RAGHAV KAPOOR & ASSOCIATES

ATTORNEY

SUPREME COURT OF INDIA

OFFICE:
106, 116-17, UNITY GROUP
AGGARWAL PLAZA, S.F.S
POCKET, MUKHERJEE NAGAR
DELHI-110009
kapoor.raghav8@gmail.com

REGD. A.D & SPEED POST

Ref. No. M. V XXIX/VI DATED

REGD. AD/U.P.C/SPEED POST

TO,

1. MAHINDRA HOLIDAYS & RESORTS INDIA LTD

2. SH. MANOJ BHAT
Managing Director & CEO
(Mahindra Holidays & Resort India Lmt)
3. Mrs. Preeti Chaudhary (Club Mahindra Employee) (Admin team) Jasola.
4. Mr. Vikram kocher (Club Mahindra Employee) (Admin team) Jasola.
5. Sh.Prashant Joshi (Club Mahindra Employee) (Sales Team).
6. Sh. Govind Verma (Club Mahindra Employee) (Sales Team).
7. Sh. Sumit Dixit (Club Mahindra Employee) (Sales Team).
OFFICE:
i. Mahindra Towers, 1st Floor, “A” Wing, Dr. G.M
Bhosle Marg, P.K Kurne Chowk, Worli Mumbai-400-018.
ii. Mahindra Towers, 2nd Floor, 17/18, Patullos Road,
Mount Road, Chennai, Tamil nadu, India-600-002.
 iii. P-2, Unit No. 215-217, 2nd Floor, Best Business Park
Netaji Subhash Place, Pitampura, New Delhi-110034

iv. Salcon Aurum, 2nd Floor Jasola Vihar Delhi-110025

LEGAL NOTICE

Under the instruction from and on behalf of “MY CLIENT” Sh. Raghav Kapoor, S/o

Sh. R. Kapoor, R/o H.No.1102, Mukhrjee Nagar Delhi-110009 (herein referred to as

“MY CLIENT”) has instructed me to serve upon “YOU NOTICEE’S” the present

Legal Notice / Demand notice for carrying out unethical, unfair and illegal trade

practice, carried out by “YOU NOTICEE’S” by way of committing fraud and also

carrying out cyber crime and other malicious trade practice which has caused “MY

CLIENT” to face extreme hardship, mental agony, physical harassment, psychological

trauma and by your malicious act and conduct “YOU NOTICEE’S” have also caused

a loss of the hard earned money of “MY CLIENT” which has led “MY CLIENT” to

direct me on his behalf to serve upon “YOU NOTICEE’S” present LEGAL /

DEMAND NOTICE for the said reasons.

1) That on Dt 25/04/2024 on the invite of Ms. Neha Gupta Employee ID 20850

“MY CLIENT” was asked to attend a seminar of 45 min which was organized

by “YOU NOTICEE’S” at “BARBEQUE NATION” Model Town-III, Delhi

along with his family.

2) That as per the invite “MY CLIENT” visited the abovesaid place with his

family and where “MY CLIENT” was attended by Mr. Sumit Dixit Employee

ID 40169 and one Mr. Govind Verma employee ID 27628 who collectively

explained the holiday package by the name of “Go Zest” having a validity of

three years and other benefits including (no annual membership Fee, carry

forwards amount of the package after three year in case of an upgrade, Free
 Kalyan Jewellery voucher worth ten thousand and Free extra holiday vouchers,

etc).

3) That after explaining the legacy of Club Mahindra and its resorts located all over

India and abroad and also explaining about the “GO ZEST” three years Holiday

Package”, “MY CLIENT” was thereafter introduced to one Mr. Prashant Joshi

who introduced himself as the senior of Mr. Sumit Dixit & Mr. Govind Verma

who stated that the holiday package namely “GO ZEST” which has a validity of

three years vide which “MY CLIENT” will get an access to stay with his family

in any of the resort of “YOU NOTICEE’S” for a total 7 nights in one year each,

making it 7 nights for every year till the holiday packages “GO ZEST” expires.

4) That Mr. Prashant Joshi also explained to “MY CLIENT” that the said holiday

package i.e “GO ZEST” having a validity for three year is for an amount of Rs

1,58,872/- but under special offer the same was being sold for Rs 1,24,898/- and

the said offer was only for today i.e Dt. 25/04/2024 and further Mr. Prashant

Joshi also explained to “MY CLIENT” that they also accept part payments and

the remaining balance amount can be cleared off by “MY CLIENT” with the

facility of interest free Equated Monthly Installment.

5) That the deal was finalized by Mr. Prashant Joshi and the said holiday package

was sold for Rs 1,24,898/- on Dated 25/04/2024 to “MY CLIENT” and further

“MY CLIENT” was asked to make an upfront payment of Rs 77,414/- out of a

total sum of Rs 1,24,898/- and the balance remaining amount of Rs 47,484/- was

bifurcated into interest free 6 E.M.I starting from December 2024 each

amounting to Rs 7,914/-.

6) That the “YOU NOTICEE’S” in lieu towards selling of the said HOLIDAY

PACAKGE asked “MY CLIENT” to make a down payment of Rs 77,414/- Dt.

 25/04/2024 towards the Holiday package which was sold for a sum of Rs

1,24,898/- where to the remaining amount of Rs 47,484/- was to be paid back in

interest free 6 monthly installments each amounting to Rs 7,914/-.

7) That after the holiday package was sold off to “MY CLIENT”, Mr. Sumit Dixit

“YOU NOTICEE’S ” assured “MY CLIENT” that he will take care of all the

concerns and membership related issues of “MY CLIENT” and for that on Dt.

27th of April 2024 “YOU NOTICEE’S” asked “MY CLIENT” to provide the

photo of aadhar card details and also asked for “MY CLIENT” account details

for the reason that the same need to be fed into the system as it will be only

thereafter that “MY CLIENT” will be able to avail his membership benefits.

8) That on Dt. 28/04/2024 “YOU NOTICEE’S” further asked “MY CLIENT” to

send the photo of the addhar card on the mobile number of “YOU NOTICEE’S”

as the same was not getting uploaded on to your system and simultaneously

“YOU NOTICEE’S” also asked for an OTP number which was sent on the

whatass app of “MY CLIENT” and upon enquiring the same “YOU

NOTICEE’S” told “MY CLIENT” that it is for the system update and client

verification, where after the same was told by “MY CLIENT” to “YOU

NOTICEE’S” over the phone.

9) That it is worthy to mention that “MY CLIENT” with the assistance and

management of “YOU NOTICEE’S (Mr. Sumit Dixit) availed the assured “7

nights 8 days holiday” granted per year till the completion of three years in the

said holiday package in the said membership bearing No. 3045192 sold to “MY

CLIENT” for Rs 1,24,898/- in the month of June 2024.

10) That till September 2024 “MY CLIENT” availed the services of the

membership bearing No. 3045192 where after in the month of October 2024
 “MY CLIENT” received a call from one Ms. TanuPriya Singh ( M.No.

9910046422) who stated that there is an outstanding balance issue on the

membership account to which “MY CLIENT” stated that the same is not

possible as the money has been paid upfront by “MY CLIENT” and the balance

amount of Rs 47,848/- is to be paid back in interest free 6 monthly installments

which are to be initiated in the month of December 2024 to which Ms. Tanu

Priya Singh assured “MY CLIENT” that she will get back to “MY CLIENT”

on the same and thereafter through out the whole month of October and

November 2024 “MY CLIENT” did not receive any call from Ms. Tanu Priya

Singh.

11) That “YOU NOTICEE’S” (Mrs. Preeti Chaudhary) gave a call on Dt. 15th

November 2024 to “MY CLIENT” who introduced herself as the senior of Ms.

Tanupriya Singh and said that the membership account of “MY CLIENT” is

being taken care off by her “YOU NOTICEE’S” and further told “MY

CLIENT” that the amount for the month October 2024 stands unpaid, upon

which “MY CLIENT” explained his grievance to “YOU NOTICEE’S”, but

“YOU NOTICEE’S” ( Mrs. Preeti Chaudhary) did not provide any satisfactory

answer to “MY CLIENT” and rather kept on pressing “MY CLIENT” to pay

off the outstanding amount for the month of October 2024.

12) That “MY CLIENT” came to know that in the month of November 2024 that an

E.M.I of Rs 9,983/- was deducted from his account towards the holiday package

membership bearing No. 3045192, against the written acknowledgment given by

“YOU NOTICEE’S” for the same to be an interest Free E.M.I amounting to Rs

7,914/- for the next 6 months. This fraud and cheating in the form of cyber crime

was objected “MY CLIENT” by way of informing the same to “YOU

NOTICEE’S” (Mrs. Preeti Chaudhary) who also acknowledged that the said
 E.M.I amount to Rs 9,983/- has been deducted from their end and after raising a

serious concern upon the same, “YOU NOTICEE’S” (Mrs. Preeti Chaudhary)

gave a fake assurance that she will look into the grievance of “MY CLIENT”

and will revert back to “MY CLIENT” with a affirmed solution on the same.

13) That being assured by the fake assurance given by “YOU NOTICEE’S” that the

grievance of “MY CLIENT” shall be looked into by “YOU NOTICEE’S”

(Mrs. Preeti Chaudhary) , “MY CLIENT” got relaxed towards the same, but

rather “YOU NOTICEE’S” were only fooling “MY CLIENT” and just merely

sitting over the grievance of “MY CLIENT” doing nothing about the same and

because of which again in the month of December 2024 another E.M.I of Rs

9,983/- was again deducted from the account of “MY CLIENT” towards which

“MY CLIENT” again approached “YOU NOTICEE’S” ( Mrs. Preeti

Chaudhary) who miserably failed to provide any favorable help, but however

“YOU NOTICEE’S” ( Mrs. Preeti Chaudhary) rather told “MY CLIENT” that

she could only help out on the condition that if “MY CLIENT” will make an

upfront payment of Rs 5,000/- which is an outstanding amount for the month of

October 2024 and further also threatened “MY CLIENT” that if the payment of

Rs 5,000/- is not cleared by “MY CLIENT” then she will get “MY CLIENT”

membership cancelled towards which “MY CLIENT” had already given an

amount of Rs 97,380/- till December 2024 from his hard earned money.

14) That again on Dt. 31st of December 2024 “YOU NOTICEE’S (Mrs. Preeti

Chaudhary) contacted “MY CLIENT” and pressed upon the demands towards

clearing off the outstanding amount of Rs 5,000/- for the month of October 2024

and without the consent of “MY CLIENT” it is “YOU NOTICEE’S (Mrs.

Preeti Chaudhary) who shared the QR code on “MY CLIENT” mobile number

i.e 9891288529 and further threatened “MY CLIENT” that if the out standing
 amount of Rs 5,000/- is not paid by “MY CLIENT” then “MY CLIENT”

membership will be revoked and “YOU NOTICEE’S” ( Mrs. Preeti

Chaudhary) further informed “MY CLIENT” that in their system the total

amount of holiday package which was sold to “MY CLIENT” is reflecting a

total sum of Rs 1,58,872/- and there is no special offer which is being reflected

in the system on which the deal was finalized and been given to “MY CLIENT”

as promised by “YOU NOTICEE’S” at the time of selling the holiday

membership package on dated 25/04/2024 for an amount of Rs 1,24,898/-

whereby which “YOU NOTICEE’S” have committing a grave fraud and

cheated “MY CLIENT” and had intentionally and deliberately siphoned and

duped his hard earned money.

15) That being aghast and shocked by the malicious conduct of “YOU

NOTICEE’S” whereby which “YOU NOTICEE’S” have cheated “MY

CLIENT” and committed a penal offence in the manner of cheating and

committed cyber crime by deducting an amount of Rs 9,983/- against Rs 7,914/-

and denying the promised special offer of Rs 1,24,898/- at the time of selling the

holiday package as committed by “YOU NOTICEE’S” in written at the time of

selling the holiday package on Dated 25/04/2024, to which “MY CLIENT”

raised his concern by sending a grievance Mail on the official E-mail address i.e

memberexperience@mahindraholidays.com on dated 17th Feb 2025, after which “YOU

NOTICEE’S” realizing the mistake which “YOU NOTICEE’S” have

committed by way of fraud , cheating and duping the hard earned money of

“MY CLIENT” started sending lucrative offer with the modus operandi to

somehow collect the outstanding amount of Rs 5,000/- from “MY CLIENT”

which “YOU NOTICEE’S” successfully managed to collect the same from “MY

CLIENT” on Dated 20th of February 2025 and to further fool around with “MY
 CLIENT” it is“YOU NOTICEE’S” who called “MY CLIENT” to your office

situated at SALCON AURUM, 2ND FLOOR JASOLA VIHAR DELHI-

110025 on the false pretext that “YOU NOTICEE’S”, will resolve the ongoing

membership dispute of “MY CLIENT”.

16) That on Dated 26th Feb 2025 “MY CLIENT” after spending more than three

hours in traffic came all the way to your office at the cost of his work at your

office situated at “Salcon Aurum, 2nd Floor Jasola Vihar Delhi-110025” to

meet “YOU NOTICEE’S” with a hope that the ongoing membership dispute

pertaining to the sum total of the costing of the holiday package membership and

increased E.M.I will be resolved to the same price which was promised to “MY

CLIENT” by “YOU NOTICEE’S” in writing at the time of selling the said

membership holiday package Dt. 25/04/2024 i.e promised amount of Rs

1,24,898/- against special offer and Rs 7194/- in interest free 6 equated monthly

installment which were to be initiated from December 2024.

17) That thereafter in the meeting held in your office on Dated 26th Feb 2025 “MY

CLIENT” was further introduced to one Sh. Vikram Kochher (YOU

NOTICEE’S) who was accompanied by Mrs. Preeti Chaudhary (YOU

NOTICEE’S) who after hearing the grievance of committing of cyber crime and

cheating by “YOU NOTICEE’S” with “ MY CLIENT” for more than an hour,

asked “MY CLIENT” to grant them some more time i.e maximum by 1st of

March 2025, so that they can work upon and find some solution which will be

beneficial for “MY CLIENT” and both for “YOU NOTICEE’S” and also

asked “MY CLIENT” to share all the screen shot and recorded telephonic

conversation happened between “MY CLIENT” and Mr. Sumit Dixit (YOU

NOTICEE’S) which was duly complied by “MY CLIENT” as the same was

shared by “MY CLIENT” with Mrs. Preeti Chaudhary (YOU NOTICEE’S) on

 her E-mail and also on her whatsapp and with this fake assurance given by both

“YOU NOTICEE’S”, “MY CLIENT” was asked to leave with an assurance

the both you noticee’s will revert back to “MY CLIENT” towards the grievance

maximum by 1st of March 2025.

18) That observing the unprofessional behavior and pathetic attitude towards “MY

CLIENT” by way of sitting over “MY CLIENT” grievance and not providing

any favorable response or input by “YOU NOITCEE’S” as promised in the

meeting held on Dt. 26th Feb 2025 at your office led “MY CLIENT” to send a

reminder mail towards non-intimation of any solution which was to be given by

“YOU NOTICEE’S” till 1st of March 2025 on Dt. 3rd of Feb 2025, but as

expected “YOU NOTICEE’S” did not revert to the same.

19) That the irony of “MY CLIENT” is that “YOU NOTICEE’S” failed to fulfill

your promise by not giving any reply / solution as promised by maximum by 1st

of March 2025 as stated by “YOU NOTICEE’S” as decided in the physical

meeting held at your office on Dt. 26th Feb 2025 which “YOU NOITCEE’S”

miserably failed in doing so and rather “YOU NOTICEE’S” preferred to sit

over the grievance of “MY CLIENT” and doing nothing over the same because

of which “MY CLIENT” waited for the response of Mr. Vikram Kochher

(YOU NOTICEE’S) and it was on Dt. 4th of March 2025 that “MY CLIENT”

finally called up “YOU NOTICEE’S”(Mr. Vikram kochher) to inquire about

the progress or the solution which was to be given by Mr. Vikram kochher

(YOU NOTICEE’S) as promised by him till 1st of March 2025, upon which Mr.

Kochher ( You Noitcee’s) started giving one excuse or the other and did not

provide any favorable response / solution towards the ongoing membership

dispute.
20) That “MY CLIENT” also tried approaching “YOU NOTICEE’S” ( Mr.

Vikram kochher) by way of sending text msg on his whatsapp, but YOU

NOTICEE’S( Mr. Vikram Kochher) despite reading the same intentionally and

deliberately did not provide any response to the same, hence making his

intention loud and clear that YOU NOTICEE’S all collectively have played a

fraud and have committed cheating with “MY CLIENT” by opting all

malicious act and conduct inclusive of cyber crime by which YOU

NOTICEE’S have deliberately deducted an increased wrong E.M.I without the

knowledge and consent of “MY CLIENT” and further has also cheated “MY

CLIENT” by selling the holiday package at a price of Rs 1,24,898 on the

promised date of sale of the holiday package i.e 25/04/2024 and thereafter

converting it into Rs 1,58,872/-.

I, therefore, on behalf of “MY CLIENT” namely “Sh. Raghav Kapoor” hereby

call upon “YOU NOTICEE’S” through this present LEGAL NOTICE to

compensate “MY CLIENT” on the pretext of damages caused by “YOU

NOTICEE’S” toward causing mental agony, physical and mental torture,

physical harassment and also for duping siphoning “MY CLIENT” hard earned

money to the tune of compensatory amount amounting to Rs 5,00,000/-

alongwith interest @ 10 % from Dated 25/04/2024 i.e (the date when the holiday

package “GO ZEST” Membership No. 3045192 was sold to “MY CLIENT” for

a promised amount given in writing to Rs 1,24,898/-) and further “YOU

NOTICEE’S” are also directed to pay Rs 50,000/- apart from the

abovementioned claimed amount towards the present Legal Notice within in 15

days from the date of receiving of the present LEGAL / DEMAND NOTICE

failing which “MY CLIENT”, shall be constrained to initiate legal course of

action against “YOU NOTICEE’S”, before the appropriate forum of Law by

taking a recourse of civil or criminal proceeding against “YOU NOTICEE’S”

under the relevant provision of laws and to make sure that a strict legal / penal

action against “YOU NOTICEE’S” be taken, for which I have already been

instructed and the same shall be proceeded at your own risk, costs and

consequences and which “YOU NOTICEE’S” deem liable to pay to “MY

CLIENT”.

Copy kept for further reference.

MY CLIENT
(SH. RAGHAV KAPOOR)