ADVOCATE TARUN
PANT“TUSHAR”
Office : 25, Bajrang Vihar, Kursi Road Lucknow (Near L.B.S Girls College)-U.P
Pin : 226026
E-mail :tarunpant.adv@gmail.com, info.atozlegalsolutions@gmail.com
Website : www.atozlegalsolutions.in
Mobile No’s : +91-8299635251
Ref-TAR/LN/0197 Date: 06-09-2020
REG A.D/U.P.C
DEMAND NOTICE/ LEGAL NOTICE
From,
Samarjeet Singh
S/O Shiv Kumar Singh
R/O SS4/360, Vibhav Khand, GomtiNagar
Lucknow-226010
TO,
Indra C.J Barua ( Indra C.J)
W/O Ganga Ram Barua
R/O- House No 4/132A-1
Vishal Khand-4, GomtiNagar
Lucknow-Pin 226010
Sir,
UNDER INSTRUCTIONS FROM AND ON BEHALF OF MY CLIENT, MR. SAMARJEET SINGH,
AGED ABOUT 32 YEARS, R/O- CARE OF SHIV KUMAR SINGH, SS4/360, VIBHAV
KHAND,NEAR MANTRI AAWAS, GOMTINAGAR, LUCKNOW-226010(HEREINAFTER
CALLED AS “MY CLIENT”). I AM INCLINED TO SEND YOU THIS LEGAL NOTICE THE
CONTENTS OF WHICH ARE SET FORTH HEREIN BELOW AND THE PROVISIONS
WHEREOF MAY BE PLEASE TO NOTE
1. That my above named client Samarjeet Singh, Aged About 32 Years, Presently
Residing at SS4/360, Vibhav Khand, Near Mantri Aawas, Gomtinagar, Lucknow –
226010 is an authorized authority in a reputed registered firm M/S Mangrove
Books Inc. engaged in a business of supplying books in bulk (Book Supplier) and
having its registered address at 4/140, Vibhav Khand, Gomtinagar, Lucknow-
226010.
2. That you had agreed to sell or entered into a formal agreement on dated
20.05.2018 to sell the property situated at Plot No. 7, Land record number(Khasra
Sankhya 87,91,93 minjumla(combined) , Chak- Malhauri, Ward-
Chinhat,Lucknow , total measuring 3300 Sq feet. You executed the formal
agreement to sell in the presence of witnesses thereof on the very same day. The
Boundary if the afore-stated property is as follow
EAST 22. Feet Road
WEST Aaraji Digar
NORTH Plot No. 8
SOUTH Plot No. 6
3. That the sale consideration of the above-mentioned land was settled at Rs
24,75,000.00 ( Twenty Four Lakh Seventy Five Thousand Rupees Only) . Out of
the total sale consideration you have received the earnest money/advance
payment of Rupees 17,00,000.00 ( Seventeen Lakhs Rupees Only) as follows-
(a)- Rs 5,00,000 (Five Lakh Rupees Only) through Cheque having Its Number
04816, Ac No.-135301500590, Drawn on- ICICI Bank, A/c Holder Name- Vijay
Kumar Mani dated 24.11.2017
(b)- Rs 5,00,000 (Five Lakhs Rupees Only) Cash on dated 27.12.2017
(c)- Rs 2,00,000 (Two Lakh Rupees Only) Through N.E.F.T On dated 15.05.2018
on your husband’Mr. Ganga Ram Baruva account having its number
30248705530, I.F.S.C- SBIN00099116.
(d)- Rs,5,00,000 (Five Lakh Rupees Only) cash on dated 20.05.2018
From my above-said client and acknowledge the above said transactions in the
afore-said sale deed in the presence of witnesses thereof. It is germane to
proclaim here that my client promised to pay the balance sale consideration
amount of Rs 7,75,000( Seven Lakh Seventy Five Thousand Only) on the date of
execution and registration of above-said Agreement to sell.
4. That as per the terms and condition of the Agreement to sell, the date for
execution and registration of the sale deed was fixed after three months and you
were bound to execute and register the sale deed of the above-mentioned land
in favour of my said client on the scheduled date.
5. That on the scheduled day after having prior discussion my client reached at the
office of Sub Registrar, along with the balance sale consideration and expenses of
stamp papers and registration charges, witnesses etc. My client waited you at the
office of Sub Registrar whole the working hours but you did not turn up to
execute and register the sale deed of the above mentioned land in favour of my
said client.
6. That since then my client have been visiting your house and has been
continuously requesting you and offered you the balance sale consideration and
requesting you also to execute and register the sale deed of the above
mentioned land in favour of my said client after but you have been avoiding to
the legitimate requests of my client on one pretext or the other. It is further to be
mentioned here that my client several times tried to meet you personally in order
to requested you to execute and register the sale deed in respect of the above
mentioned land in favour of my client on receipt of the balance sale
consideration from my client but you clearly refused to execute and register the
sale deed in favour of my said client and refused to receive the balance sale
consideration.
7. That now because of your fraudulent and dishonest intention you do not want to
execute and register the sale deed in favour of my client intentionally and
deliberately and wants to grab the hard earned money of my client which was
received by you as earnest money.
8. That since the very beginning my client was ready and is still ready and willing to
perform his part of contract but it seems that you do not want to perform your
part of contract intentionally and deliberately.
9. That the above act of yours make it abundantly clear that from the very
beginning you mischievously and intentionally gave false assurance to my client
with ulterior designs, motives and dishonest intention. It is further stated by my
client that after relying on your fictitious concocted and frivolous promises or
offers my client suffered gigantic amount of loss along with plenty much mental
harassment. The evidences of monetary losses along with other incidental
charges are safe in the hands of my client and will produce the same to
appropriate court or authority after the cession of this right of specific
performance for recovery of principle amount along with the interest through
legal proceedings.
10. That this notice is issued without prejudice to our Clients’ other rights, remedies,
claims and contentions in any other proceedings which have already
been initiated or filed and/or may be initiated or filed before any Court of Law
with regard to the aforementioned dues and specific performance of contract.
11. That you shall ignore this legal notice at your own peril and cost. A copy of this
notice is retained in my office for the future necessary actions if desired.
I, therefore, through this Legal Notice call upon
you to receive the balance sale consideration from my above said client and get
the sale Deed of the above mentioned land executed and registered in favour of
my said client along with incidental charges, legal expenses and compensation
within the period of fifteen days from the date of receipt of this Legal Notice,
failing which I have clear instructions from my above said client to file civil,
criminal complaint, suit for specific performance of contract and other Misc.
proceedings against all of you in the competent court of law and in that event
you shall be fully responsible for all costs, risks and responsibilities which you
note well.
You are also liable to pay a sum of Rs. 5500/- towards charges
for this present notice
No part of this notice has been ill-framed by the advocate and is totally/wholly based on the facts and grounds as told by the client.
Copy Retained.
Lucknow. Advocate
(Tarun Pant)
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