530, STERLING CENTER, MOHD FARHAN KHAN

M.G. ROAD, CAMP, PUNE ADVOCATE

MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

Date: 28.10.2022

LEGAL NOTICE

(WITHOUT PREJUDICE TO THE OTHER RIGHT’S UNDER THE LAW)

To,

1. EVA BARTELS THOMSEN

FOUNDER OF SMA
ADDRESS: 3RD FLOOR, D541 OFFICE
BUILDING, SPINAGAR INDRA ROAD,
SUAN LUANG BANGKOK
EVA@SMAMAKEUPACADEMY.COM

2. NICOLAI BARTELS THOMSEN

FOUNDER OF SMA
ADDRESS: 3RD FLOOR, D541 OFFICE
BUILDING, SPINAGAR INDRA ROAD,
SUAN LUANG BANGKOK
NICOLAI@SMAMAKEUPACADEMY.COM
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

3. RITA VERMA
PARTNER & DIRECTOR & CEO OF
SMA INTERNATIONAL MAKEUP ACADEMY
ADDRESS: BUSINESS SQUARE, OFFICE NO. 301,
SR.NO.26 LANE NO.5, KOREGAON PARK,
PUNE, INDIA – 411001
RITA@SMAMAKEUPACADEMY.COM
+91-830828095

4. HILDE MARIE JOHANSEN

FOUNDER OF SMA INTERNATIONAL
MAKEUP ACADEMY
ADDRESS: BUSINESS SQUARE,
OFFICE NO. 301, SR.NO.26 LANE NO.5,
KOREGAON PARK, PUNE, INDIA – 411001
HILDE@SMAMAKEUPACADEMY.COM
+91-8412012300

Under instructions from and on behalf of my client, Mr. Mojtaba

Arabiyan, S/o Akbar Arabiyan, Residing at 2, Naylor Road,
Building – D, Flat No. 3, Mourya Society, Pune - 411001 and acting
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

upon his advice, I hereby serve upon you the following legal notice.
My client has been subjected to continuous and severe cheating,
mental and physical harassment, criminal intimidation, breach of
trust, physical assault targeting his sexual orientation, insults
related to his sexual identity, and the spreading of false narratives
against him within the class. These acts have caused significant
harm, including deficiency in service, unfair trade practices, and
repeated public defamation. This ongoing misconduct at the
School of Makeup Academy (SMA) has inflicted immense distress
on my client, exacerbating his pre-existing health condition,
specifically kidney stones, which has led to severe emotional
breakdowns. The nature of these actions constitutes criminal
misconduct, and should any further harm befall my client as a
result of these acts, all responsible parties will be held liable and
prosecuted under the relevant provisions of law.

1. My client respectfully states that he harboured a genuine

interest in mastering professional makeup and, with great
anticipation, was drawn to enroll at SMA INTERNATIONAL
MAKEUP ACADEMY, situated at 301, 3rd Floor, Business
Square, Lane 5, Koregaon Road, Ganga Fortune Society,
Meera Nagar, Koregaon Park, Pune, Maharashtra 411001.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

This decision was significantly influenced by a promotional

advertisement on social media, particularly Instagram, which
highlighted that the batch would be personally conducted
by Ms. Hilde Marie Johansen, a makeup professional whom
my client deeply admires. My client specifically sought to
learn under her guidance, given her expertise in the field.
After making an inquiry, he received a message via whatsapp
from Ms. Rubusha on 13th October 2022, detailing the
course fees and associated bank details. Subsequently, my
client remitted the following payments online: Rs. 5,000 on
13th October 2022, Rs. 75,000 on 11th November 2022, Rs.
75,000 on 13th November 2022, Rs. 25,000 on 13th
November 2022, and Rs. 79,600 on 28th November 2022,
amounting to a total of Rs. 2,59,600 for the course fees.
However, on the first day of class, my client was informed
that Ms. Hilde Marie Johansen would be unavailable to
conduct the fashion and fantasy module due to personal
reasons. Although this unexpected change was
disappointing, my client continued with the program,
trusting in the academy’s assurances and extending his best
wishes for Ms. Johansen’s recovery.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

2. On the first day of classes in May 2023, my client explicitly

disclosed to the faculty members—namely Ms. Rita, Ms.
Apurva, Ms. Sameera, Ms. Beverly, and Ms. Khushboo—his
Muslim background and the significant constraints imposed
by his conservative family concerning his pursuit of makeup
artistry. He emphasized that, due to these restrictive beliefs,
he is in a highly vulnerable position, having saved diligently
over a period of three years to fulfill his aspiration of learning
makeup specifically under the guidance of Ms. Hilde
Johansen at the School of Makeup Academy (SMA). My client
further conveyed that, to protect his personal safety, he
informed his family that he is enrolled in advanced levels of
Pranic Healing, rather than makeup training, as revealing the
truth could expose him to severe physical danger, as well as
mental and emotional abuse,. Additionally, he communicated
his ADHD(Attention deficit hyperactivity disorder) diagnosis
and detailed the severe trauma and PTSD (Post-Traumatic
Stress Disorder) he has endured as a result of childhood
abuse.
3. My client informed SMA management of his ADHD, which
influences his excitement and curiosity in learning. Despite
this disclosure, management failed to provide a supportive
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

environment. Furthermore, my client was enduring

significant physical pain from a 30mm kidney stone,
necessitating surgery on 19th June 2023. In spite of these
critical health conditions, staff members continued to subject
him to mistreatment.
4. Since May 2023, my client has faced persistent harassment
from staff members Ms. Apurva Patil, Ms. Sameera Shaikh,
and Ms. Rita Verma Agarwal. Despite disclosing a traumatic
personal history of sexual abuse and severe insecurities,
these staff members showed indifference and hostility toward
him. In particular, following Ms. Sameera's return from
Bangalore, her behavior became openly hostile, repeatedly
insulting my client in front of other students, which severely
impacted his self-esteem. During practical sessions, Ms.
Sameera consistently ignored his requests for assistance,
prioritizing other students, forcing him to wait for up to an
hour, causing him significant emotional distress. On one
occasion, she publicly humiliated him for a minor error,
suggesting he restart the course due to a mistake while
applying eyeliner, triggering an emotional breakdown. On the
same day, my client’s physical health deteriorated, requiring
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

hospitalization due to pain from a 30mm kidney stone,

further exacerbating his mental and emotional suffering.
5. Following repeated mistreatment, my client approached SMA
management seeking a resolution, including a request to
discontinue the course and a refund for the remaining
amount. Expressing concerns for his well-being and safety,
management initially urged patience and promised a
resolution by August 2023. My client, who had saved course
fees through two years of work in Goa as a fortune teller,
continued to face financial strain due to the ongoing issues
at SMA. Management later assured him that he could join the
August 2023 batch at no extra cost, with a guarantee that
Ms. Sameera Shaikh would not be teaching; however, in early
August, management informed him that Ms. Sameera would
indeed be instructing the batch, contradicting their
assurances. Upon questioning, management admitted these
promises were merely intended to pacify him, exposing a lack
of professionalism and integrity. Management further
claimed they would consult with Ms. Eva during a Thailand
trip to resolve the issue, yet no action followed. Additionally,
management falsely asserted that Ms. Sameera had
apologized, which she had not, either privately or publicly. In
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

response to his renewed refund request, management

threatened to rusticate my client for classroom behavior,
such as talking and joking, a pretext raised only after his
refund request, underscoring the unprofessional conduct
and lack of accountability exhibited by SMA management.
6. In a meeting on August 23, 2023, my client was informed by
SMA management that a trainer from Spain, David, would be
arriving to teach the fashion and fantasy module. However,
management specified that Ms. Sameera would conduct the
bridal module, despite my client’s pending bridal exam and
incomplete bridal program. Management then offered the
option to join the December 2023 or February 2024 batch,
demonstrating a failure to track my client’s course
progression accurately. During this meeting, my client
disclosed severe financial and health challenges, including a
2.8mm kidney stone. Supporting sonography from
September 6, 2023, was provided, confirming his medical
hardship. Facing financial distress, my client requested
permission to delay his attendance until May 2024, to which
management initially agreed. However, they later informed
him that attendance from the start of the May batch was
conditional on his health, contrary to previous assurances.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

Management then cancelled his access to the aftercare

program without justification, adding undue hardship. After
numerous emails and submission of a doctor’s certification
stating he was unfit to attend until June 2024, my client was
ultimately permitted to join the July 2024 batch, but only
after a lengthy and unnecessary exchange.

7. My client was denied a model for practice during makeup

practical’s in the July 2024 batch, unlike other students who
were regularly provided with models. Despite his requests to
management, particularly to Nitin Agarwal and Juhi, for
equal practice opportunities, no explanation was given for
their refusal. On July 8, 2024, my client requested model
contact numbers from Apurva, who delayed their release
until July 10, merely hours before he was expected to secure
a model for July 11. This short notice left him with limited
time to arrange for a model, especially as he had faced prior
model cancellations, adding to his stress and anxiety.
Through considerable effort, he ultimately arranged models
at no cost, showing commitment under highly stressful
conditions.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

8. On July 15, 2024, my client purchased an eyebrow brush

from Juhi Khemnani at SMA Pune. Despite multiple
reminders via WhatsApp and in person, the receipt was only
provided on July 24, causing undue stress. Additionally, on
July 18, Apurva unexpectedly pressured my client’s model,
Aishu, to join a demo scheduled for July 19, despite his
advance booking. Aishu expressed her discomfort due to
Apurva’s failure to provide her with shoot images over the
past two years, making her hesitant to participate. Though
my client considered escalating this to Rita, he chose
patience, hoping it was an isolated incident.
9. On July 24 and 26, 2024, my client experienced an
intimidating encounter with Apurva in the restroom at SMA,
where Apurva entered, locked the main door, and began
vaping. When questioned, Apurva responded with
intimidation, instructing my client to keep the incident
confidential, warning that Rita disapproved of my client and
would scold him if he sought Apurva’s assistance with
photographing models. Under duress, my client felt
compelled to promise silence, fearing expulsion. This conduct
raises serious concerns about safety and professionalism, as
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

such unprofessional behavior compromises the emotional

and physical well-being of students.
10. On July 25, 2024, my client requested permission from Juhi
Khemnani to practice on a model at SMA on July 28 but was
directed instead to practice on July 27. Then, during the July
29 exam, my client was paired with a model, Nikita Gawas,
and was the first to complete the assigned look. Despite this,
Apurva restricted him from using a DSLR to record, delaying
Nikita’s turn in the photobooth until other students had
completed their work, resulting in only 25-35 photos for his
model versus 65+ for others, causing emotional distress.
11. During the July 2024 batch, Apurva requested a tarot reading
after class. My client offered a numerology session as a
complimentary gesture but informed her that tarot readings
were part of his professional work and charged accordingly.
Apurva reacted with apparent displeasure, showing
unprofessional conduct that impacted the working
relationship and created discomfort for my client.
12. On August 5 and 8, 2024, my client contacted Apurva via
WhatsApp with class-related queries; however, Apurva
ignored these messages and failed to provide necessary
clarification. In July and August 2024, my client notified
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

Apurva of a prior booking made on July 13, 2024, for the

model Vidya to work on two bridal looks scheduled for August
7 and 8. On August 6, Vidya reached out to my client
regarding outfit details, which my client immediately
forwarded to Apurva. Apurva disregarded this message and
knowingly double-booked Vidya for a demo on August 7.
13. At 11:45 p.m. on August 6, Vidya cancelled her professional
engagement regarding the make-up practical’s with my client,
citing Apurva's request to Vidya for participating in her demo
practical. This last-minute cancellation caused significant
stress, particularly challenging for my client, who has ADHD
and finds it difficult to manage sudden disruptions. Forced to
seek a replacement model past midnight, my client faced
unreasonable pressure.
14. The following day, when my client voiced frustration about
the situation, he was summoned to a meeting with Apurva
and Juhi, where he was reprimanded for referring to Vidya as
"unprofessional." Denied an opportunity to explain the
impact of the abrupt model cancellation, my client
experienced intimidation and was coerced by Rita into signing
a warning letter. He was told the letter held no significance
and was merely an acknowledgment not to make similar
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

comments. This letter was presented during a busy makeup

practice session, affording my client insufficient time to
review its contents thoroughly, thus depriving him of a fair
and clear understanding of the matter.
15. On August 7, 2024, my client’s model, Aditi Jajot, arrived for
a Western bridal makeup session. Despite multiple requests,
Apurva and Rita failed to provide essential accessories, such
as jewellery and a bridal veil. Following the makeup session,
Apurva summoned my client to the restroom, where she
reprimanded him and discouraged him from seeking her
assistance with photography, stating, "Rita hates you, Mojo,
and if you call me for help, Rita will not allow it, as she is
against you." Although my client continued to request the
required items, Apurva claimed they were unavailable.
Shortly thereafter, Apurva left for a meeting with Rita, Brinda,
and Juhi, leaving my client unsupported.
16. My client further reports that on the same day, Apurva
provided jewelry and a veil to Vidya, another model, who was
double-booked by Apurva. This selective provision of items
demonstrated clear intent to undermine my client’s work and
humiliate him in front of Aditi, who repeatedly questioned
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

him about the lack of necessary accessories, exacerbating the

unprofessional treatment and creating a sense of humiliation.
17. The following day, on August 8, 2024, during a photoshoot
with his model, Khushi, Apurva’s behavior escalated. While
my client was recording Khushi for the shoot, Gunjan made
a comment, provoking Apurva to rush over and turn off the
star light abruptly, disrupting the shoot without warning.
This act startled both my client and Khushi, who later
messaged my client to express her disappointment with the
session's outcome, citing the interference as the reason for
subpar photos.
18. Moreover, my client learned from Shireen that other students,
Reema and Tanya, in the April 2024 batch, were allowed to
stay late (until 8 or 9 PM) to complete makeup practice,
receiving assistance from Apurva. Despite this, when my
client requested similar accommodations, he faced
unwarranted restrictions.
19. My client also received a recommendation for model Pooja
Arahunshi and subsequently booked her in July for August
13, 2024. On August 8, in Juhi's cabin, with Apurva and Rita
present, my client informed them that he had booked Manavi
Raut as his model for August 9, 2024, and Pooja Arahunshi
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

for August 13, 2024. He expressly requested, in the presence

of Juhi and Apurva, that Pooja not be double-booked, as she
had been scheduled a month in advance. Juhi and Apurva
assured him, with Rita present, that Pooja would not be
double-booked, confirming that the discussion served to
prevent such scheduling conflicts.
20. On August 9, 2024, my client informed Apurva that Pooja
Arahunshi would be his model for August 12, 2024, and
specifically requested no double-booking. Apurva assured
that Pooja would remain available on that date. Shortly after,
on August 5, 2024, Apurva inquired privately with my client
regarding tarot card reading charges and asked him not to
disclose this conversation to the School of Makeup Academy
(SMA) staff. In good faith, my client provided the information,
unaware that Apurva would later use this inquiry against
him.
21. On August 10, 2024, Apurva booked my client for a tarot card
reading session. Meanwhile, students Gunjan, Sneha, and
Srishti, who failed their theory exams, frequently withheld
essential Airbrush products at their stations, despite
repeated requests from my client. In addition, Sneha
frequently interrupted by running into my client’s station
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

during practical sessions, disrupting his focus and crowding

the workspace. Gunjan engaged in deliberate, disruptive
behavior, including slapping my client on the forehead and
verbally threatening him during lunch breaks in front of other
students, such as Manya, Shireen, and Srishti. My client also
observed Gunjan regularly carrying alcohol in her bag and
pressuring him and others, along with Apurva, to purchase
alcohol following his exam success.
22. My client consistently reported these issues to Apurva;
however, she delayed addressing them, issuing only a general
announcement over a week later without immediate
intervention. Further, Manasi Badekar’s disruptive actions of
deliberately increasing music volume while my client was
clarifying doubts with Apurva severely impacted my client,
who has ADHD, sinus, and migraine conditions that are
aggravated by loud noise. Instead of assisting, Apurva
laughed, worsening my client’s distress and creating a hostile
learning environment.
23. In August 2024, during a lunch break, my client engaged in
a courteous discussion with Brinda about her gemstones
when Manasi abruptly interrupted, rebuking Brinda and
ordering her not to converse with my client on the practical
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

floor. A few days later, Juhi falsely accused my client of using

offensive language during the conversation. Despite my
client’s denial and request for clarification, Juhi refused to
allow him an opportunity to defend himself, indicating bias
against him.
24. On August 10, 2024, while my client was dining with friends,
he texted Apurva about her tarot card reading session timing.
Apurva responded that she was uncertain due to a bridal
trial. Soon afterward, my client received a call from Pooja
Arahunshi, revealing that Apurva had approached her,
offering Rs. 1,000 to act as a model for the hair exam
scheduled on Tuesday, August 13, 2024. This incident
represents the third instance of Apurva’s deliberate
interference with my client's model bookings, reflecting an
intent to undermine my client’s work, especially distressing
given his ADHD, which heightens his stress and disrupts his
ability to function with last-minute model cancellations.
25. In response, my client messaged Apurva, expressing his hurt
and frustration at the repeated booking disruptions,
reminding her that he had previously confirmed Pooja
Arahunshi as his model on August 13 and had clearly
requested no double-booking. Further, my client also
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

messaged Juhi via the SMA back-end team number about the
ongoing model booking issues. Just as he was about to
contact Rita regarding this matter, Apurva called, pressuring
him to delete the message sent to Juhi, warning that any
such communication would count against him due to his
warning letter. Fearing termination, my client reluctantly
complied, refraining from notifying Rita.
26. During the WhatsApp call, Apurva offered a seemingly
insincere apology, acknowledging her prior conduct and
assuring my client that similar incidents would not recur,
advising him to continue providing model names in advance.
Despite my client’s repeated notifications, specifically
identifying Pooja as his model for August 13 in front of Rita
and Juhi, Apurva later deflected responsibility, citing
miscommunication with Juhi, who she claimed was
inexperienced in arranging models, leading Apurva to
manage bookings on her behalf.
27. On August 12, 2024, during a practical session, my client
made a light-hearted remark about his excitement over the
use of a Fenty highlighter, humorously stating, "It's my
favourite highlighter, I'm so excited, I might jump out of the
window," which resulted in laughter from the class. A witness
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

supports that this comment was made in a light-hearted

manner. However, my client was later confronted by Juhi in
an abrupt and condescending tone, insisting that all students
must leave after practice and requesting he meet Rita in the
cabin. My client observed Juhi and Apurva in a separate
room, seemingly plotting against him, rather than assisting
on the practical floor.
28. Subsequently, students Gunjan, Sneha, and Srishti were
reportedly compelled to write statements against my client to
support his termination. Shireen corroborates that all other
students were sent downstairs, leaving only my client with
Rita, Nitin, Apurva, Brinda, and Juhi, who proceeded to
intimidate, harass, and coerce him into signing a termination
letter filled with false allegations, including an alleged threat
to push students out of the window. My client was denied the
opportunity to thoroughly read the letter, containing multiple
pages, and after reading only the first few lines, was
pressured to sign immediately. Recognizing the document as
fraudulent, my client refused to sign, as he was not permitted
to explain himself.
29. Ankita, my client’s model, overheard the confrontation and
subsequently checked on his well-being, later contacting him
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

on August 13 and again on August 15, 2024, to express that

she witnessed the harassment and coercion tactics used by
SMA staff and director Rita to pressure him into signing the
termination letter. During the intimidation, threats were
made to inform his father about his enrollment in makeup
classes if he did not comply. Additionally, when my client
requested the academy’s DSLR camera to photograph Ankita,
Apurva promised to provide it within ten minutes but did not
follow through. Later, during the photoshoot, Brinda abruptly
turned off the star lights, startling both my client and Ankita.
30. My client questions why Apurva consistently seeks to book
the same models on identical dates, despite clear prior
confirmation by him of these bookings, often secured weeks
to a month in advance. It is perplexing that Apurva does not
arrange for her demo models on alternative dates, avoiding
unnecessary conflicts. My client perceives Apurva’s repeated
interference, including pressuring his models to participate
in her demos, as targeted and deliberate. He believes this
pattern of conduct is fuelled by a personal vendetta,
particularly after his decision not to provide Apurva with a
complimentary tarot reading. These actions suggest a
calculated effort by Apurva to intimidate and undermine my
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

client, with an apparent aim of seeking his termination from

SMA.
31. My client feels subjected to bullying and harassment by
several SMA staff members, including Manasi Badekar from
Hair Originals, resulting in significant mental and emotional
distress. Given my client’s health conditions—ADHD, PTSD,
sinus issues, migraines, fatty liver, and kidney stones—this
behaviours exacerbates their vulnerability. Additionally, my
client asserts that Rita threatened to inform his father about
his enrolment in makeup classes should he refuse to sign the
termination letter, a threat that raises serious concerns due
to the potential risk of physical abuse, as my client identifies
as a member of the LGBTQ+ community. My client had
previously confided in Rita, whom they viewed as a motherly
figure, seeking her support, yet her actions have placed my
client in a situation of fear and potential abuse at home.
Furthermore, Rita contacted my client's father via WhatsApp,
notifying him of their suspension, thus increasing the
likelihood of verbal, emotional, and physical harm within the
household.
32. My client also contends that Apurva and Rita manipulated
students such as Gunjan, Sneha, and Srishti into submitting
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

baseless complaints, accusing him of disrupting class by

asking questions. These allegations are without merit, as
seeking clarification is standard in any educational setting,
particularly for students with learning disabilities. In
contrast, feedback from multiple models, including Aishu,
Ankita, Nikita, Riya, Aishwariya, and Pooja, reflects positively
on my client's professionalism, indicating an enjoyable and
constructive working environment.
33. On 23rd August 2024, my client had a conversation with
Vinali, who disclosed that SMA staff, including Rita, had
bullied other students in her February 2023 batch,
describing a persistently toxic environment and noting SMA’s
lack of transparency regarding the teaching lineup,
specifically about Hilde’s absence. Vinali also corroborated
instances of bullying directed at my client by Sameera, an
SMA trainer, during the May 2023 batch. On 27th August
2024, Shireen informed my client that models were arranged
for an odd student in their batch for fashion makeup practice;
however, my client was denied this same support when they
were in a similar position, which is unfair. Upon reaching out
to SMA Founder Hilde Marie Johansen, my client was blocked
without any response.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

34. Subsequently, on 1st October 2024, Srishti informed my

client that Apurva pressured Gunjan to lodge a complaint
against them and coerced Srishti and Sneha into submitting
letters to create additional issues. Additionally, Srishti,
Manyaa, Vinali, Shireen, and Tanu confirmed that my client
did not threaten to push any student out of the window,
clarifying that a lighthearted comment made on 12th August
about their favorite Fenty highlighter was misconstrued; it
was clearly in jest and received laughter from the class,
including the trainers. My client has received further
feedback from other students, including Vinali, affirming that
SMA staff, particularly Rita, engaged in bullying behavior,
contributing to a hostile environment.
35. Finally, on 12th August, my client’s makeup practice and
photoshoot were interrupted by Gunjan’s continuous
disruptions, and Apurva’s intervention involved turning off
the lights during a video recording, which my client regards
as an unprofessional and unsupportive act by SMA staff.
36. My client states that on 12th August 2024, Srishti and
Shireen reported that Vinali overheard SMA staff shouting,
threatening, and coercing my client to sign a termination
letter, reflecting a pattern of abusive and intimidating tactics
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

within the academy. Srishti further revealed that Apurva and

Manasi often mock students during practical sessions,
fostering a hostile environment that compromises the
learning experience and adversely affects students’ mental
well-being. These actions have severely impacted my client’s
mental and emotional health, aggravating pre-existing health
issues including ADHD, sinus problems, migraines, fatty
liver, and kidney stones. Additionally, as a vulnerable
member of the LGBT community, my client was subjected to
deliberate emotional exploitation by SMA staff, resulting in
significant psychological harm. Furthermore, my client has
endured baseless accusations from Gunjan, Sneha, and
Srishti, without evidence, damaging their reputation at SMA
and causing considerable stress.
37. My client had enrolled in your prestigious P4 Master Makeup
Program, which includes four levels: Fundamental - Beauty,
Bridal, Fashion, and Fantasy Makeup. This course was
specifically designed to be completed within a total of 70 days
of class. My client paid a total amount of ₹2,59,600/- fees to
SMA Pune for the aforementioned program. The payments
were made in October and November 2022. Despite having
fully paid the required fees and enrolling in the complete
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

course, my client has only been allowed to attend 26 days of

class out of the total 70 days as promised at the time of
admission. This significant shortfall in providing classes has
caused my client substantial hardship and disrupted his
education and career aspirations in the makeup industry.
38. My client made several attempts to address this issue with
SMA Pune management but has not received any satisfactory
response. As a result, your failure to comply the terms of the
course, coupled with the restricted class attendance,
amounts to Deficiency of Services U/S. 2(1)(g), fraud and
Unfair Trade Practices U/S. 2(1)(r) of Consumer Protection
Act 1986. My client is a consumer U/S. 2(1)(d)(iii) and the
services defined U/S.2 (o) of the said Act.
39. In light of the above, my client demands the immediate refund
of the ₹2,59,600/- paid for the program, as the services you
promised were not delivered in full, and my client was
deprived of the opportunity to complete the course as per the
agreed schedule. Furthermore, I hereby assert claim for
Compensation in the amount of Rs. 50,000/- from you. This
amount is sought as reparation for the legal expenses and
other associated costs that my client has been compelled to
incur due to your actions, resulted in considerable mental
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

distress and the continuous mental harassment emotional

stress and intimidation inflicted upon my client by you
notably exacerbated by the fact that you are fully aware of my
client’s compromised health situation.
40. If you fail to refund the said amount within 15 days of receipt
of this notice, my client will be constrained to take
appropriate legal action in the appropriate court of law to
seek justice for the harassment, intimidation, discrimination,
Mental Stress, defamation, and emotional abuse suffered
against you to recover the said amount along with interest,
costs, and damages. for which my client shall proceed to file
a separate criminal case against you all.
41. My client made several attempts to address this issue with
SMA Pune management but has not received any satisfactory
response. As a result, your failure to comply the terms of the
course, coupled with the restricted class attendance,
amounts to Deficiency of Services U/S. 2(1)(g), fraud and
Unfair Trade Practices U/S. 2(1)(r) of Consumer
Protection Act 1986. My client is a consumer U/S.
2(1)(d)(iii) and the services defined U/S.2 (o) of the said
Act.
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

42. In doing so, you have committed the act of Fraud and
Cheating, Criminal Conspiracy, Criminal Breach of
Trust, Criminal intimidation in terms of defining
sections 61, 316, 318 and 351, and their punishment
under sections 61(2), 316(2), 318(4) and, 351(2) (3),
Bharatiya Nyaya Sanhita, 2023 (BNS). Moreover, you
people have deliberately cause mental distress, despite
knowing the health condition of my client, in order to
harm him, which would affect my client severely.
43. I, therefore, call upon you to refund the total amount of
₹2,59,600/- paid by my client for the course, due to your
failure to deliver the promised services and breach of the
agreed terms. Additionally, I demand that you compensate
my client with ₹50,000/- for the legal expenses and emotional
distress he has endured as a result of your conduct.
44. Furthermore, I call upon each of you to send a separate
personal apology to my client within 24 hours of receiving this
notice, acknowledging the discrimination, mental
harassment, and emotional suffering inflicted upon him. This
apology must reflect recognition of the distress caused,
particularly in light of his pre-existing health conditions and
vulnerabilities. In addition, I demand that you publicly
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

retract all defamatory statements made against my client,

both verbally and in writing, and ensure that such retraction
is prominently displayed within the academy premises to
repair the reputational harm suffered.
45. I also call upon each of you to issue a written apology within
24 hours from the receipt of this notice for all false
accusations advanced against my client, replicating the same
manner in which these threats and accusations were
conveyed, including by email. Failure to comply with this
demand will leave my client with no alternative but to initiate
criminal proceedings against you for the harm caused to his
mental, emotional, and professional well-being.
46. Finally, I call upon you to immediately cease all forms of
harassment, intimidation, and discriminatory behaviour
towards my client and to comply with the services initially
promised, including providing him with full access to models,
aftercare programs, and the completion of the course as per
the agreed terms. If you fail to meet these demands within 15
days of receiving this notice, my client will be compelled to
initiate appropriate legal proceedings, including criminal
complaints under the provisions of the Bhartiya Nyaya
Sanhita, 2023, for fraud, breach of trust, conspiracy, and
530, STERLING CENTER, MOHD FARHAN KHAN
M.G. ROAD, CAMP, PUNE ADVOCATE
MAHARASHTRA - 411001 SUPREME COURT OF INDIA
+91-9582526224, +91-9021494379,
+91-9971350230, 011-40052021
mohd.farhan.khan@live.com

defamation. My client will also seek additional compensation

for the damages, interest, and costs resulting from the
distress and financial losses caused by your misconduct.

KINDLY TAKE NOTE OF IT

Sincerely,

MOHD FARHAN KHAN

Advocate
Supreme Court of India
35, Lawyers Chamber,
Bhagwan Das Road, New Delhi - 110001
+91-9582526224, +91-9021494379
mohd.farhan.khan@live.com