REGD. POST./EMAIL

To,                                                           Dt.XXXXXX

XXXXXXXXXXXX

Advocate

M/s. XXXXXXXXXXXX & Co.

Chamber NoXX Civil Wing,

XXXXX,

XXXXXX.

EmailXXXXXXXXXXXXXXXXX

Ref:  Reply to your legal notice dated 09.06.2023 issued on behalf of your client Mr. XXXXXXXXXX to my client.

Dear Sir,

In reference to your legal notice dated 09.06.2023 addressed to my client MsXXXXXXXX W/o ShXXXXXXXXX, (hereinafter referred as my client), I have been instructed to give reply to the same as under:-

At the very out-set, I would like to inform you that your notice as based on wrong, false and incorrect information and it seems that your client has not supplied you the true and complete information and as such the contents of your notice are false, frivolous and baseless except wherever the same are specifically admitted by my aforesaid client. Had you known the ground situation prevailing you would yourself had understood the whole scenario and you must have thereon tried to persuade your client so that good sense could prevail upon your client, anyways I wish to clarify and reply your legal notice in the following paragraphs.

The notice under reply is based on false and frivolous facts and as such the same is liable to be withdrawn by your client out-rightly.

That my client received the aforesaid legal notice on 11.06.2023 and the contents of your notice are not admitted and same are denied except to the contents which are admitted in the following paragraphs.

That my client a tenant of subject premises on the strength of duly executed rent agreement dated ……… for a period of (3) three years for the agreed monthly rent of Rs……../- and the rent deed was signed by your client and the rate of the rent was to be enhanced as per the provisions of DRC Act.

Since then my client paying the rent through cheque / cash in the name of your client without any default and if the calculation are properly made it would make clear that the amount deposited with your client was more than the arrears.

In entire notice your client didn’t explain any bonafide reason for termination of the tenancy of my client, hence, the termination is illegal and unreasonable and my client is not in position to vacate the subject premises with immediate effect, my client using the same for commercial purpose and lot of goods were lying in the subject premises for advance period of work. Hence, the termination of tenancy at this stage is illegal and unreasonable, due to this my client will suffer with huge loss of money and reputation which cannot compensate in terms of money and this illegal termination is not tenable and acceptable in any manner, which shows that the malafide intention of your client to defaming the goodwill and reputation of my client. This has caused significant harassment to my client, and which is not tolerable such behavior in any manner. Hence, your client sent the notice under reply based on false and frivolous information.

That my client always paid rent on time which can be seen from bank statement of my client and my client are surprised to see such a vague notice and fabricated liability which is shown by your client, therefore all these activities of your client show malafide intention and sole intent to harass my client, which is very much evident from the fabricated contents of the notice. 

Therefore, by all these activities of your client it is very much clear evident that your client is giving false and unreliable information to you which don’t have any ground reality. Therefore, my client will definitely take some strict action towards your client for such a malafide conduct, therefore without any doubt your client is liable for the same.       

As such my client are in shock and surprise that from where your client has cooked up this fake/false stories which don’t even have any ground reality. Therefore, my client has instructed me to take a strict legal action against your client, if your client doesn’t withdraw this notice and my client is not liable to pay any damages.

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

In light of the above, my client requests you to withdraw your notice for a refund immediately. If you do not withdraw your notice, my client will have no choice but to take legal action to protect his right / interests. Please note that our client is also entitled to claim compensation for any losses they may have suffered as a result of false and frivolous claim of your client.

Please note that in case, your client shall take any legal proceedings against my client, in that event, your client shall be doing so at its costs, risks and consequences thereof. Any threatened action if your client chooses to take; your client shall be doing so at its costs, risks and consequences therefore.

I trust, however by timely action, you will obviate the necessity of any unpleasant steps having been taken against you client. It will be in your’s client own interest to withdraw the notice, otherwise my clients will initiate appropriate proceedings against you.

This notice has not legal force and still your client proposes to take any legal action against my client, in that event, your client shall be doing so at its own costs, risks and consequences thereof which you may please advise your client.

Copy kept.

(XXXXXXXX)

                                                Advocate