To

Mr. A.E. Ravichandran,

Advocate,

New No.294B, Opposite to Dhanalakshmi Bank,

Thambichetty Street,

George Town,

Chennai – 600 001

Sir,

Your notice dated 26.04.2014 issued on behalf of your client Smt. Kalyani Ammal, Wife of Suda
Keerthi Naidu to my client Mr. S. Baskaran is placed in my hands with due instructions to issue the
following reply notice.

At the outset my client denies all the allegations against in your notice as false except those which
are herein admitted.

It is true that your client is mother of my client and his father Suda Keerthi Naidu died on
24.12.2002. It is also further true that your client and my client’s sisters Kamatchi, Sarala,
relinquished their share in the properties containing in their release deed dated 08.03.2004 bearing
document No.1438of 2004 on the file of SRO, on receipt of Rs.50,000/- towards their share and ever
since my client has become absolute owner of the property mentioned in the said Release Deed
exercising his right independently without any interference from any one. It is also worth to
mention that my client’s father during his life time made separate provision for his daughters for her
livelihood. The said Release Deed does not containing any conditions as stated in paragraph 2 of
your notice and the Release Deed is executed on payment of consideration as claimed by them.
However, my client out of love and affection and as a dutiful son maintaining his mother by paying
Rs.4,500/- as a maintenance for the mother. As per her request my client used to deposit every
month in the account maintained by her without any default.

It is my client’s mother requested my client not to deposit the amount in the bank account since she
has become age old and attained for the purpose of withdrawing money she has forced to take the
assistance of her daughters unable to collect the money from them and requested my client not to
deposit the amount instead asked him to pay in hand. In obedience to the said request my client
without any default paying Rs.4,500/- to his mother as on date. Although the amount is not a
charity or gratuitous payment but as a son in order to discharge his responsibility to take care of her
mother is paying this amount besides doing everything to his mother as per her needs. In fact my
client’s mother told my client specifically that her daughters are trying to …. Winger when
withdrawing the money from the bank my client used to deposit. Only to that context my client
started paying money to your client directly by cash. Moreover, he is taking care of his mother in all
respects for which he requires no assistance or commands from any one including his sisters.
According to my client his mother has got no complaints and the instant notice is issued only at the
instance of her daughters in order to create chaos among the families. As stated supra, my client is
not only paying the cash by way of maintenance but also providing food, shelter and cloth besides
taking care of her health too.

My client is having every transaction that the instance notice is issued not at the instruction of her
mother but some one else. Whatever be at this juncture my client reiterates that as a only son he is
duty bound to take care of her mother and he is doing so till now without any hesitation and in
future he will do the same for which he requires no commands. As such the claim made in your
notice is absolutely baseless and as my client paying the amount only to his mother he does not
create any documents. However, since there is an allegation that he is not paying the amount to his
mother, he deposits the maintenance amount at Rs.4,500/- by opening the account in the Bank
situated opposite to her house so as to withdraw the same as and when she requires. Since my
client is taking care of his mother in all respects there occurs no necessity for her to claim an
exorbitant amount as mentioned in your notice and the said demand is made not at the instance of
my mother. At this juncture, you may please advise your client suitably on the lines mentioned in
this reply and despite receipt of the same if your client proposes to initiate any proceedings at the
instance of the 3rd parties your client is doing so at her risk.

It is pertinent to note that my client’s mother Kalyani ammal is residing at Plot No.26, Land Worth
Nagar and not as mentioned in your notice.

My client had already transferred his rights in respect of Item 3 of the property in favour of his wife
and as far as that particular land is concerned, my client’s wife is absolute owner ever since
execution of Settlement Deed.
To

1. Mr. D. Kumar,
2. Mrs. K. Sarala

Both are residing at

No.2/257-C, Gemeni Street,

Chinayampalayam,

Palladam

Coimbatore – 641 062

Sir / Madam,

My client S. Baskaran, Son of K.P. Suda Keerthi Naidu, residing at No.2/26, CTH Road, Veppampattu
Village, Thiruvallur Taluk and District has duly instructed me to issue the following notice:-

My client states that the 1st of you is his Brother-in-law and the 2 nd of you is his Sister. My client
executed the Power of Attorney appointing the first of you as his Power Agent by virtue of the Deed
Power of Attorney dated 14.08.2006 bearing document No.1247 of 2006 on the file of SRO,
empowering the first of you to deal with the property situates at Thiruvallur Taluk and District,
Veppampattu Village comprised in Survey No.425 bearing Plot No.26, Land of Wealth Nagar
measuring an extent of 1558 sq. Ft. The Power of Attorney had been executed by my client
specifically to deal with the property and no consideration was received by my client. The condition
containing in the said deed is that the first of you is liable to settle the account due under the
transaction if any done by you. Ironically the first of you executed a Sale Deed in favour of the
second of you without mentioning the relationship between both of you in respect of the property
comprised in Power of Attorney for a consideration of Rs.1,16,850/-. In the sale deed in Page No.3,
you have specifically stated that the entire sale consideration of Rs.1,16,850/- has been received by
you cash and handed over possession to the 2 nd of you. In the said sale deed does not containing
that you are executing the sale deed in favour of the 2 nd of you as she is your wife. The transaction
has been done as if it is done with the 3 rd parties. What so be although the 1st of you received the
sale consideration of Rs.1,16,850/- from the second of you for execution of sale deed on 11.09.2006
bearing document No.10237 of 2006 on the file of SRO, Thiruvallur. But did not pay the amount to
my client, despite his demands. The first of you being an agent of my client duty bound to pay the
sale consideration received by you from the 2 nd of you in a letter of spirit but purposely with a view
to cheat and defraud my client, both of you did not whisper anything to my client as on date.

In order to away due payment both of you are trying to create problems among my client and his
mother so as to put my client under duress. The first of you and 2 nd of you being Husband and Wife
and had the transaction as if you are 3 rd parties and grab the property unlawfully with my client’s
knowledge and having failed to repay the sale consideration mentioned in the said deed both of you
have committed hurries crimes against my client.

Both of you are hereby demanded to pay Rs.1,16,850/- being the sale consideration received by the
1st of you paid by the 2nd of you to my client together with interest at 24 % per annum from
11.09.2006 onwards. If you fail to adhere the demand made in the notice please note that my client
would initiate necessary proceedings for recovery of said sum besides initiating criminal proceedings
for the mischievous act done by you holding you liable for all such costs and consequences arising
thereof.
All the Piece and Parcel of Vacant House site bearing Plot No.245 MIG, Phase – II ….. in the
sanctioned plan at Nolumbur, measuring an extent of 139.61 Sq. Mtr. Or 1503 Sq. Ft., Comprised in
Survey No.223/1 Part of Nolumbur Village, Ambattur Taluk, Thiruvallur District within the
Registration District of North Chennai and within the Sub Registration District of Konnur, and within
the civic jurisdiction of Chennai Corporation.

From the verification of documents produced before me it is found that originally the schedule
mentioned property was allotted by the Tamil Nadu Housing Board in favour of Mr. S. Ranganathan
in and by a Deed of Sale dated 14.12.1988 and Lease cum sale agreement entered into between
Tamil Nadu Housing Board and S. Ranganathan.

Mr. S. Ranganathan had paid the Lease amount duly obtained Registered Sale Deed from the Tamil
Nadu Housing Board on 06.02.2004 Registered as Document No.689 of 2004 at Sub Registrar Office,
Konnur. Mr. S. Ranganathan who was in possession and enjoyment of the same from the date of
purchase and after obtaining the sale deed in his favour sold the same in favour of Mrs. Clara Joseph
in and by a Deed of Sale dated 13.02.2004 Registered as Document No.691 of 2004 at Sub Registrar
Office, Konnur.

Mrs. Clara Joseph who was in possession and enjoyment of the schedule mentioned property plot in
order to develop the same into residential Flat appointed her Son Mr. Antony Cristoper Joseph as
her Power Agent in and by a Deed of General Power of Attorney dated 02.04.2014 Registered as
Document No.1516 of 2014 at Sub Registrar Office, Konnur.