Mob: - 9167605656/9167195656

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: 26/10/2022
To,
THE STATE BANK OF INDIA,
RACPC BORIVALI WEST (15545),
MTNL BLDG, DEVIDAS LANE,
BORIVALI WEST,
MUMBAI, 400103

SUBJECT: - REPLY HAVING SUBJECT : DEMAND BEFORE INITIATING LEGAL

ACTION/SARFAESIACTION NOTICE DATED 06/10/2022.
Dear Sir,
I have been instructed by my clients named as below to reply to your notice dated 06/10/2022.
Smt. Neeta Anant Waskar(Widow)( Legal Heir)
Shri. Avadhoot Anant Waskar(Son) )( Legal Heir)
Shri. Prashant Anant Waskar(Son) )( Legal Heir)
Mrs. Smita Hemant Nagwekar(Daughter) )( Legal Heir)
Residence & Property address :
Flat No.202, 2nd floor, Nalini Bhuvan CHSL, Opp. Municipal School, D.N.Mhatre Road,
Eksar ,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 1 st
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 Mrs. SMITA HEMANT NAGWEKAR and
Shri. AVADHOOT ANANT WASKAR.

4. Further my clients states that paragraph number 5 of your notice is totally

false and frivolous, as the legal heirs as well as society office had not received
any kind of notices from your end till date.

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 of any Flat No. 101
as per your statements if at all any flat numbering 101 existed in past taken
from my clients by the bank till date.

7. My clients state that the Flat was purchased by the deceased in the year 1982
and the redevelopment took placed in the year 2019, Since 2019 till date i.e
four years my clients did not receive any notice from your end, neither
received a single letter on the subject mentioned in your notice. So my clients
feel that you’re trying to threat and EXTORT money from my clients in a illegal
way.

8. My clients states that there have been family splits of legal heirs of the
deceased.

9. As per your notice you forcibly demand my clients to pay the loan amount
along with interest on which my clients very strongly demand for a reason for
such an action as to why my clients shall do the same.

10. 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.

11. My clients states that their father who demised in the year 2014 and the
building was redeveloped in the year 2019. So how can you state that the
above mentioned Flat no.101 And Flat no.202 is same?

12. As per paragraph number 10 my clients states that you have been raising
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.
Therefore, I INSTRUCT YOU AS UNDER;
I , therefore, call upon you through this legal notice to issue No Dues certificate
regarding the above said loan account in favour of my said clients and not to raise
any demand of money from my clients, within the period of 15 days from the date
of receipt of this notice , failing to which my clients has given me clear instructions
to file civil , criminal and other Misc. proceedings against you in the court of law and
in that event you shall be fully responsible for all costs, risks and consequences
thereof.

Signature of Clients Advocate

Smt. Neeta Anant Waskar Adv. Seema Gangania

Shri. Avadhoot Anant Waskar

Shri. Prashant Anant Waskar

Mrs. Smita Hemant Nagwekar