MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

Cell No.0335-1199917/0345-1199917
Email Address: advocatemirnohri@gmail.com
Office Address. Office No.32, District Council Building Near Gul Center, Hyderabad.

Ref:MMN/142/2023 Dated:24-10-2023

To,

Operation Manager
of Muslim Commercial
Bank Limited (MCB)
Nasim Nagar Branch
Hyderabad, Sindh, Pakistan
On behalf of,

Zeeshan Khaskhely
S/o Kareem Khaskhely
R/o Naseem Nagar Chowk
Hyderabad, Sindh, Pakistan

LEGAL NOTICE

WITHOUT PREJUDICE, I am to serve you this Legal Notice on the following grounds,

as under:-

1. That, the undersigned is a peace loving and law abiding citizen of Pakistan

having been guaranteed with certain fundamental rights as guaranteed under

the Constitution of Islamic Republic of Pakistan, 1973.

2. That, My Client is a software engineer, having good moral values and respect

in the eyes of the locality.

3. That this legal notice is sent to you to let you know that My Client is quite

displeased with your actions against My Client on the date of October 19,

2023, at the MUSLIM COMMERCIAL BANK LIMITED (MCB) Nasim Nagar

Branch.

4. That My Client has a bank account in MUSLIM COMMERCIAL BANK LIMITED

(MCB), which he uses for purposes that are personal as well as professional.

5. That on dated: 01-01-2023, My Client made an online application through the

official website of MUSLIM COMMERCIAL BANK LIMITED (MCB) for the

|PAGE 1 OF 5|
 MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

Cell No.0335-1199917/0345-1199917
Email Address: advocatemirnohri@gmail.com
Office Address. Office No.32, District Council Building Near Gul Center, Hyderabad.

Ref:MMN/142/2023 Dated:24-10-2023

issuance of a cheque book with the sum amount charges for it and the reason

for this application was to enable My Client to make payments to his suppliers

and contractors in accordance with the terms and conditions of their

respective contracts.

6. That on the dated: 01-01-2023, My Client was contacted by a representative of

bank via telephone and the said representative informed My Client that his

cheque book had been ready for collection at MUSLIM COMMERCIAL BANK

LIMITED (MCB) Nasim Nagar Branch and the said representative also

requested My Client to kindly visit the branch and collect his cheque book

from you.

7. That at the relevant time, My Client was not present in the city as he had to

travel to another location for his serious personal works, Therefore, My Client

duly communicated this fact to the representative of your bank who had

contacted My Client earlier and requested My Client to collect his cheque book

and My Client also informed the said representative that he would be able to

collect his cheque book only after a period of 40 to 50 days from the date of

the telephone call.

8. That after a period of approximately 40 to 50 from the date of issuance of the

cheque book by your bank, My Client visited you on the 19th day of October,

2023 in bank, with the intention of collecting his cheque book from your

custody.

9. That when My Client arrived at your bank on the aforementioned date, You in

the front of My Client wilfully and unlawfully disposed of his cheque book on

the grounds of his alleged delay in collecting the cheque book from your bank.

|PAGE 2 OF 5|
 MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

Cell No.0335-1199917/0345-1199917
Email Address: advocatemirnohri@gmail.com
Office Address. Office No.32, District Council Building Near Gul Center, Hyderabad.

Ref:MMN/142/2023 Dated:24-10-2023

10. That you also acted in a highly unprofessional and disrespectful manner

towards My Client when he visited your bank to collect his cheque book and

instead of providing cheque book to My Client you disposed of his cheque book

and also used abusive and derogatory language against My Client in a loud

voice, causing My Client humiliation and embarrassment in front of all the

other customers and staff members who were present at the bank premises at

that time and you also threatened My Client with physical violence, Therefore

it is worth mentioning that this kind of act from you towards My Client is clear

cut violation of the principles of good customer service and breached the

terms and conditions of the banking contract between you and My Client.

11. That your actions constitute a flagrant violation of the law and amount to

several civil and criminal wrongs. You have breached the contract that you

entered into with My Client when he opened an account with your bank and

applied for a cheque book. You have also defamed My Client by making false

and malicious oral statements about My Client in public, thereby injuring his

reputation and dignity. You have also threatened to use physical force against

My Client, thereby causing My Client bodily harm and mental distress. You

have also violated the human rights of My Client by depriving My Client of his

liberty, security, and dignity, as guaranteed by the Constitution of Pakistan and

the Universal Declaration of Human Rights. Your actions are not only unlawful

but also immoral and unethical. They reflect your disregard for the principles

of justice, fairness, and good faith that govern the banking sector and the

society at large.

|PAGE 3 OF 5|
 MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

Cell No.0335-1199917/0345-1199917
Email Address: advocatemirnohri@gmail.com
Office Address. Office No.32, District Council Building Near Gul Center, Hyderabad.

Ref:MMN/142/2023 Dated:24-10-2023

12. That you also engaged in the unlawful and malicious acts of blackmail and

extortion against my client by threatening him that you had acquired a cheque

from his cheque book and that you would file a false First Information Report

(FIR) against My Client on the ground of that cheque. You thereby attempted

to force My Client into paying you an exorbitant amount of money or else face

legal consequences for dishonouring of cheque, You also made false and

baseless claims that you had proof to show that My Client had issued the

cheque fraudulently and that My Client had no arrangements with his bank to

ensure that the cheque would be honoured. You thereby created false evidence

and levelled false accusations against my client with the intention to harm him,

which are punishable offences in Pakistan under sections 193 and 211 of the

Pakistan Penal Code 1860. Your actions are not only illegal but also immoral

and unethical. They reflect your bad faith and hidden agenda to cheat and

torment My Client.

13. That due to your unlawful and malicious acts, My Client has suffered mental

agony, loss of reputation, physical harm, and financial loss.

14. That, you have committed illegal and unlawful act for which you are at liberty

to initiate legal proceedings against you as according to law.

I hereby call upon you to do the following within 15-Days from the date of receipt of this

notice:

a) To apologize to My Client in writing for your misconduct and mistreatment.

b) To pay My Client a sum of Rs. 10,00,000/- (Rupees Ten Lakh Only) as

compensation for the damages caused to My Client.

c) To issue a fresh cheque book to My Client without any delay or charges.

|PAGE 4 OF 5|
 MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

Cell No.0335-1199917/0345-1199917
Email Address: advocatemirnohri@gmail.com
Office Address. Office No.32, District Council Building Near Gul Center, Hyderabad.

Ref:MMN/142/2023 Dated:24-10-2023

If you fail to comply with the above demands within the stipulated time, My Client will be

constrained to initiate appropriate legal action against you in the court of law.

NOTE: A copy of this notice is retained in my office for record and further action.

Please Take Notice.

MIR MUHAMMAD NOHRI

ADVOCATE HIGH COURT OF SINDH

|PAGE 5 OF 5|