Professional Documents
Culture Documents
Avdhut Bank Legal Bank
Avdhut Bank Legal Bank
Email: - legals.knk@gmail.com
SEEMA J. GANGANIA
B.A, LLB
Advocate High Court, Mumbai
Main Office:- 52/D5, Sheesh Mahal CHS ,SVP Nagar,Old Mhada, Andheri (West), Mumbai – 400053
Branch: - Kandivali/ Bhayandar
Date: 22/10/2022
To,
THE STATE BANK OF INDIA,
RACPC BORIVALI WEST (15545),
MTNL BLDG, DEVIDAS LANE,
BORIVALI WEST,
MUMBAI, 400103
1. My Clients states that paragraph number 1 of your notice is totally false and frivolous,
as my clients had not made any request to yourself as per mentioned by you in 1st
paragraph of your notice.
2. My clients states that they are not aware of anything mentioned by yourself in
paragraph number 2 of your notice as the person that you’re writing about is deceased
and you’re the best person to understand as the agreement might have taken place
between you and the deceased and my clients are not aware of anything like this.
3. My clients states that it’s very wrong and unethical on your part to compare
and state the joint relevance of property address mentioned by you in
paragraph number 3 and 4 of your notice as the address Flat no. 101 does not
exist and Flat no.202 jointly belongs to Smt. NEETA ANANT WASKAR and Shri.
AVADHOOT ANANT WASKAR.
5. My clients very strongly says that it was a very unprofessional behavior from
your end as there was NO DEMAND PROMISSORY note was taken from my
clients by the bank till date.
6. My clients also state that there was no change of securities taken from my
clients by the bank till date.
7. My clients states that there have been family splits of legal heirs of the
deceased.
8. My clients states that there have been negligence in following the procedures
of 79(A) clause by the bank as well as the builder during redevelopment
process for which my clients should not be responsible for anything during the
above mentioned process or to pay debt to anyone.
9. My clients states that their father who demised in the year 2014 and the
building was redeveloped in the year 2017. So how can you state that the
above mentioned Flat no.101 And Flat no.202 is same?
10. As per paragraph number 10 my clients states that you have been raising the
illegal demand of the total amount along with interest from my said clients
which is quite unreasonable and illegal and my clients is not liable to pay you
any amount.