Ekta Mam Legal Notice Reply
Ekta Mam Legal Notice Reply
WITHOUT-PREJUDICE
BY SPEED POST/WHATSAPP/EMAIL
18.12.2023
To,
Manoj Kumar
S/O Late. Sh. Gian Chand
R/o Residential Flat/ Quarter, situated at
Tehsil Complex, Jalabad (W)
Tehsil Jalabad (W)
District: Fazilka, Punjab
Our Client:
(i) MR. DEEPAK BACHANI, Director of Vishuddha Nutriol Pvt.
Ltd., at E-63, RICO Industrial Area, Khairthal, Alwar-301404,
Rajasthan.
Dear Sir,
Rajasthan (hereinafter referred to as, “Our Client”), to serve upon you the
following reply to your legal notice dated 01.12.2023 received on 08.12.2023:
PRELIMINARY SUBMISSIONS
1. At the first instance I would like to reply to you that either your client had
not disclosed to you the true facts or circumstances or you are deliberately
trying to avoid and twisted the matter on false and frivolous grounds just
to harass and extort money from my client. In fact, sending of the legal
notice through you the addressee no.1 on behalf of your client i.e. addressee
no.2 shows the mala-fide and dishonest intention of your client to
misappropriate the business and money of our clients.
2. That while replying to your legal notice and narrating you the correct facts,
at the outset, our clients vehemently deny every content, allegation,
averments, and statement in the above-captioned legal notice under this
present reply, unless otherwise specifically admitted herein. We have
received the above-referenced notice dated 01.12.2023 on 08.12.2023, the
content of which is incorrectly riddled with factual errors, unsubstantiated
allegations and damaging imputations, misrepresentation of facts and
blatant attempt to coerce our clients.
That without prejudice to the aforesaid contents the para wise reply to the notice
is hereunder:
A. That the contents of para 1 of your legal notice are matter of record
and hence does not warrant any reply.
F. That it is germane to state here that your client is twisting the correct
facts just to harass and extort money from our client.
We, therefore, advise you to withdraw your false and baseless notice with
immediate effect. In case any litigation is being filed on the baseless and false
claims of your clients the same shall be defended with full force solely at your
costs, risks and consequences. Our clients reserve their right to file appropriate
legal proceedings against your client. Our client may initiate a criminal and civil
case against your client according to established law.
The impugned legal notice does not enumerate the cause of action as well as does
not fulfil/highlight the ingredients of offences as well as legal wrong. Your client
is put to strict proof about true and correct facts of the deal of the expired stock
between your client and our clients.
(i) To withdraw and retract the notice dated 01.12.2023 and its contents
thereof, with immediate effect. However, in case your clients still choose
to file any litigation, the same will be defended by our client solely at your
clients’ costs, risks, and consequences.
Please note that the present notice is limited to the issues herein and the contents
hereof are illustrative rather than exhaustive of any points available to our client
concerning the above matter, either at law or in equity. Our client's rights are
expressly reserved in this regard.
ADVOCATE EKTA