shift in another
premises.

38. That my client became agreed with you


noticee and on humanitarian ground and
considering your old age, my client
permitted you noticee to live in the said
property as a licensee only for two
months.
39. That on 1st May-2016, my client requested
you noticee to vacate the said premises,
but you noticee made false and frivolous
pretexts and since then you noticee always
kept passed the time by one pretext or the
other with the malafide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.

40. That thereafter again on 15.07.2016 my


client again met with you noticee and
requested to vacate the said premises, as
your two month’s period of license has
already been expired, but you noticee
didn’t pay any heed to the requests of my
client.

41. That now my client is not willing to keep


you noticee more as licensee in her
premises and terminated your license with
immediate effect.

42. That you are required to handover the


peaceful vacant possession of the said
property to my client within the
stipulated period after receiving the
present legal notice.
I, therefore call upon you through this
legal notice that my client do not wants to
keep you as licensee any more in her
premises and terminated your license with
immediate effect, hence I further call upon
you kindly handover the peaceful vacant
physical possession of the said premises
within 15 days after received the said legal
notice otherwise my client shall be
constrained to take legal action against you
totally on your costs, risks and
consequences.

You are further called upon to pay the


use and occupation charges/damages w.e.f
01.10.2016 @ Rs.20,000/- (Rupees Twenty
Thousand only) per month being illegal
occupant in the said property, till the
vacation of the same.

You are also liable to pay Rs.11,000/-


as legal expenses to my client.

Copy kept for further references in my


office.

PANKAJ BHUSHAN
ADVOCATE
UMESH PRASAD Chamber No.569, Lawyers Chamber
ADVOCATE Patiala House Courts, New
Delhi-01
Office at: 411, 4th Floor, Saket Courts
(DELHI HIGH COURT) Complex, New Delhi-110017
M: - 08860639126 & 09818628815
E-mail: umeshprsad@yahoo.com
===============================================================================
Ref: Dated: 24.08.2016

LEGAL NOTICE
SPEED POST
To,
SH RAMESH KUMAR
S/O SH.DODA MAL,
R/O B-230, SANGAM VIHAR,
NEW DELHI-110080,

Sir,
Instruction from and on behalf of my client
SH JAGDISH GUPTA, S/O Sh. GULAB CHAND GUPTA, R/O
992/9, 2ND FLOOR, GOVIND PURI, KALKAJI, NEW
DELHI-110019, I hereby serve upon you through
this following legal notice, facts as under:-
1. That you and my client are well acquainted
with each other for the last about 8 years
back, as both are in same business of
mobile accessories at Nehru Place, New
Delhi.

2. That by passing the time, you noticee has


established the faith over my client and
my client started keeping faith over you
being good relations. Consequently you
noticee was in urgent need of money and in
the second week of June-2016, you noticee
approached to my client and requested my
client to arrange Rs.5,00,000/- (Rupees
Five Lacs only) for his urgent need in
business and due to good friendly
relations and visiting terms, my client
arranged Rs.5,00,000/- (Rupees Five Lacs
only) and handed over the said amount to
you noticee in cash on 24.06.2016 after
withdrawing from his bank i.e. ICICI Bank
Ltd. New Delhi and given the same to you
in the presence of Sh. Sunil Gupta, S/O
sh. Gulab Chand Gupta, R/O 1384/13, 2nd
Floor, Govind PUri, Kalkaji, New Delhi-
110019 and Sh. Mukesh Mehta, S/O sh. Lala
Mehta, R/O 875/7, Govind PUri, Kalkaji,
New Delhi-110019 at his above residence
and at the time of borrowing the said
amount of Rs.5,00,000/- (Rupees Five Lacs
only) you noticee promised to return the
said borrowed amount within 15 days
positively.

3. That on 20.07.2016, you noticee approached


at the address of my client and in
discharge of remaining liability, you
noticee had issued a cheque bearing
No.028812 of dated 21.07.2016 of
Rs.5,00,000/- drawn on Bank of Baroda,
Branch at Nehru Place, New Delhi in favour
of my client against the said friendly
loan and at that time, you noticee assured
that the said cheque would be encashed
positively on its presentation.

4. That as per the instructions of you


noticee, my client had presented the said
cheque with his banker i.e. ICICI Bank,
Branch at Nehru Place, New Delhi, but the
same was returned unpaid by the banker of
you noticee with the remarks “FUNDS
INSUFFICIENT” and my client received the
information through returning memo dated
26.07.2016.

5. That after receiving the said information


of dishonour of cheque, my client
immediately contacted you noticee and
disclosed the fact about the dishonour of
the said cheque and demanded the said
cheque amount in cash, but you noticee
kept passed the time by one pretext or the
other and now on 23.08.2016, you noticee
have flatly refused to make the payment of
the said dishonour cheque to my client in
any manner.

6. I hereby call upon you through this legal


notice to make payment of the amount of
the aforesaid dishonoured cheque within
15(fifteen) days from the receipt of this
notice, either to my client directly at
its abovementioned address or to us being
our client’s advocate/counsel, at my above
mentioned office.

7. It is brought to your notice that as per


the Chapter XVII of the Negotiable
Instruments Act the dishonour of cheque
attracts imprisonment to the extent of two
years or with fine, which may extend to
twice the amount of the cheque or with
both, in addition to the punishment the
courts are also impowered to grant
compensation, at the cost of the accused,
to the complainant for interest,
expenditure & costs incurred by the
complainant for pursuing the complaint.
8. That in case you failed to pay the said
amount of the dishonoured cheque within 15
days of the receipt of this notice either
to my client directly or to me as his
advocate /counsel, I have clear
instructions to initiate appropriate legal
civil as well as criminal proceedings
against you, entirely at your risk, as to
costs and consequences, without any
further reference to you.

9. A copy of this notice is being kept in my


office for further proceedings.

UMESH PRASAD
(ADVOCATE)
REGD. A.D./SPEED POST
LEGAL NOTICE Dt. 24.08.16
To,
M/S PUKHRAJ HEALTH CARE PVT. LTD.
THROUGH ITS DIRECTOR/M.D./A.R.
REGD. OFFICE AT:
SCF-13, 2ND FLOOR,
URBAN ESTATE-1, JALANDHAR
(PUNJAB)

Sir,
Instructions received from and on behalf of
my client Sh. Krishan Gopal, S/O sh. Nathi Lal,
R/O H.No.9, Karnal Farm, Tigri, New Delhi-
110062, I hereby serve upon you through this
following legal notice facts as under:-

26. That my client was appointed by you


noticee as “Sales Executive” since
15.02.2016 as per your assurance that the
services of my client was regularized by
you and you have paid the last drawn
salary to my client as Rs.12,000/- per
month alongwith Rs.150/- per day +
Rs.300/- per month as mobile expenses and
in this regard an Appointment Letter was
also issued by you on 25.02.2016.

27. That my client has never given any chance


of complaint to you and worked all along
to the satisfaction of you noticee and my
client has never given any chance of
complaint towards his duty at any point of
time.

28. That my client has always remained honest,


diligent, hardworking and sincere towards
his work.
29. That since 18.08.2016, you noticee have
terminated the services of my client
without any sufficient rhyme and reasons
by serving an email regarding negligence
of work, my client has duly revert back
the aforesaid e-mail, but to no response.
The termination of my client is quite
illegal, unjustified and without
sufficient cause and reason.

30. That the action of you noticee of


terminating the services of my client, is
illegal, unjustified, vindictive,
victimizing and against the principles of
natural justice and fair play and my
client is entitled to reinstatement in
services with full back wages and other
service benfits.

31. That it is also relevant to point out here


that you noticee has not provided any
service benefits to my client
intentionally and deliberately.

32. That it is pertinent to mention here that


you noticee is still liable to pay all the
service benefits to my client.

33. That you noticee are liable to pay the due


expenses for whole month of July, 2016 and
for 18 days for August, 2016.
I, therefore call upon you through this
legal notice to reinstate the services of my
client with full back/earned wages and
overtime and other service benefits/
consequential benefits of my client and
continuity of services, within 07 days from
the date of receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate legal proceedings
against you totally on your costs, risks and
consequences.

You are also liable to pay Rs.11,000/-


as fee of this legal notice.

Copy kept in my office for further


references.

RANI BHARDWAJ
(ADVOCATE)
CHAMBER NO.308,
LAWYERS CHAMBERS
SAKET COURTS COMPLEX
NEW DELHI
REGD.A.D./SPEED POST
LEGAL NOTICE
To,
1. SHRI MAHENDER
S/o LATE SH PARMANAND,
R/o H.No.1/100058, 2ND FLOOR,
WEST GORAKHPARK, DELHI-110032

2. LALIT SAPRA
S/o SH MAHENDER,
R/o H.No.1/100058, 1ST FLOOR,
WEST GORAKHPARK, DELHI-110032

Sir,
Under instructions from and on behalf of my
client SMT. RAM DITI, W/o LATE SH PARMANAND, R/o
1/9997, WEST GORAKH PARK, DELHI, I hereby serve
upon you through this following legal notice,
facts as under:-

1. That my client is aged about 75 years old


widow lady and senior citizen of India and
having full faith over the due process of
law.

2. That my client is the sole and absolute


owner of the property bearing No.
1/100058, West Gorakh Park, Shahdara,
Delhi-110032, measuring area about 50 Sq.
Yds., duly built upto three storey i.e.
ground, first and second floor.

3. That you noticee No.1 is the real son of


my client and noticee No.2 is the grandson
of my client, being son of noticee No.1.

4. That my client had executed a Will in


respect of the aforesaid property in
favour of you noticee No.1 on 31.07.2013,
but since then the behaviour of you
noticee No.1 & 2 had become changed and
you both the noticees started treating my
client with cruelties, atrocities and
tortures with the malafide intention and
ulterior motives to cause wrongful loss to
my client and wrongful gain to yourself.
And due to your aforesaid conduct and
attitude, my client got cancelled the
aforesaid WILL deed from the concerned
Sub-Registrar and the same is no more in
existence in any manner.

5. That my client was well within the


possession and occupying the said property
since the date of its purchase and my
client has permitted you noticees to live
in the said property as licensees, but in
the year 2015 you noticee No.1 & 2 within
the collusion and conspiracy of each
other, have forcibly dispossessed my
client from the said property and finding
no other option, my client had no place to
reside, but to live in the parking space
of property bearing H.No.1/9997, West
Gorakhpark, Delhi-110032, which is in the
name of the wife of you noticee No.1
namely Chandrakanta, who had expired on
25.11.2015.

6. That it is pertinent to mention here that


not only this, you noticees No.1 and 2
have kept a person namely Sachin, S/O Sh.
Devender on ground floor of the said
property as your tenant without having any
right, title or interest and even without
the permission and consent of my client,
for which my client is going to initiate
separate legal proceedings.

7. That my client being the owner of the


aforesaid property, do not wish to permit
you both the noticees to live on the first
and second floor of the said property
bearing No. 1/100058, West Gorakh Park,
Shahdara, Delhi-110032 in any manner. You
are further required to be noted that my
client has terminated your license/living
capacity/locus standi to live in said
premises, therefore you noticees have no
right to stay in the property of my client
as licensees and both of you are liable to
pay the use and occupational charges @
Rs.10,000/- per month w.e.f. 25.09.2016
and now you are living in the said
property as unauthorized occupants.

8. That you are further required to note that


you notices not indulge yourself in
receiving the rent from the above said
tenant of ground floor in future after
receiving this legal notice, as you
noticee have no more permission and
authority to receive the rent from the
said tenant in any manner, otherwise my
client renders yourself for criminal
trespass and other legal consequences as
laid down under the law.
I, therefore call upon you through this
legal notice to vacate the said premises of
my client i.e. first and second floor of the
said property bearing No. 1/100058, West
Gorakh Park, Shahdara, Delhi-110032, which
is in your possession, within 15 days from
the date of receipt of this legal notice,
failing which my client instructed me to
initiate appropriate legal action against
you noticees No.1 and 2 totally on your
costs, risks and consequences and you
noticees will be liable to pay all the
expenses of litigations to my client.

You are also liable to pay the use and


occupation charges @ Rs.10,000/- per month
to my client in respect of the said premises
w.e.f. 25.09.2016 till the vacation of the
same.

Copy kept in my office for further


references.
REGD.A.D./SPEED POST
LEGAL NOTICE
To,
SH MOHD. ASIF
S/O SH. MUSTAQ AHMED,
R/O D-2/117, GALI NO.2, B-BLOCK,
DAYALPUR, DELHI-110094

Sir,
Under instructions from and on behalf of my
client SH MOHD. SAJID ANSARI, S/O SH. ABDUL
MAJEED, R/O 12-A/64, GALI NO.3, VIJAY MOHALLA,
MAUJPUR, DELHI-110053, I hereby serve upon you
through this following legal notice, facts as
under:-

84. That you and my client having good


friendly as well as visiting terms with each
other from the last many years.

85. That consequently in the month of


December-2015, you approached to my client
and requested to arrange a cash of
Rs.1,00,000/- (Rupees One Lac only) as a
friendly loan by showing your urgent
personal requirement, consequently my client
arranged a sum of Rs.1,00,000/- (Rupees One
Lac only) and handed over to you noticee in
the last week of December-2015 and at the
time of borrowing the aforesaid amount, you
assured to my client that the said amount
would be returned positively within 4-5
months.

86. That thereafter my client has approached


to you noticee in the last week of April-
2015, and demanded the said friendly loan
amount of Rs.1,00,000/- (Rupees One Lac
only), then in discharge of your above said
liability, you issued, signed and delivered
a cheque bearing No.736120 of dated
18.05.2016 of Rs.1,00,000/- drawn on Punjab
National Bank, Branch at Karawal Nagar,
Delhi-110094 and at the time of issuing the
aforesaid cheque you assured to my client
that the said cheque would be honoured
positively at the time of its presentation.

87. That as per your assurance and


instructions my client had presented the
said cheque in his banker i.e. ICICI Bank,
Branch at____________________, Delhi, but
the said cheque was dishonored by your
banker with the remarks “FUNDS INSUFFICIENT”
and my client has received the returned memo
received of dated 24.05.2016.

88. That immediately my client contacted to


you and disclosed the fact about the
dishonor of said cheque, then you noticee
apologized your guilt and requested my
client to give some more time of two months
and assured that this time you will
definitely arrange the sufficient amount in
your bank account for honouring the said
cheque.

89. That consequently my client again


presented the said cheque in his banker as
per your commitment and instructions, but it
was utter shocking for my client when the
said cheque got again dishonored by your
banker with the remarks “FUNDS INSUFFICIENT”
and my client has received the returned memo
received of dated 19.07.2016.

90. That thereafter my client again


contacted you and revealed the reality about
the dishonor of said cheque, and then my
client demanded the said cheque amount in
cash from you, but since then you are kept
passing the time by one pretext to another
and now you instead of making the payment of
the said cheque, you have flatly refused to
pay the said cheque amount to my client in
any manner.

91. That for discharging your liability, you


issued, signed and delivered the above said
cheque, which was dishonored by your banker,
as you noticee have not arranged the
sufficient amount in your banker/ account
and thus you breached the trust of my client
and committed an offence punishable under
section 138 of N.I. Act R/W section 406/420
of Indian Penal code.

I, therefore call upon you through this


legal notice to return the amount of above
said dishonoured cheque i.e. Rs.1,00,000/-
(Rupees One Lac only) to my client within 15
days from the receipt of this legal notice,
failing which my client shall be constrained
to initiate appropriate civil as well as
criminal proceeding against you totally on
your costs, risks and consequences.
You are also liable to pay Rs.5500/- as
fee of this legal notice.

Copy kept in my office for further


references.
M.A. SAMANI
ADVOCATE
Ocean Chaudhary CHAMBER No.F-619,
ADVOCATE F-BLOCK, 6TH FLOOR,
KARKARDOOMA COURT
DELHI HIGH COURT COMPLEX, DELHI-110032.
ENL. No.D- M: 9212577259
Ref. No. Dated:
REGD. A.D./SPEED POST
LEGAL NOTICE
To,
M/S NAME OF COMPANY___________
THROUGH ITS PROPRIETOR
MR. GIRISH KUKREJA,

OFFICE AT:
6929, PREM GALI, ASHOK GALI,
GANDHI NA GAR, DELHI-110031

ALSO AT (RESIDENCE):
D-1, SURAJMAL VIHAR,
DELHI-110092

Sir,
Instructions received from and on behalf of

my client SH SANTOSH KUMAR, S/O SH. KEDAR SINGH,

PRESENTLY RESIDING AT: C-27, GHAZIPUR, DELHI-

110096 I hereby serve upon you through this

following legal notice facts as under:-

34. That my client was appointed by you

noticee as “DRIVER” in the year 2004 and

as per your assurance that the services of


my client was regularized by you and you

have paid the last drawn salary to my

client as Rs.15,000/- per month.

35. That my client has never given any chance

of complaint to you and worked all along

to the satisfaction of you noticee and my

client has never given any chance of

complaint towards his duty at any point of

time.

36. That it is pertinent to mention here that

the duty hours of my client was from 9:30

AM in the morning till 7:00 PM, but you

noticee always got done the over-time from

my client upto 9:30 PM till night even

without any over-time and wages.

37. That you noticee has not paid the due

salary to my client since March-2016 and

my client requested you noticee on many

occasions to pay the all due salary, but


you always kept passed the time by one

pretext or the other.

38. That on 26.07.2016 when my client demanded

his all due salary from you noticee, you

noticee have terminated the services of my

client without any sufficient rhyme and

reasons. It is relevant to point out here

that on 26.07.2016 when my client went to

his job as usual, then you noticee was not

present at your home and your wife Smt.

Kanika Kukreja told my client to make a

telephonic call to you noticee and when my

client called you noticee on your mobile

no.9268924037, then you have disconnected

the phone and redial from landline No.011-

22074129 at 10:15 AM that no need to come

on job since now and even you noticee had

abused my client in filthy and abusive

language and rather threatened my client

to face dire consequences. The termination


of my client is quite illegal, unjustified

and without sufficient cause and reason.

39. That the action of you noticees of

terminating the services of my client, is

illegal, unjustified, vindictive,

victimizing and against the principles of

natural justice and fair play and my

client is entitled to reinstatement in

services with full back wages and other

service benfits and due salary according

to Minimum Wages Act.

40. That it is pertinent to mention here that

you noticee is still liable to pay the all

due salary to my client from March-2016

till date and overtime since the date of

joining the job by my client i.e. Since

2004.

I, therefore call upon you through this


legal notice to reinstate the services of my
client with full back/earned wages and other
service benefits/consequential benefits of
my client and continuity of services, within
07 days from the date of receipt of this
legal notice, failing which my client shall
be constrained to initiate appropriate legal
proceedings against you totally on your
costs, risks and consequences.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

Ocean Chaudhary
Advocate
LEGAL NOTICE
REGD.A.D./SPEED POST
To,
M/S PACL INDIA LIMITED,
THROUGH ITS DIRECTOR
REGD. OFFICE AT:
22, 3RD FLOOR, AMBER TOWER,
SANSAR CHAND ROAD, JAIPUR-302 004,

CORPORATE OFFICE AT:


7TH FLOOR, GOPALDAS BHAWAN,
BARAKHAMBA ROAD, NEW DELHI-110001

Sir,
Under instructions from and on behalf of my
client KASHISH KUMARI (MINOR), D/O SH. NANHE
LAL, THROUGH HER FATHER/ NATURAL GUARDIAN I.E.
SH. NANHE LAL, R/O H.O.A. 803, MOHALLA RAJEEV
COLONI NAGAR, GHAIZIABAD, U.P., I hereby serve
upon you through this following legal notice,
facts as under:-

92. That my client is a minor, hence she is


being represented through her father
/natural guardian as above named.

93. That my client is a peace loving and law


abiding citizen of India and is residing at
the above given address and having full
faith over the due process of law.

94. That you noticee is a company which


deals in real estate and civil construction
work etc. and operating your business at the
above given addresses.

95. That my client had booked a plot


measuring 1000 sq. Yards with you noticee in
your scheme and in this regard a Registrtio
Letter vide S.No.CB40B 7471184 was issued by
you noticee on 21.06.2010, vide registration
No.U032275202 and the said amount was to be
paid in instalment as per the payment plan
of you noticee.
96. That thereafter my client has paid the
instalment of the aforesaid booking of plot
to you noticee without any delay or default.

97. That my client approached to you noticee


on various occasions and demanded the
possession of the plot, but on each and
every occasions, you noticee kept passed the
time by one pretext or the other with the
malafide intention and ulterior motives to
cause wrongful loss to my client and
wrongful gain to yourself.

98. That now you noticee has flatly refused


to give the possession of the aforesaid flat
to my client or even a single penny to my
client in any manner.

99. That you noticee has played fraud and


cheating with my client and my client is
also going to initiate civil as well as
criminal proceedings against you noticee
before the competent court of law.

I, therefore call upon you through this


legal notice to hand over the peaceful
possession of the above said booked plot to
my client within 15 days from the receipt of
this legal notice, failing which my client
shall be constraint to initiate appropriate
civil as well as criminal proceeding against
you totally on your costs, risks and
consequences.

You are also liable to pay a sum of


Rs.2,00,000/- as damages/compensation for
mental and physical torture, deficiencies in
services, unfair trade practice to my
client.

You are also liable to pay Rs.5500/- as


fee of this legal notice.

Copy kept in my office for further


references.

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