Pankaj Vs Sandeep Legal Notice Specific Performance From Buyer

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Regd. A.D./ Courier

LEGAL NOTICE
To,
Sandeep S/o Sh. Satyanarain S/o Sh. Dhula,
resident of village Sandal Khurd, Tehsil
and District Sonepat.

Sir,
Under the instructions from and on behalf
of my client; Pankaj Kumar son of Sh. Ved
Parkash son of Sh. Chander Singh, resident
of village Sandal Khurd, Tehsil and
District Sonepat, I have the honour to
serve you with the following legal
notice:-
1. That you noticee being owner in possession
of the land measuring 04 Kanal 14 Marle to
the extent of your 922409/11299400 share
out of total land measuring 57 Kanal 13
Marla, the land comprised in Khewat
No.48//46//1, Khatoni No.67, in Rect. &
Killa No.19//1(2-12), 2(5-11), 3(7-4),
4/1(4-7), 8/1(2-0); 26//8/3(2-7), 9/1(1-
17), 12(9-13), 13(7-12), 14(8-0), 27(0-
9),; 27//18/1/2(6-1), situated in the
revenue estate of village Sandal Khurd,
Tehsil and District Sonepat entered into
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an Agreement to sell with my client on


17.03.2022 to sell your land as details
mentioned above at the rate of Rs.25 lakhs
per acre and you have received
Rs.1,33,000/- as an earnest money in cash
on the same day. An agreement to sell was
reduced in writing in the presence of
witnesses thereof and after understanding
the contents of the agreement you put your
thumb impression over the agreement to
sell dated 17.03.2022. You had also
executed the separate cash receipt for an
amount of Rs.1,33,000/- in the presence of
witnesses thereof in favour of my client
in respect to sale your above-mentioned
land.
4. That as per the terms and conditions of
Agreement to sell the date for execution
and registration of the sale deed was
fixed for 16.02.2023 and you were bound to
execute and register the sale deed of the
above-mentioned land in favour of my said
client up to 16.02.2023 after clearing all
the dues loan etc. regarding your land
mentioned above.
5. That on 21.10.2022, you approached my
client and requested him to pay
Rs.20,000/- on the pretext that you are
dire need of money with the purpose to
clear the loan of the land in question. On
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your genuine request, my client paid


Rs.20,000/- to you in cash and a receipt
was also executed by you in favour of my
client by affixing stamp over it.
6. That after 15 days, my client asked you
about the clearance of loan of your land,
then you noticee told my client that you
could not arrange sufficient amount to
clear the loan and avoid the same on one
pretext or other.

my client reached at the office of Sub


Registrar, Kharkhoda alongwith the balance
sale consideration and expenses of stamp
papers and registration charges etc. My
client waited you at the office of Sub
Registrar, Kharkhoda, District sonepat
whole the working hours but you did not
turn up to execute and register the sale
deed of the above mentioned land in favour
of my said client.
6. That since then my client has made several
requests to you notice and offered you the
balance sale consideration and also
requested you notice to execute and
register the sale deed of the above
mentioned land in favour of my client, but
you are avoiding of legitimate requests of
my client on one pretext or the other.
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8. That now it seems that you have become


dishonest and you notice do not want to
execute and registered the sale deed in
favour of my client intentionally and
deliberately and wants to grab the money
of my client, which was received by you
noticee as earnest money. However, since
very beginning my client was ready and is
still ready and willing to perform his
part of the agreement as he was/is having
sufficient funds for performing his part
of the contract of payment of balance sale
consideration. My client tried to contact
you notice for fixing the date for
execution of the sale deed, but you notice
did not show any interest in this regard.
Hence, through this legal notice, you
are hereby called upon you the Noticee to
receive the balance sale consideration
from my above said client and get the sale
Deed of the above mentioned land executed
and registered in favour of my said client
within the period of 30 days from the date
of receipt of this Legal Notice, failing
which I have clear instructions from my
above said client to file civil, criminal
complaint, suit for specific performance
of contract and other Misc. proceedings
against you in the competent court of law
and in that event you shall be fully
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responsible for all costs, risks and


responsibilities which you note well.

NOTE: A copy of this notice has been


preserved in my office for record and
future course of action

Vijay Rana,
Advocate, Sonepat

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