SANGRAM B.

SURYAVANSHI
B.S.L., LL.M,
Advocate High Court, Mumbai
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Office: 15, Vasudev Mension, 3rd Floor, 30-C/F, Opposite Yazdani Bakery, Cawasji
Patel Street, Fort, Mumbai - 400001
Contact: +91 97307 36824 / +91 8422953831
e-mail: suryavanshisangram@gmail.com
Ref Date: 28/11/2022

To,
Bhagvan Swarup Shukla )
Central Govt. Standing Counsel, )
Supreme Court of India & Delhi High Court, )
Ch. 459, Block-I, Delhi High Court, )
New Delhi - 1100503 )
Mob. No. 9910483635 )

Subject : Reply to your Notice dated 24th October, 2022 and 10th November,
2022 issued on and under the instructions of your Client – Hitex Industries
having registered office at L-304, Devi Indrayani Co. Op Housing Society, Dehu
Alandi Road, Talwade, Pune 411062 to my Clients to amicably settle the financial
loss of about Rs. 1.10 Crore.

Ref: 1. Notice issued by your client dated 24th October, 2022

2. Notice issued by your client dated 10th November, 2022

Dear Sir,

I am concern with my Clients – (1) RF Technology having office at B-208,

Ashoka Apartment, Navghar Cross, S. V. Road, Near Kasturi Park, Bhayander

East, Thane – 401105, (2) Mr. Raneesh Rajan R/at A-4, Gulshan Manzil Chawl,

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Behind Shivner Mohili Village, Sakinaka S. O. Mumbai – 400072 and (3) Omkar

Arunrao Jagdale Age 38 years, Occupation Business, R/at A. Y. Fadtare, Shivaji

Colony, Near Tambe School, Nakhate Wasti, Rahatani, Pune – 411017. Upon

instructions from my Clients, I am responding the allegations / contentions

referred to in your Notices dated 24th October, 2022 and 10th November, 2022

issued upon untrue / false instructions given by your Client - Hitex Industries

having registered office at L-304, Devi Indrayani Co. Op Housing Society, Dehu

Alandi Road, Talwade, Pune 411062 Mr. Manoj Kagde by suppressing the

material facts with dishonest intention.

1. At the outset, my Clients have denied all the allegations / contentions made

in the Notices dated 24th October, 2022 and 10th November, 2022

(hereinafter referred to as ‘the said Notices’) issued at the instance of

your Client. Nothing contained in said Notice should be deemed to have

been admitted, save and except stated herein.

2. As far as the contents of para No. 1 of the said Notices dated 24 th October,

2022 and 10th November, 2022 is concerned, the same are false and

baseless and your client put the strict proof thereof.

3. As far as the contents of para No. 2 of the said Notice dated 24 th October,

2022 and 10th November, 2022 is concerned, the same are false and

baseless and your client put the strict proof thereof. My client no. 2 and 3

i.e. Raneesh Rajan and Omkar Jagdale are professionally engineers and

they were worked in Monga Stryfield Company and they are expert

engineer of RF dryer machine. My clients no. 2 and 3 i.e. Raneesh Rajan

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 and Omkar Jagdale are working as freelancer as technical service engineer

of RF dryer machine for different customer. My clients were not an

employee of your client. Therefore, the question of breach and direct

violation of the employment does not arise.

4. As far as the contents of para No. 3 of the said Notice dated 24 th October,

2022 is concerned, the same are false and baseless and your client put the

strict proof thereof. My clients states that My client no. 2 and 3 i.e. Raneesh

Rajan and Omkar Jagdale were / are not any employee of your client i. e.

Hitex Industries my clients were business partner but when business set

then your client change his words, my client no. 2 and 3 are working

individual on behalf of customer and customer directly pay cash to my

client for the work done by my client.

5. As far as the contents of para No. 4 of the said Notice dated 24 th October,

2022 and 10th November, 2022 is concerned, the same are false and

baseless and your client put the strict proof thereof. My client no. 2 and 3

are technical expert as well as having knowledge of spare parts. Your client

also used my client’s expertise benefit and doing his business.

6. As far as the contents of para No. 5 of the said Notice dated 24 th October,

2022 and 10th November, 2022 is concerned, the same are false and

baseless and your client put the strict proof thereof. My clients states that

your client promises to give 10% commission on sales when your client

business is set up properly then your client deny to give commission of 10

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 % to my clients. Then my clients decline to do the business with your client.

Therefore, your client have been cheated to my clients by giving false

information. Therefore your client have committed an offence of cheating.

7. As far as the contents of para No. 6 of the said Notice dated 24 th October,

2022 and 10th November, 2022 is concerned, the same are false and

baseless and your client put the strict proof thereof.

8. In view thereof your client is hereby called upon you to withdradw the

notices dated 24th October, 2022 and 10th November, 2022 issued on behalf

of your client - Hitex Industries having registered office at L-304, Devi

Indrayani Co. Op Housing Society, Dehu Alandi Road, Talwade, Pune

411062 Mr. Manoj Kagde within 15 days from the receipt of this Reply

failing which my clients will file appropriate Civil as well as Criminal

proceedings against your client.

9. My clients are in financial/mental agony due to your client irresponsible

attitude, owing to which, assign my services as an Advocate for seeking

legal advice and instruct me to reply your notices dated 24 th October, 2022

and 10th November, 2022. Thus, the cost of this Reply cum Notice is

charged/encumbered/kept upon you, which is calculated to the tune of Rs.

10,000/- (Rupees Ten Thousand Only).

Advocate

CC to
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Hitex Industries

having registered office at L-304,

Devi Indrayani Co. Op Housing Society,

Dehu Alandi Road, Talwade, Pune 411062