OFFICE/CHAMBER OF THE M.

R QURESHI ADVOCATE AND ASSOCIATES

Ref : HRQ/1/2023 Date : 03/06/2023

To
Mr. Mohd Ehtesham s/o Late Mohd Mohtashim,
Research Scholar, Department of Chemistry,
Jamia Millia University, Delhi. 110025
cell no. : 8882039381
Email : mohdehtesham200@gmail.com

Subject : Legal Notice

Dear sir, upon the instructions of my client namely Ms. Kulsoom Koser D/o Bahadur Ali
Research Scholar Department of Chemistry Jamia Millia Islamia University Delhi, this legal
notice is hereby served upon you as under:

1: That my client named above is a female research scholar doing PhD in chemistry in the
Department of Chemistry, Jamia Millia Islamia University, New Delhi is belonging to a very
reputed family hailing from Tehsil Budhal District Rajouri Jammu and Kashmir, as her
younger sister is also doing PhD in physics her father is serving in the education department,
whole of the family is a very reputed in the eyes of general public.

2: Ms. Kulsoom Koser is a well known hard working and very popular research scholar doing
PhD in chemistry with a view to tarnish her image and reputation you have deliberately and
maliciously filed an peshbandi application duly signed by your good self and got registered and
submitted on 07|10|2022 and got registered in the police station Jamia Nagar Okhla New
Delhi wherein you have maliciously stated against my client the verbatim is reproduced as
under:

“we worked together in the said lab since we had joined. The said Kulsoom is senior to the
applicant and as such she has forcibly and by misplacing the facts develop friendly relation
with the applicant for the last one year the said Kulsoom is one way or the other continuously
torturing and harassing the applicant and causing financial loss. When the applicant came to
know that the said Kulsoom having illicit relations to others then the applicant not only raised
the objections but also keep the distance from her which could not be tolerated by her
consequently the said matter was referred by me to the grievance committee of the department
of chemistry Jamia Millia Islamia university and matter has also reached to the police station
Jamia nagar “

The above said your statement is not only maliciously made but it appears to be a well
designed intentionally submitted and got registered in the police station without any basis just
to maliciously ruin the reputation and tarnish the image and character assassination
deliberately and intentionally done by your good self with the sole objective of maligning her
reputation in the eyes of the students as well as general public at large, your deliberate attempt
has been taken by my client as a serious note of it and considered it to be highly offensive and
defamatory. Such deliberate imputation which are available as a public document in the record
of police station Jamia Millia has immensely harm the reputation of the said research scholar
Miss Kulsoom Kausar,

That on the complaint of said Kulsoom Koser, FIR No.134 was got registered against you
under section 376/506 IPC in the police station Badarpur on dated 04/04/2023 and during
investigation you have attempted to harm and pressurised her for withdrawal of the complaint/
FIR lodged against you for which again the two FIR’s were lodged against you , when she has
applied and obtained certified copies of the FIR’s and other documents on 31/05/2023, she
came to know about the above your malicious imputations made by you in writing in your
application of dated 07/10/2022. which prima-facie shows that you have attempted to tarnish
the image and character of the said Kulsoom Koser deliberately and intentionally without any
basis.

A: Immediately withdraw the above said malicious and defamatory statement from the record
of police station Jamia Millia Okhla New Delhi

B: Submit an unconditional written apology to my client duly signed by your good self

The needful is required to be done within the 10 days from the date of the receipt of this notice
failing which my client shall be constrained to initiate appropriate legal remedies both civil and
criminal at entirely your cost and consequences

Copy of this notice is here by sent through register post in your address as well as will be sent
to your WhatsApp no. as well as on your email after retaining the same in our office chamber
for further necessary action under law.

M/S M.R Qureshi Advocate and Associates

High Court of Jammu and Kashmir and Ladakh

H.R.Qureshi
Advocate
Cell no : 8825001284
Email : haroonrashid242@gmail.com