AMBUJ GUPTA GUPTA LEGAL CONSULTANTS

ADVOCATE Office: T-2319, IInd Floor, T-Block, Faiz Road,

Karol Bagh, Near Jhandewalan Metro,
New Delhi, Delhi-110005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------
Ref. No. AG/ KBO/ 040/ 18 Dated: 20.04.2018

Speed Post/ Regd. A.D./ Courier

To,

Mr.

SUB: LEGAL NOTICE OF DEMAND

Sir,

Under the instructions from and on behalf of my

clients Smt. Ruchi Nautiyal R/o G – 14, Sector – 12,
Noida – 201301, Uttar Pradesh (hereinafter called as my
‘Client’), I do hereby serve upon you the following Legal
Notice as under:-

1. That my client was offered a job for the Post of

Senior manager procurement through a letter of
intent which was sent by you the noticee no. on
______ sent by you on the behalf of your company to
my client. That in the said Letter of intent salary of
my client was fixed at Rs. 11,00,000/- P.A.

2. That my client was appointed by you the noticee

vide your letter of intent. Thereafter, my client
joined her duty on _______ with you the noticee.

3. That my client did her job diligently, regularly and

with utmost punctuality sincerely, and with full
devotion by doing her job in accordance with the
well-settled provisions of the law. You issued the
letter of intent in the name of my client.

4. That on ______ when my client came to the office

you the noticee no. abruptly called her to your
====================================================================================================================
E-Mail: ambujgupta@guptalegalconsultants.com, Mob No. : +91-9873654324

Page 1 of 5
AMBUJ GUPTA GUPTA LEGAL CONSULTANTS
ADVOCATE Office: T-2319, IInd Floor, T-Block, Faiz Road,
Karol Bagh, Near Jhandewalan Metro,
New Delhi, Delhi-110005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------
cabin and stated that the services of my client are
no more required by you the noticee and also told
my client that the said company is going through a
financial crunch and that my client will be
terminated without any reasonable rhyme and
cause. That it was further stated by you the noticee
no. That it is better for my client to resign from her
post as it would be hassle-free for the company and
also would not affect my client’s future. You the
noticee further stated that my client if terminated
might face a more difficult time securing a new
position due to the said termination and that if my
client resigns she can more easily present herself in
a positive light for prospective employers.

5. At the time of resignation of the services of my

client, you the noticee did not pay the salary for the
month of ________ and ____ days salary for the
month of ________ which comes to Rs. ____/- to my
said client.

6. That you did not pay the salary of Rs. ____/- and the
amount of bonus of Rs. ____/- which totally comes
to Rs. ____/-.

7. That after persistent requests and regular follow-

ups from my client’s side, you the Noticee agreed to
make the payment of Rs. /- towards the balance
outstanding amount and asked some time to pay
the said amount and thereafter requested my client
to wait for the mail for full and final settlement as
the company is busy in closing of the financial year
and would email my client at the earliest possible as
per you the noticees assurances my client believing

====================================================================================================================
E-Mail: ambujgupta@guptalegalconsultants.com, Mob No. : +91-9873654324

Page 2 of 5
AMBUJ GUPTA GUPTA LEGAL CONSULTANTS
ADVOCATE Office: T-2319, IInd Floor, T-Block, Faiz Road,
Karol Bagh, Near Jhandewalan Metro,
New Delhi, Delhi-110005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------
upon you had no other option but to wait for your
mail.

8. That thereafter upon receiving your email dated ____

my client was shocked to learn that you the noticee
in your email only offered to pay Rs. ____/- as full
and final settlement whereas the total outstanding
amount was at Rs. /-.

9. That my client intimated the same to you the

noticee. Thereafter, my client repeatedly called on
your telephones to inform you about the said
outstanding amount, that you the noticee on one
pretext or another avoided the said payment despite
repeated follow-ups through various verbal
discussions, repeated reminders, emails, etc. but all
went in vain as the amount has not been paid till
date.

10. That my client has suffered irreparable loss at the

hands of you the noticees due to the wilful and
malafide conduct, though the same can never be
measured in terms of money, for which my client
reserves the right to sue at the appropriate stage.

11. That from your conduct of making false, dishonest

representations, promises and assurances and in
deliberately not making the payment and thus
thereby causing wrongful loss to my client and
wrongful gains to yourselves is indicative of your
nefarious designs and ulterior motives to cheat and
defraud my client. The said acts, omissions and
other surrounding circumstances amply establish
that you had made false representations, promises
and assurances with a prior intention to not ensure
====================================================================================================================
E-Mail: ambujgupta@guptalegalconsultants.com, Mob No. : +91-9873654324

Page 3 of 5
AMBUJ GUPTA GUPTA LEGAL CONSULTANTS
ADVOCATE Office: T-2319, IInd Floor, T-Block, Faiz Road,
Karol Bagh, Near Jhandewalan Metro,
New Delhi, Delhi-110005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------
the payment of the dues and thus cheat and
defraud my client. Such acts/ omissions amount to
commission of serious criminal offences punishable
under IPC. It is apt to write that there are provisions
for imprisonment under Indian Panel Code and
which may be rigorous.

12. My Client shall separately take recourse to the other

legal proceedings for initiating legal action for your
other acts of cheating and fraud, as would be
advisable under the law. My Client reserves the legal
right to take such recourse to law and legal process
including civil action for recovery of dues, interest
and compensation in future.

13. That you are liable to pay to My Client the aforesaid

amount of Rs. /- (Rupees Only) in respect
of the above-mentioned transactions, within 15 days
from the receipt of the present notice.

I, do hereby call upon you to remit the payment of Rs.

/- (Rupees only), within 15 days from the date of receipt of
this Legal Notice. You are further called upon to pay interest
@ 2% p.m. from the due date of the said sum till the date of
actual payment. Failing which necessary legal action (Civil
as well as Criminal) will be instituted against you the
noticee without any further notice and solely at your risks,
costs and consequences.

Please note that the failure to comply with the

aforesaid notice within the stipulated time shall expose you
to the aforesaid criminal proceedings under relevant
provisions of Indian Penal Code, 1860 and code of civil
procedure code, 1908.
====================================================================================================================
E-Mail: ambujgupta@guptalegalconsultants.com, Mob No. : +91-9873654324

Page 4 of 5
AMBUJ GUPTA GUPTA LEGAL CONSULTANTS
ADVOCATE Office: T-2319, IInd Floor, T-Block, Faiz Road,
Karol Bagh, Near Jhandewalan Metro,
New Delhi, Delhi-110005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------
Failing Compliance, my client Smt. Ruchi Nautiyal
reserves his rights to initiate an appropriate legal
proceeding against you the addressee for recovery of the
total amount i.e. Rs. __________ /-.

The copy of this Legal Notice has been retained in our

office for further necessary proceedings against you, in case
compliance is not made within the stipulated period as
mentioned above.

AMBUJ GUPTA

ADVOCATE

====================================================================================================================
E-Mail: ambujgupta@guptalegalconsultants.com, Mob No. : +91-9873654324

Page 5 of 5