BY RPAD

REPLY LEGAL NOTICE

11-08-2014
ATUL KUMAR JAIN, ADVOCATE,
B.e-com, M.A. (Philosophy), MBA(Finance), LLB.
High Court of Madras
Ward No. 4, Tumsar Road, Katangi,
Dist Balaghat, M.P. 481445
To,
Mr. Surendra Shukla,
Advocate, H. I. G. 11/B
Dindayal Puram, Civil Lines, Balaghat
Sub: REPLY LEGAL NOTICE.
Dear Sir,
Under the instructions of my clients Mr. Mahendra Kumar Surana,
Mr. Bisanlal Chakole, Mr. Suryakant Jain, Mr. Dheeraj Surana, Mr.
Khojanlal Chakole, all partners of M/s. Gurudev Land Developers
and Builders, having its registered ofce at Ward No. 4, Tumsar
Road, Katangi, dist Balaghat, M. P. 481445, I am hereby replying /
rebutting to your Legal Notice dated 23-07-2014 as follows:
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1. My clients state that, the contents of Para 1 of your legal
notice are matter of record and thus it is not required to
comment on the same herein.
2. My clients state that, the content of Para 2 of your legal notice
is false, fabricated, malicious and with ulterior intention of
your client. They all jointly and / or severally deny to have
any such alleged oral agreement with your client at any point
in time. My clients state that, they are a registered
partnership frm and any transaction in the frm are strictly
in writing not oral as alleged by your client. Partners No. 1, 4
and 5 as listed in your legal notice, clearly deny to have any
meeting as alleged, with your client at any point in time. They
are even surprised to receive such a fabricated legal notice
from your client, since they have never even seen your client
for any such transaction or otherwise. Your client is put to
strict proof.
3. My clients deny the allegations / averments contained in Para
3 of your legal notice. Your client is put to strict proof.
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4. My clients deny to have any such plot with the described
boundaries and Road as alleged in the Para 4 of your legal
notice. Your client is put to strict proof.
5. My clients deny the allegations / averments contained in Para
5 of your legal notice. Your client is put to strict proof.
6. My clients deny the allegations / averments contained in Para
6 of your legal notice. Your client is put to strict proof.
7. My clients state that, they had have a meeting in this regards
and they had inquired about the matter from their partner
Mr. Suryakant Jain. They had come to know about the said
alleged legal notice and the reply given by said Mr. Suryakant
Jain to your client. It was clear by the reply of Mr. Suryakant
Jain that it is a personal transaction between your client and
Mr. Suryakant Jain as they are Nephew and Uncle in relation.
My client further states that, your client and his father both
are jointly and severally in the nature of making false cases,
fabricating facts, alleging to have oral agreements, suing and
losing the cases in the court of law based of such alleged oral
agreements. Your client and his father have no other business
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to trouble their relative and our partner Mr. Suryakant Jain
and his family by some way or other and this notice to our
frm is also result of your clients malafde intention to take
advantage of the fact of issuing the Cheque in the name of
our frm. My clients state that, the fund as alleged to have
been paid in respect such alleged oral agreement to our frm
was a clear personal transaction between your client and his
uncle Mr. Suryakant Jain and said money is already been
paid to Mr. Suryakant Jain on his request then and there. My
clients once again STRICTLY STATE THAT THE POLICY IN
FIRM IS VERY STRICT AND CLEAR TO HAVE ONLY WRITTEN
AGREEMENTS FOR ANY TRANSACTION AND THEY DO NOT
ENTERTAIN AND HAVE NOT PRACTICE OF WORKING OF
ORAL AGREEMENTS OF ANY KIND OR OTERHWISE. ANY
MONEY RECEIVED ON ACCOUNT OF TOKEN MONEY FOR
BOOKING OF ANY PLOT IN THE FIRM ARE
ACKNOWLEDGED BY THE CHALLAN / RECEIPT ISSUED TO
THE PROPOSED BUYER and thus allegation of your client to
have any oral agreement with our frm is a sheer illegal and
fabricated. Detailed reply on this issue has already been sent
by Mr. Suryakant Jain to your client and his earlier counsel
Mr. Dharmendra Dhanesh on 30
th
May 2014 by Speed Post
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Acknowledged Due. A copy of the said reply notice is enclosed
herewith for ready reference ad the content of the said notice
shall be read as part and parcel of this reply notice for brevity.
Your client is put to strict proof.
8. In view of the foregoing, I call upon you to advice your client
suitably and withdraw this false and fabricated notice. If in
case your client misadventures by initiating any illegal and
unlawful proceedings against any and / or all of my clients or
Firm, they will fght it out tooth and nail all at your clients
cost and risks. This part my clients will take a proper and
suitable civil and / or criminal action against your client as
the case may be and as per the due course of law for
troubling and harassing them by sending such illegal and
unlawful fabricated legal notice if in case your client does not
apologies to them in writing within 30 days of receipt of this
reply legal notice.
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9. Your client is liable to pay a sum of Rs. 10000.00 (Rupees Ten
Thousand Only) towards the cost of this notice along with the
cost of earlier notice.
Please take note of the above and advice your client suitably.
Regards
ATUL KUMAR JAIN
ADVOCATE, HIGH COURT OF MADRAS
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