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CHAMBERS
(Advocates Name)
ADVOCATES & SOLICITORS

Registered /Speed Post

To
Adv. ………………..
(Address)

CC:

(Company Name And address)

Dated – ……………..

SUB:- REPLY TO LEGAL NOTICE DATED ……………. ISSUED BY YOU TO MY

CLIENT

My clients ……………….., having its office at ………………., along with all its Directors
have placed in my hands a legal notice dated ………………., issued by you under the
purported instructions of your client, namely, ………………….., instructing me to reply
thereto as under:-

At the outset, my above-named clients (all the addressees mentioned in the legal
notice sent by you) deny each and every allegation, accusation and/ or insinuation
made by your client in the notice under reply. My client has further informed me
that your notice under reply is based on incorrect and misrepresented facts. In fact,
your client has apparently misled you in scribing the notice under reply by
concealing and/or misrepresenting the true and correct facts in sending the notice
under reply.

Subject to what is submitted hereinabove, on the merits of your notice my client’s

point wise submission are as under:

1. That the contents of para 1 are false and hence denied.

2. That the contents of para 2 are factually incorrect and hence denied. In fact your
client has concealed and manipulated the facts due to reasons best known to them.
It is vehemently denied that my clients had approached your client on any occasion
or made any representations whatsoever. Whereas, it was your clients who had
approached my client for purchasing edible oils from my client company due to the
goodwill of my client in the market. It is true and admitted that my client has been

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supplying edible oil to your client and several transactions have taken place
between my client and your client.

3. That in regard to para no. 3 of your Legal Notice under reply, it is stated that the
contents of para are true and correct only to the extent that your client had been
placing orders for supply of edible oils and the remaining contents are explicitly
denied being false and frivolous. It is vehemently denied that your client was
making the advance payments towards the orders placed by your client. Instead,
your client has been making part payments against the supply of products by my
client and it was only a few occasions that your client had made advance payment. It
is vehemently denied that suddenly my client had stopped the supply of goods or
that advance payment was already made and was due on my client. Since, no
statement of account has been attached by your client along with the notice under
reply, as such the same can neither be admitted nor denied at this stage due to want
of knowledge.

4. That the contents of para 4 & 5 of the notice under reply, are wrong hence denied.
It is vehemently denied that any amount whatsoever is due and outstanding to be
paid by my client to your client. It is further vehemently denied that my client has
used the money belonging to your client or appropriated the same for their own use.
It is pertinent to mention here that an amount of Rs. 19,00,000/- was lastly
transferred by your client to my client on 03.01.2018 by way of RTGS for the
purchase of edible oils. However, the said amount was later refunded back to your
client by my client by way of Bank transfer as well as through cash since you did not
want to purchase the materials due to reasons best known to you and wanted to get
a refund. As such, my client had duly agreed to refund the amount of Rs. 19,00,000/-
as paid by you to my client and had duly refunded the said amount to your client
through bank transfers as well as through cash and as such no amount whatsoever
is outstanding to be paid by my client to your client as on date.

5. That the contents of para 6 to 8 are completely false and vehemently denied. It is
denied that there is any liability on the part of my client to be paid to your client or
that my client is liable to pay any compensation to your client as claimed by you in
the notice under reply. The present notice under reply has been sent just to harass
my client and to extort money out of my client which he is not liable to pay.

In view of the above it is stated that neither cost of the notice, nor any amount of
whatsoever nature is payable to your client by my client.

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Office: 205, Amba Deep Building, Kasturba Gandhi Marg, Connaught Place, New Delhi- 110001.
M: 9560622223. Email: santhalia@gmail.com
In these circumstances, you are requested to advise your client to withdraw the
notice under reply forthwith. In case, your client still insists to continue to
intimidate and harass my client and proceed to take any legal action or any legal
proceedings against my client, the same shall be defended by my clients at the costs,
risks and consequences of your client.

Please advise your client accordingly.

On Behalf of ………….. Pvt. Ltd. & its Directors

(Advocate)

(Place)

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Office: 205, Amba Deep Building, Kasturba Gandhi Marg, Connaught Place, New Delhi- 110001.
M: 9560622223. Email: santhalia@gmail.com