To,                                                                           Dt.: ______

__________________________

ADD:____________________

Email: ______________

Sub:  Rejoinder to your Reply dated __________ to the Legal Notice dated ___________ sent on behalf of My Client __________.

Dear Sir/Madam,

This Rejoinder on behalf of my client ____________, to your reply dated _____________ to the Legal Notice dated __________ sent on behalf of My Client. My client asserts her status as a legal heir and her entitlement to rental income from property No. _______________, New Delhi-110016. My client seeks clarification of her lawful rights concerning the rent generated by your tenancy on the tenanted premises.

Under the Hindu Succession Act, 1956, my client is entitled to a rightful share of the estate of her late father _______, including the rental income from the said tenanted premises. Following the death of the original owner, ____ ______, the said property devolved to all legal heirs, including My Client Mrs. _________, making her one of the joint owners.

My client Mrs. _______ as a co-owner, has an undisputed right to her share of rent directly from you the addressee, regardless of any arrangement the Lab might have with another heir. The tenancy under the laws do not permit the selective payment of rent to one legal heir at the exclusion of others entitled to the said premises, making it legally imperative for you the addressee to fulfill her legitimate demand of rent.

My client Mrs. ___________ acknowledges the previous existence of a Power of Attorney (POA) executed in favor of Ms___________, dated __________. However, it is critical to clarify that this POA was publicly revoked by my client prior to the issuance of the Legal Notice dated ____________ to you the addressee.

The said revocation of PoA has been widely circulated through a public notice in newspapers i.e. The Indian Express and Jansatha on ________, making it legally binding. Consequently, any right previously vested in favour of ____________ concerning rent collection on behalf of My Client is nullified. This revocation reinstates my client’s direct authority over her share of the said property and, by extension, her entitlement to her share in rental income from you the addressee.

While you the addressee stated that a lease deed was executed solely with __________, it is legally untenable to ignore the rights of other legal heirs in ancestral property. The privity of contract doctrine does not apply in this scenario to deny co-owners their legal rights in the said property.

__________ is one of the Legal Heirs of Late ___________, but you ignoring the facts that __________ is no more Attorney Holder of my client _________, and intentionally not distributed the rent equally among all co-owners / LRs, deliberately ignoring the rights of my client constitutes a breach of equitable principles governing tenancies in jointly held properties.

You the addressee is required to regularize its tenancy by securing explicit consent from my client, a legal co-owner. Without her consent, any further occupation of the premises by you the addressee constitutes unauthorized occupation.

Furthermore, the demands of my client for rent payments to be proportionately distributed among all legal heirs is valid and lawful. This regularization should include acknowledgment the share of my client and her consent as a necessary part of the tenancy.

My client demands an immediate acknowledgment of her rights in the said property and the arrangement for direct payment of her rightful share of rent. Failure to comply will leave her no option but to initiate legal proceedings, including eviction and recovery of unpaid dues, as well as any additional claims arising from non-compliance.

Additionally, you the addressee may be held accountable for unauthorized occupation under the Transfer of Property Act, 1882, if prompt corrective action is not taken.

This rejoinder to your reply is issued without prejudice to all other legal rights and remedies available to my client under laws. If you the addressee fail to comply the same, my client reserves the right to pursue further actions, including claims for damages and any other relief deemed necessary under the law.

As such the ground / contents raised in your reply is false, unknown, shocking and frivolous. That the contents of your reply under reply is wrong and denied as stated.

You the addressee emphasizes its reputation and the service tenure it has provided. This fact, while noted, is irrelevant to the issue of the rental dispute and does not alter the legal entitlements of my client as a co-owner of the property. The lease deed dated ___________ executed between you the addressee and ____________, as cited, cannot override the rights of other legal heirs to the said tenanted premises. My client __________ is not disputing the lease deed itself but is asserting her right to receive her share of rent as one of the lawful heirs of Late ______.

You the addressee stated that demand of my client for rent as an "arm-twisting tactic." This assertion is without foundation. My client’s claim is legitimate and arises from her lawful rights as a co-owner, and any suggestion of malicious intent is irrelevant and unfounded. That you the addressee further states that the notice dated _____________ contains “conjectures” and “surmises.”. My client’s claim is based on her rights under succession law, and her entitlement to rent has been outlined clearly and backed by her lawful standing as a co-owner.

The allegations regarding malafide intentions and ulterior motives are unsubstantiated. The demand of my client is based on her legal right to the rental income from said property she co-owns. The demand for rent is in accordance with the law, and any attempt to attribute malice to my client is baseless. The lack of detail you the addressee mentions does not negate my client legal right to rent. My client has clearly communicated her rights as a co-owner, and this demand is based on lawful entitlement.

The reference to the POA does not affect my client’s entitlement, as it was revoked prior to her legal notice, as submitted above in detail. The revocation was made publicly, which you the addressee was made aware of, voiding any authority that ________________ may have previously had to exclusively receive rent on behalf of my client. That you the addressee stated that my client is bound by the terms of the POA. However, since the POA was revoked, this fact is no longer valid. My client retains her legal rights as a co-owner of the property, independent of any POA arrangements that no longer hold legal validity.

You the addressee invokes privity of contract, stating that my client is not party to the lease deed. Nonetheless, as a co-owner, legal rights of my client entitle her to claim her share of rental income. The doctrine of privity does not allow the tenant to sidestep obligations to all co-owners in interstate held properties, especially in cases where a POA has been revoked.

In view of above, my client expects immediate acknowledgment of her share in the rental income and a swift arrangement for direct payments. Any further disregard of her rights may compel her to initiate legal proceedings to uphold her lawful entitlements.

I trust, however by timely action, you will obviate the necessity of any unpleasant steps having been taken against you the addressee. It will be in your interest to withdraw the reply / notice and made direct payment of her share of the rent to the account of the my client, any delay or failure in paying her share of rent will be treated as a breach of law and non-compliance of the same, my client shall be left with no other option but to pursue legal remedies, including but not limited to eviction proceedings and recovery of arrears under the relevant provisions of the law.

In the event of such proceedings will be initiated against you the addressee at your risk, cost, and consequences, any costs, expenses, or other liabilities shall be borne by you, the addressee.

A copy of this rejoinder has been kept in my office for further reference and action.

____________

Advocate