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4th February, 2023

BY SPEED POST / COURIER AND EMAIL

To,

1. ANP Trade Link LLP

10/A, "VIMAL", Panchayat Nagar,
Street No.2 ,University Road, 
Rajkot - 360005 (Gujarat) INDIA 

2. Ms. Anitaben Vimalbhai Bhut

Designated Partner, ANP Trade Link LLP
10/A, "VIMAL", Panchayat Nagar,
Street No.2 ,University Road, 
Rajkot - 360005 (Gujarat) INDIA 

3. Mr. Amit Hasmukhbhai Rathod

Designated Partner, ANP Trade Link LLP
10/A, "VIMAL", Panchayat Nagar,
Street No.2 ,University Road, 
Rajkot - 360005 (Gujarat) INDIA 

SUB: LEGAL NOTICE FOR RECOVERY OF DUES AND DAMAGES

ON OTHER LEGAL GROUNDS

Dear Sir/Madam,
The above titled Law Firm has been instructed by Qahraman Center GmbH
Allgemeines Handel - Import & Export, having its registered office at
Berghauschensweg 27441468 Neuss / Germany (Referred to as My Client) to
serve upon Legal notice for recovery of dues and damages on other legal
grounds. We thereby serve you this notice with the following effects: -

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in
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1. That you the addressee No. 1 is a registered partnership firm with its
designated partners Ms. Anitaben Vimalbhai Bhut and Mr. Amit
Hasmukhbhai Rathod, addressee No. 2 and 3 respectively with the
registered address of the firm being 10/A, "VIMAL", Panchayat Nagar,
Street No.2 University Road, Rajkot - 360005 (Gujarat) INDIA. The
firm is a manufacturer and exporter of all kinds of products such as
Guar Gum Powder, Bamboo sticks, incense sticks, wide range of
candles with different kinds of Glass Jar and Fancy glasses varieties as
informed by your firm to my clients.

2. That My Client is a company based in Germany involved in iimport and

export of cosmetics, electronics, textiles and motor vehicles as well as
provision of postal services from Germany abroad. My Client has a
great reputation in the German markets in supplying good quality
products which they import from various parts of India and other
Countries.

3. That My Client while searching for a company to import wax candles

from India in the course of business in the year 2021 came in contact
with your firm and after seeing the profile of your firm on the search
engine my client further expressed his interest to have a long-term
basis relation with your firm in order to import wax candles of different
types according to the samples provided by my client. That further in
pursuance of the request of the My Client your firm was introduced by
Mr. Prashant Lashkari, an employee of your firm as a leading
manufacturer and exporter 23 products located at Rajkot (Gujarat,
India). That the said employee of your company also informed by email
to my client that your firm was the leader in exports and the promoters
of your firm had 6 other companies in the similar business. That it is
further stated that when my client expressed his desire to buy wax
candles from your firm and inquired if your firm had the requisite
machinery to meet the demands of my client, it was represented to my

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in
 3
client that your firm being a leader in this business had the requisite
machinery to execute the order of my client and my client believing
upon your representations and assurances decided to go ahead with
this order with your firm.

4. That your firm acting through Mr. Prashant Lashkari represented to My

Client that you addressee was one of the big players in the business of
making wax candles and had the best machinery available in Indian
Market to make wax candles as per the samples provided by my client
and after the initial discussions your firm agreed to provide to My
Client with four qualities of wax candle namely Silver dinner candle at
the rate of 1.45 USD per box for a total 6500 boxes total amounting to
9,425 USD, Golden dinner candle at the rate of 1.45 USD per box for a
total 19500 boxes total amounting to 28,275 USD, White dinner candle
at the rate of 1.20 USD per box for a total 19500 boxes total amounting
to 23,400 USD, Black dinner candle at the rate of 1.20 USD per box
for a total 6500 boxes total amounting to 7,800 USD. It was agreed
between my Client and your firm that the total consignment amount
was 68,900 USD and in lieu of this my client made an advance
payment of dollar 10,000 USD to your firm and the remaining had to be
paid by my client against the proof of shipping the order.

5. That as soon as the deal was finalized between your firm and my
client, you the addressee No. 1 circulated the Performa Invoice to My
Client which was the signed and sealed by way of Performa Invoice
dated 03.07.2021 and my client made a payment of 10,000 USD on
08.07.2021 through wire transfer against the said invoice.

6. That after the advance payment was paid, you the addressee sent
production samples to my client for approval which were very bad in
quality and hence they were not approved by my client. Further you the
addressee without waiting for an approval from my client produced the

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in
 4
samples in bulk which were bad in quality. That further after the
samples were rejected by my client you asked for reference samples
which were provided by my client initially and also later and your firm
assured my client that you would match the samples provided by my
client. That it is further stated in spite of repeated efforts from your side
you could not provide the pre -production sample according to
requirements of my client and further you kept on promising my client
that you would be able to complete the order and needed some time to
match the samples. It is stated that as it was very well known to you
from the beginning that you did not have the required machinery to
execute the order and in spite of this you falsely misrepresented to my
client that you had all the machinery to execute the order and your firm
could not process this order for my client within the time promised.

7. That it is further stated that when by April 2022 that is after a year
when the order was placed, you could not match the specifications
provided by my client, my client being represented through Mr.
Sandeep Rastogi wrote an email to you asking for a cancellation of the
order with reasonable cancellation charges. That further in reply to this
email you wrote to my client that you had invested in raw material dies
in machines of around 35,000 to 37,000 USD to reach the quantity
ordered by my client and therefore you were not in a position to return
the amount as the same was not viable for you. That further in reply to
this email my client acting through Mr. Sandeep Rastogi replied to your
email vide reply email dated 15.04.2021 and made it clear to you that
the required quality of the order could not be attained by your firm and
therefore the consignment was not viable for the company and
therefore the company once again requested you to cancel the order
and return the balance amount after deducting the cancellation charges
according to the established principles of business.

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in
 5
8. That you the addressee now did not provide any update to My Client
and kept silent for a month and then finally wrote an email dated
18.05.2022 to the appointed agent of my client, Mr. Sandeep Rastogi
and informed him that the management of your firm had concluded that
they had decided to deduct USD 8268 from in advance of 10,000 as
cancellation fee and decided to return USD 1732 to my client. That it is
further stated that the agent of my client replied to your email informing
you in strict terms that in the normal course of business 30% is
deducted from the deposit money and therefore the deductions being
offered by you were not acceptable to my client but in spite of this
email and numerous phone calls made to you the addressee no. 2 and
3 , your firm has shown no inclination to follow the rules of business
and therefore my client is now left with no choice then to serve you with
this legal notice

9. That you the addressee No. 1 , 2 and 3 have not only committed
Breach of contract but have cheated my client by misrepresenting to
my client since the beginning that you had the required machinery to
execute the order but have failed to fulfil the order of my client for
more than any year. That you the addressee have breached the
contract and have caused direct and indirect loss to my Client who has
suffered an immense loss due to the non-performance of this order.
This non-performance of the contract by you has also caused loss of
reputation and Goodwill to My Client and his Company. My Client
seeks Rs. 1,50,00,000 for Damages caused to the company directly
and on account of reputation and goodwill that it has suffered in the
international market due to Non-shipment of the import order till date
and non-performance of this contract by you.

10. That you the addressee No 1 have failed to complete the Import order
and also failed to Repay the Advance payment on non-fulfilment of the
import order of USD 10000 Dollar. That till date the Repayment amount

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in
 6
of USD 10,000 has not been paid to my client thereby adding to huge
financial losses with each passing day. This notice is , therefore,
served to you whereby you are called upon to return all the charges
that are an amount of USD 10,000 and damages in the tune of Rs.
1,50,00,000 within fifteen days from the receipt of this legal notice.

NOTE: A copy of this Notice is retained by us in our Office for reference and
record. Needless to add, our client expressly reserves and retains its right to
add/amend/correct/vary/ or modify this notice .

If we fail to hear from you within fifteen days from the date of this notice, we
will have no alternative but to seek appropriate legal resources in order to
recover the amounts for breach of contracts and to enforce our rights under
criminal law and other civil remedies available to us .

Your Sincerely,
FOR SS GLOBAL LAW FIRM

SONIA SAINI
(Managing Partner)

G-4, Shokeen Plaza, Plot-3 Sector-12, Pocket-7, Dwarka New Delhi-110075

Phone: 011-47098554 Email: info@ssglawfirm.in , Website: www.ssglawfirm.in