From the Desk of:

SONIA GILL, Villa No. 83, Krishna Kunj Villas,

ADVOCATE, RAJASTHAN HIGH COURT Kalwar Road, Jhotwara Jaipur,
FOUNDER PARTNER, AASLAW Rajasthan-302012

Speed Post/Regd. A.D. Date: 17/03/2020

To,

1. Manish Goyal,

S/o. Vishnudutt Goyal

14/23, Sita Ram Bazar Kesarganj, Ajmer Rajasthan
305001
2. Amit Bhola

R/o Bhola Bhawan St. Stephan School

Near Dairy Boot, Makarwali Road, GC Road
Ajmer-305007

SUBJECT: LEGAL NOTICE FOR UNFAIR TRADE PRACTICE.

Dear Receivers,

Under instructions and authority from my Client Mr. Yogendra Singh (hereinafter

referred to as ‘My Client’), Permanent Resident of Chirawa, Digania, Dist. Jhunjhunun-

333027. I hereby serve upon you, the Noticee, the following legal notice:

1. By this demand notice, I invite your attention that My Client who is a proprietor. He

is a reputed and respected member of society. Suffice it to say that my client enjoys a

good reputation in public life.

2. That My Client took your premises situated at Ajmer Road, Pushkar for hotel

business. That in pursuance several negotiations which were undertaken between

My Client and You Receiver no.1 through assistance of Receiver No.2 (Whom My

Client paid the commission as per the market rate), both the parties entered into an
From the Desk of:
SONIA GILL, Villa No. 83, Krishna Kunj Villas,
ADVOCATE, RAJASTHAN HIGH COURT Kalwar Road, Jhotwara Jaipur,
FOUNDER PARTNER, AASLAW Rajasthan-302012

Lease Agreement dated 25.04.2019 (hereinafter referred to as “the said Agreement”)

and have agreed to abide by the terms and conditions of the said agreement.

3. That in pursuant of the agreement, My Client paid You Receiver no.1 all the

payment as per the Agreement and complied with the performance of its all

contractual commitments.

4. That pursuant to the said Agreement, You were supposed to provide all the facilities

including Leakage, seepage, glass elevation, light, open restaurant pack and AC

installation. You Noticee had done only one Leakage work for which you availed Rs.

40,000 from My Client. You Noticee had done that work in haste and in

unprofessionalism manner. Your service was not up to the mark as it changed the

appearance of the Hotel and it started appearing as Guest House. Most of the

customer complained regarding the aforesaid issue and due to your default in

service, my client’s hotel got negative rating and remarks. Your non-responsive and

unfair trade practice gravely adversely affected my client’s business.

5. That despite a number of telephonic & personal reminders, you considerably have

failed to make the necessary repair and did not accede to the genuine request of My

Client. My client had record of all the telephonic conversations done in this

matter. Furthermore, you started to put the matter off and on, on the one pretext or

the other.

6. You Noticee denied giving the User ID and Password of C Form portal in order to

create hurdles in my business. Now, since the Elvis has left the building and My

Client is left with no other option but to get you served with the present legal notice.

7. We are constrained to state that aforesaid act from your side prove your intention to

commit and perpetuate fraud on my client and indulge in cheating and criminal

misappropriation.
From the Desk of:
SONIA GILL, Villa No. 83, Krishna Kunj Villas,
ADVOCATE, RAJASTHAN HIGH COURT Kalwar Road, Jhotwara Jaipur,
FOUNDER PARTNER, AASLAW Rajasthan-302012

8. That, the above said act on your part has caused us great loss and damage besides

mental tension, trauma and inconvenience and loss of value of money. Due to this

My Client is not in position to run the business beyond 25 th march, 2020. The Period

of agreement (11th Month) is also expiring in the end of this month.

9. This legal notice may be treated as the last and final communication on the issue as

My Client had already suffered a lot due to your deficiency.

10. Therefore, I call upon you the Noticee to immediately and with utmost expediency

undertake to carry out the following action, namely:

(i) To refund my security deposit and amount already paid to you with

interest and charges paid for service;

(ii) To pay compensation towards My Client in sum of Rs. 15,00,000/- on

account of the mental pain and agony suffered by My Client as well as

business losses incurred due to your default which is totally illegal,

arbitrary and unfair trade practice;

(iii) To pay a sum of Rs. 1,00,000/- towards the cost of the present legal notice.

Since your illegal behavior has necessitated the issue of this notice, you

are hereby charged with its costs.

(iv) Take back possession of the property by 25th March, 2020.

11. That under these circumstances, You are required to comply with the above

demands forthwith and in any case no later than 15 days from the receipt of this

notice, failing which My Client shall be constrained to initiate appropriate criminal

and civil actions against you as per law, entirely at your risk and cost.

12. THE CONSEQUENCES THAT MAY FOLLOW IF YOU FAIL TO COMPLY TO

LEGAL EXPECTATION STATED HEREINBEFORE –

From the Desk of:
SONIA GILL, Villa No. 83, Krishna Kunj Villas,
ADVOCATE, RAJASTHAN HIGH COURT Kalwar Road, Jhotwara Jaipur,
FOUNDER PARTNER, AASLAW Rajasthan-302012

(a) Take notice that a criminal complaint before Police in the shape of FIR may

also be filed against you, followed by inevitable action of the Police; 

(b) Take notice that if you do not make payment within 15 days from receipt of

this notice, then a Summary Suit may also be filed against you in the

competent court of jurisdiction;

(c) Take notice that all costs of above litigations will be recovered from you.

13. A copy of the present legal notice is being retained in my office for the record.

THANKING YOU IN THE ANTICIPATION OF YOUR EFFECTIVE ACTION IN

THIS REGARD.

Yours Truly Settled By

SONIA GILL ASHISH KUMAR GILL

ADVOCATE ADVOCATE