Mobile: 93831 23422

93811 23422

R. THANJAN B.A., LLB

R. SENTHIL KUMAR B.Sc., LLB
G. Jai Singh B.sc., LLB
ADVOCATES, MADRAS HIGH COURT
Chamber: No.264, New Addl. Chamber, High Court Campus, Chennai –600 104.
BY RPAD Date: 12.12.2022

To:
Mr. Santhosh. B
S/O. Baskar
Padmavath Nagar 7th Cross street,
Vinayagapuram, Puzhal,
Chennai – 600 099

Madam/Sir,
Under instructions from our client Mr. M.H.Mohammed Aneez , Aged 32 years,
residing at 88, Krishna flats, Ponnankinaru street, Villivakkam, Chennai – 600 049,
we are issuing the following notice to you .
Our Client instructed us to state that you are well known to our client and
both of you are friends for several years – almost 10 years , gained trust from our
client and became family friends also for years. Upon gaining trust, you have
approached our client for financial assistance for your business especially for a EB
contract work. Our client came forward for financial assistance by way of providing
loan with condition to repay the Loan within six months from the date of receipt of
the loan.
Our Client further instructed us to state that our client has even visited your
home in Puzhal at 7, vinayagapuram, Chennai-99, discussed with you and your
parents regarding the Loan and also transferred the sum of 32,00,000 in various
dates from his bank account------ as follows,
Our client further instructed us to state that after expiry of 6 months, you had
suddenly cut down the contact from our client, not answering the phone calls and
started evading from our client. No other way, our client had visited your home in
Puzhal, to the shock and surprise our client came to know that you had vacated the
house already and our client can’t able to trace your whereabouts.
Our client instructed us to state that no other way, our client had lodged a
police complaint on 30.03.2022 ( CSR No 293/2022 ) in M3 Puzhal Police Station
and over Investigation by the Police, you have came forward to repay the loan with
in 3 months and same had been agreed by our client. But you have again started
evading from our client and no other way, our client again approached M3 Puzhal
Police station for non payment of the Loan amount and you have been arrested and
remanded to Judicial custody on 26.08.2022 for the Offences punishable under
Section 406 and 420 of Indian Penal Code in Crime No. 717/2022.
Our client further instructed us to state that our client heard that you have came
out of Judicial custody by conditional bail on 06.10.2022 and on approach you have
came foreward to meet our client and ready to make a deal out of the court
settelement and for that our client had meet you in a coffee shop with one of his
friend Mr. Senthil and received 2 cheques for 16,00,000 each and asked my client to
deposit one cheque for Rs.16,00,000 on 29.11.2022. With positive hopes, our client
has deposited one cheque with his Banker –HDFC Bank, Vinayagapuram Branch,
Chennai-600 099 , bearing Cheque No.000001 ( Bank : City Union Bank,
Vinayagapuram Branch, Chennai – 600 099 ) given by you for Rs.16,00,000/- on
30.11.2022. To the at-most shock and surprise to our client, the cheque was
dishonored for the reasons: “DRAWER SIGNATURE DIFFERS “, intimated to our
client by return memo from our clients bank on 30.11.2022 and same has been
informed to you on the date itself.
Our Client further instructed us to state that Even our client is unaware of the
reasons for the non-payment of the Cheques given by you but my client immediately
approached you and informed the return of Cheque for the said reason, but you
have evasively replied, without giving any proper reason. This act of you is nothing
but act of cheating intentionally and Negligence to honour the cheques given and
thereby, you have committed an offence under the provisions of Sec.138 of
Negotiable Instruments Act and also Sec.420 of I.P.C.
.
In the above said facts and circumstances, we hereby call upon you, on
behalf of our client to pay a sum of Rs.16,00,000/- to our client within 15 days from
the date of receipt of this legal notice, failing which our client will take appropriate
legal action against you, particularly under Sec.138 of N.I. Act and Sec.420 of I.P.C.
and in that event, both are held liable for all the costs and consequences arising
thereof.
Also, pay a sum of Rs.5,000/- towards cost of this legal notice.
 Yours,

                       (R. THANJAN , R. SENTHIL KUMAR & G. JAI SINGH)

Mobile: 93831 23422

98419 96530

R. THANJAN, B.A., LL.B.,

D. GOKULAKRISHNAN, M.A., B.L.,
ADVOCATES, HIGH COURT
Chamber: No.264, New Addl. Chamber, High Court Campus, Chennai –600 104.
BY RPAD Date:
24.03.2021

NOTICE UNDER SEC.138 OF N.I., ACT.

To:
Mr. N. Venkatesan
No.10 (Old No.1333) Flat No.2A,
7th Cross Street, Poombugar Nagar,
Kolathur, Chennai – 600 099.

Sir,
 Under instructions from my client Mrs. R. Sumathi, wife of Rajalingam, residing at
No.21, Alapakkam Main Road (2 nd Floor), Srinivasa Nagar, Maduravoyal, Chennai-600 095, I
am issuing the following notice to you:
My client instructed me to state that you have approached my client for financial
assistance to meet out your Real Estate business and meet out your family commitments
and accordingly, my client has also came forward to assist by way of financing to tune of
Rs.5,00,000/- on various dates, particularly from 05.07.2020 to by way of cash and you
have also promised to my to repay the same within 6 months.
My client further instructed me to state that after expiry six months, my client
demanded the aforesaid amount to repay the same, together with interest as promised by
you, but somehow or other, you have evaded my client’s request and demand and the
reason is best known to you alone. However, you have prolonged to repay the said
borrowal amount to my client and thereby you have failed and neglected to pay the same.
In the mean time, a compromise was made between you and my client and as per the said
compromise, repay the entire dues, due to my client and you have also issued following
cheques to discharge the same:
a) Cheque No. 000116 dated on 21-01-2021 for a sum of Rs.1,00,000/-
b) Cheque No.000114 dated on 21-01-2021 for a sum of Rs. 2,00,000/-
c) Cheque No.000115 dated on 21-01-2021 for a sum of Rs. 2,00,000/-
All cheques drawn on HDFC Bank Ltd, Anna Nagar Branch as full and final settlement, for
the aforesaid total sum of Rs.5,00,000/-
My client further instructed state that on the basis of your promise and assurances
for honouring the aforesaid cheques finally, my client has also deposited the aforesaid
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cheques on 11.03.2021, but to my client’s shock and surprise that the said cheques
were returned on the reason of ‘Other Reasons’ on 12.03.2021, which was intimated
to my client on 13.03.2021.
My client instructed me to state that once the you borrowed the said amount
of Rs.5,00,000/- on various date from 05.07.2020 by way of cash and you arrived a
settlement by discharging the loan amount, to the tune of Rs.5,00,000/- and
supposed to pay the same to my client legally, but you have failed and neglected to
honour the same and thereby, you have committed an offence under the provisions
of Sec.138 of Negotiable Instruments Act and also Sec.420 of I.P.C. Even after
returning of the afore said cheques, my client has also contacted you, but you have
replied evasively without any proper response.
 In the above said facts and circumstances, I hereby call upon you, on behalf
of my client to pay a sum of Rs.5,00,000/- to my client WITHIN 15 DAYS from the
date of receipt of this legal notice, failing which my client will take appropriate legal
action against you, particularly under Sec.138 of N.I. Act and Sec.420 of I.P.C., by
holding you liable for all the costs and consequences arising thereof. Also, please
pay a sum of Rs.10,000/- towards cost of this legal notice.
Yours faithfully,
  
                    (R.THANJAN/D.GOKULAKRISHNAN)

Mobile: 93831 23422

93811 23422

R. THANJAN, B.A., LL.B.,

ADVOCATE, HIGH COURT
Chamber: No.264, New Addl. Chamber, High Court Campus, Chennai –600 104.
BY RPAD Date:
01.02.2021

NOTICE UNDER SEC.138 OF N.I., ACT.

To:
Mrs. Radha Yadav Esackkiappan
D/o Esackkiappan,
No.102/04, Patel Road, 1st Street,
Tondiarpet, Chennai – 600 081.

Madam,
Under instructions from my client Mr. D. Gokulakrishnan, son of late K. Doss,
residing at 6/41 South Kasar Garden Aminjikarai, Chennai-600 029, I am issuing the
following notice to you:
 My client instructed me to state that you have approached my client for financial
assistance to meet out your business commitments, particularly Catering business, my client
has also came forward to assist by way of financing to tune of Rs.9,45,000/- on Various
dates by way of cash for a sum of Rs.3,50,000/- and the balance amount for a sum of
Rs.5,95,000/- by way of transferring through RTGS on Various dates through your
Husband’s Current account as per instruction of you and you have also promised to my to
repay the same within 3 months.
My client further instructed me to state that after expiry three months, my client
demanded the aforesaid amount to repay the same, together with interest as promised by
you, but somehow or other, you have evaded my client’s request and demand and the
reason is best known to you alone. However, you have prolonged to repay the said
borrowal amount to my client, but you have failed and neglected to pay the same. In the
mean time, a compromise was made between you and my client and as per the said
compromise, you have issued a cheque for a sum of Rs.7,00,000/- bearing cheque
No.443996 dated 30.12.2020, drawn on State Bank of India, Medavakkam Main Road
Branch as full and final settlement, since you have paid a sum of Rs.2,95,000/- on various
dates, out total payable amount, i.e. principal amount of Rupees plus interest Rs.50,000/- as
per compromise.
My client further instructed state that on the basis of your promise and assurances
for honouring the aforesaid cheque finally, my client has also deposited the same on
20.01.2021, but to my client’s shock and surprise that the said cheque was returned
on the reason of ‘Payment stopped by drawer’ on 21.01.2021, which was intimated
to my client on 22.01.2021.
My client instructed me to state that once the you borrowed the said amount
of said Rs.9,45,000/- on Various dates by way of cash for a sum of Rs.3,50,000/- and the
balance amount for a sum of Rs.5,95,000/- by way of transferring through RTGS on Various
dates in your Husband’s account and you arrived a settlement by discharging the loan
amount, together with agreed interest to the tune of Rs.7,00,000/- after deducting
paid amount of Rs.2,95,000/- and supposed to pay the same to my client legally, but
you have failed and neglected to honour the same and thereby, you have
committed an
-2-
offence under the provisions of Sec.138 of Negotiable Instruments Act and also
Sec.420 of I.P.C. Even after returning of the aforesaid cheque, my client has also
contacted you, but you have replied evasively without any proper response.
 In the above said facts and circumstances, I hereby call upon you, on behalf
of my client to pay a sum of Rs.7,00,000/- to my client WITHIN 15 DAYS from the
date of receipt of this legal notice, failing which my client will take appropriate legal
action against you, particularly under Sec.138 of N.I. Act and Sec.420 of I.P.C., by
holding you liable for all the costs and consequences arising thereof. Also, please
pay a sum of Rs.10,000/- towards cost of this legal notice.
Yours faithfully,
  
                                                                         (R. THANJAN)

Mobile: 93831 23422

93811 23422

R. THANJAN, B.A., LL.B.,

ADVOCATE, HIGH COURT
Chamber: No.264, New Addl. Chamber, High Court Campus, Chennai –600 104.
BY RPAD Date:
24.03.2021

To:
R. Shanmugasundaram,
Advocate
No.110/890, 1st Floor,
G.S.T. Road, Tambaram Sanatorium,
Chennai - 600 047.

Sir,
Your reply notice dated 26-02-2021 sent on behalf on your client Mr. Karthik
paramasivam to my clients legal notice dated 23.02.2021 sent on behalf of Mr. D.
Gokulakrishnan, who has been handed over in my hands with instructions to give the
following rejoinder to your client through you:
 My Client denies all the averments contained to your reply notice, except those that
are specifically admitted herein and puts your client to strict proof of the same.
At the first instance, your client blind denial in respect of borrowal is itself false, since
your client borrowed, but your client and your client’s wife, both are playing a bowl game to
escape from the liability and however, borrowed to discharge of some of the commitments
of your client’s business on various dates, for which your client issued the subject cheque,
that too after compromise between my client and with your client and such facts have not
been disclosed the issuing the reply notice. However, your client has surpressed the entire
material facts with view to escape from the liability. Moreover, no one issue cheque with out
any reason or commitments and there is no chance to have your client’s cheque with my
client. It is obvious that your client contacted for borrowal of the loan amount from my
client and to discharge the said loan alone, the subject cheque was issued to my client. my
client has alleged by your client and accordingly, my client stoutly denied for which your
client alone has to proved for such false statement.
In the second instance, your client has replied falsely with view to escape to the
liabilities and nothing more, however, my client will proceed strictly under the provisions of
N.I. Act, for which your client answerable to my client before the court of law for such
dishonor of cheque.

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In the above said facts and circumstances, I hereby call upon your client,
through you on behalf of my client to advice your client accordingly and also advised
to comply my client’s legal notice dated on 23.02.2021 within the stipulated time or
otherwise, your client has no other go, except the consequences the court of law for
the offences committed by your client, which please note and even after receipt of
rejoinder, your client is doing his own risk and consequences arising thereof.
Yours faithfully,
  
                                                                        (R. THANJAN)