Legal Notice Partition

XYZ, BBA, LL.B.
, Office:
ADVOCATE No._____, 2nd Floor,
___________________ Complex,
1st Main, Gandhinagar,
Bangalore – 560 009
Phone: _________________
Mobile: _________________
E-mail: [email protected]
BY RPAD
Dated: 16.08.2021
Sri.Rajesh.M
S/o. late Yogesh
4th Floor, No.20(Old No.25),
1st Cross,A.M. Lane,
Chickpet,Bengaluru - 560 053
Sir,
Under the instructions from and on behalf of my clients1)Smt.

Saraswati, W/o. late Yogesh, C/o. Smt. Lakshmi, #75, 5 th Main Road,
Bagalkunte, Bengaluru – 560 073, 2)Smt. Lakshmi, W/o.Gajendra,
#75, 5th Main Road, Bagalkunte, Bengaluru– 560073, 3)Smt. Latha.,
W/o. Potaraju, #83, Kallahalli, Kanakapura–562 117 and 4)Smt.
Ambika, W/o.Shivanna,RamakkaLayout, Anekal – 560 021,I issue this
notice you as under:
1. My clients state that the first of my client is the wife of late Yogesh
and 2 to 4 are the daughters and you are the son of late Yogesh.That
you and my clients are members of Hindu Undivided Joint Family.
That propositus Sri.Yogesh had inherited the ancestral property which
is more fully and particularly described in the Schedule hereunder
and hereinafter referred to as the 'Schedule Property'. Upon his demise
you and my clients have derived equal share, right, title and interest
over the Schedule Property as legal heirs of late Yogesh. My clients
state that the portion of the Schedule Property was acquired under
Partition Deed dated 20.11.1963 and the remaining half share which
had fallen to the share of Sri.Subramanya was subsequently
purchased by Smt.Nanjamma the mother of Sri.Yogesh and she
conjoined both the properties. Thus the Schedule Property is in joint
possession and enjoyment by you and my clients upon the demise of
Sri.Yogesh.
2. That my clients and you are entitled to 1/5 th equal share in the
Schedule Property. That the Schedule Property consists of 5 shops in
the Ground Floor, 2 bedrooms house in 1 st, 2nd and 3rd Floor and
Single Bedroom in Fourth Floor. That the monthly rents in respect of
the Schedule Property are promptly being paid by all the tenants and
nonetheless you have failed to share the rent with my clients in
proportion to their 1/5th share and have been assuring that you will
divide the same and still not kept your words and you have also not
shared the details with my clients.
3. That my clients have sought their share in the joint family property,
and from you and you have been assuring and promising to divide and
share the Schedule Property amongst all the legal heirs but have been
postponing the issue on one or the other pretext. That of late you have
also failed to give shelter and take care of your mother Smt. Saraswati
and now the first of my client is living with her daughters i.e., 2 nd to 4th
of my clients. That the first of my client is suffering from various age-
related ailments and needs money to meet the medical needs which
you have deprived and also neglected to look after the first of my client
and also failed to discharge your onus and duty to take care of her.
That my clients have been very sympathetic to you, as you are a
physically challenged person and all these days my clients were
extending all their kind cooperation and helping hand to you. That you
have taken undue advantage of their co-operation and sympathy and
misusing and mismanaging the joint family properties and failed to
account the income derived from rents.
4. Now it has come to my clients ’knowledge through discreet enquiry

that you are falsely propagating that you are the absolute owner of the
Schedule Property and searching for buyers in order to sell the same
and to resettle without disclosing the share of my clients and in this
regard you have engaged real estate agents to look for prospective
buyers. My clients state that they have equal share, right, title and
interest in the Schedule Property and no partition or division amongst
the Undivided Hindu Joint Family Members has ever taken place.
5. My clients hereby call upon you to divide the Schedule Property

into 5 shares and to remit the rents to my clients to the extent of their
share. That you are hereby called upon to provide the true and correct
account of the rents received since all these days and to share the
same in the ratio of 1:5 with each of my client.
THEREFORE my clients hereby call upon you to effect partition

and divide the Schedule Property by metes and bounds and put my
client into their divided share and also to pay the rent so far collected
as per their share and entitlement within 7 days from the date of
receipt of this notice, failing which my clients will be constrained to file
a suit for partition before the Hon'ble City Civil Judge Bengaluru,
without further notice and in which event you will be held liable for all
the costs and consequences arising thereon.
You are also liable to pay my client a sum of Rs.10,000/- towards

the cost of this notice.
SCHEDULE PROPERTY
All that part and parcel of residential-cum-commercial property

bearing No.20 (Old No.25), 1st Cross, A.M. Lane, Chickpet, Bengaluru,
comprising of Ground, First, Second, Third and Fourth Floors,
measuring East to West 31 feet and North to South 27.3 feet and
bounded on the:
East by : House of Lakshmamma,
West by : House of Siddappa,
North by : House of Gurappa,
South by : Road.
Sd/-
(Sri.XYZ)
Advocate
D.PRABHAKAR, B.Com., LL.B., Chambers:
ADVOCATE No.202, 2nd Floor,

Jala Shambhavi Complex,
23/22, 1st Main, Gandhinagar,
Bangalore – 560 009.
Phone: 2225 9806, 4151 3701
Mobile: 98450 15701
E-mail: [email protected]
BYRPAD
Dated: 10.03.2016
Smt. Shiva Rudramma
W/o.C. Nanja Vadeyar
Residing at House No.3127,
Basaveshwara Nagar,
K.G.F. Road,
Bangarpet Town,
Bangarpet – 563 114
Sir,
Under instructions from my client Sri. A. Murali S/o late

Ankappa, residing at No.3208, SheshachalamMudaliar Road,
Bangarpet – 563 114, I issue this notice to you as under:-
1. My client states that he is the absolute owner of Site bearing 99

and 100 formed out of Sy.No.66/1, 66/3, 83/1, 89/1, (Old No.89),
90/2, (Old No.90) and 92/4 of Inorahosahalli Village, Kasaba Hobli,
Bangarpet Taluk, Kolar District, which is hereafter referred to as Item
No. 1 & 2 of the SCHEDULE PROPERTY.
2. That you have approached my client and envisaged interest in

purchasing the schedule property from my client and upon mutual
discussion and negotiation my client has agreed to sell the schedule
property for a sale consideration of Rs.1,80,000/- free from all
encumbrances and you have agreed to purchase the schedule property
for the said sale consideration. Accordingly my client and you have
entered into two Agreements of Sale dated 16.07.2014 in respect of
each of the item of the schedule property and the same was registered
in the office of the Sub-Registrar, Bangarpet.
3. That apart your husband has also got entered into similar
agreement of sale in respect of site No.95, 96 & 97, within the layout
of the Schedule Property on the same terms and conditions and in all
you and your husband have entered into five Agreements of Sale and
got it registered on the same day. That under the said two Agreements
of Sale you have paid Rs.80,000/- in all and has agreed to pay the
balance sale consideration amount on the day of registration. Further
you have agreed to complete the sale transaction within Two years
from the date of agreement of sale.
4. That both you and your husband have fraudulently got an

agreement from my client contrary to the covenants of the registered
agreement of sale, on the very same day i.e., 16.07.2014, wherein you
have falsely stated that my client has availed loan of Rs.20,00,000/-
from you and your husband and the said agreement of sale is that of
pledge made in pursuance to the alleged loan transaction and towards
security for the alleged loan amount. That the further contents of the
said agreement says that upon repayment of the alleged loan amount,
both you and your husband would cancel the said five agreements of
sale executed in favour of you and your husband.
5. That in the month of September 2014 you have approached my

client and expressed that due to unforeseen circumstances, you are
not interested in purchasing the schedule property and requested my
client to refund the advance amount of Rs.80,000/-. My client
informed you that the advance amount cannot be refunded
immediately, as there is slow in real estate market and assured of
refunding the advance amount only upon identifying the prospective
purchaser. You have agreed to the said proposal that my client will
refund the amount on sale of the schedule property and you have also
assured of identifying the prospective purchaser and would extend all
Co-operation in this regard.
6. My client states that you and your husband have brought

Mr.M.Chandra Kumar, S/o. R.V.MuniswamyMudaliar and Smt.Syed
Noor Fathima as prospective purchasers for purchase of three sites, to
which you and your husband have entered into agreement of sale. My
client accordingly sold the schedule property under Sale Deeds dated
13.10.2014 and on 11.05.2015, has refunded you the advance
amount of Rs.80,000/-on the very same day out of the sale
consideration received from the said purchasers. That you have agreed
to cancel the agreement of sale dated 16.07.2014 and Agreement of
similar date entered into with you and your husband by my client.
7. That you have failed to execute Cancellation of Agreement of Sale

in respect of the Schedule Property and the Agreement,byviolating the
gentlemen’s agreement. That you and your wife after receipt of the
advance amount paid under Agreement of Sale are evading from
cancelling the Agreement of Sale and are acting contrary to the
understanding and Agreement dated 16.07.2014. Your acts of
receiving the amount and not complying with the terms of the
agreement amount to breach of trust and cheating my client and other
criminal offences. My client reserves liberty to initiate appropriate
criminal proceedings against both of before the court of law, apart
from filing civil suit for declaration in respect of the Agreement of Sale.
THEREFORE my client hereby calls upon you to join him to

execute the Deed for Cancellation of Agreement of Sale and Agreement
executed by you and your husband and to return the original Sale
Agreements within 7 days from this notice failing which my client will
be constrained to approach the court of law and in which event you
will be held liable for all the costs and consequences arising thereon.
That you are liable to pay a sum of Rs.10,000/- towards the cost
of this notice to my client.
Thanking you yours faithfully

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XYZ, BBA, LL.B.

Under the instructions from and on behalf of my clients1)Smt.

4. Now it has come to my clients ’knowledge through discreet enquiry

5. My clients hereby call upon you to divide the Schedule Property

THEREFORE my clients hereby call upon you to effect partition

You are also liable to pay my client a sum of Rs.10,000/- towards

All that part and parcel of residential-cum-commercial property

East by : House of Lakshmamma,

West by : House of Siddappa,

North by : House of Gurappa,

D.PRABHAKAR, B.Com., LL.B., Chambers:

ADVOCATE No.202, 2nd Floor,

Under instructions from my client Sri. A. Murali S/o late

1. My client states that he is the absolute owner of Site bearing 99

2. That you have approached my client and envisaged interest in

4. That both you and your husband have fraudulently got an

5. That in the month of September 2014 you have approached my

6. My client states that you and your husband have brought

7. That you have failed to execute Cancellation of Agreement of Sale

THEREFORE my client hereby calls upon you to join him to

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