Mr. Parichay Ashar Advocate.

Email ID- 2807.stkabirnav@gmail.com Chamber : Chamber no. 130 ,

Phone No. – 9016898933 Lawyer’s Chambers, Gujarat
High Court Ahmedabad

Date 12.01.2024
(By Speed Post, E-mail and Whatsapp)
To,
Adv. Nishit Raj,
Advocate and Corporate Consultant of
Tecso Charge Zone Ltd.
Having its office at
B-702, Vrundalaya Greens,
Atladra Padra main road,
Vadodra-390012,
Gujarat, India.
E-Mail- lex.nishitraj@gmail.com

And

Tecso Charge Zone Ltd.

Having its registered office at
401, Benison Complex,
54 Haribhakti Society, OP road,
Vadodra, Gujarat 390007.

Dear Sir,

Re: Legal Notice dt. 07.01.2024 bearing reference no. L01012024 (the “said notice”)
issued by Adv. Nishit Raj, Advocate and Corporate Consultant of Tecso Charge Zone
Ltd. (“you”) to Mr. Darshit Vyas.

Sub: Reply to the said notice cum legal notice being counter claim for non-payment of
outstanding dues of my client by Tecso Charge Zone Ltd.

I am concerned for my client, Mr. Darshit Vyas having its address at B-36, Trisha duplex, harni
road, Vadodra-390022, Gujarat upon whose instructions I am to address you as follows:

________________________________________________________________________________
Address : C/102, Nilgiri Luxurious Apartment, near Sola Civil Hospital, Ahmedabad
 Mr. Parichay Ashar Advocate.

Email ID- 2807.stkabirnav@gmail.com Chamber : Chamber no. 130 ,

Phone No. – 9016898933 Lawyer’s Chambers, Gujarat
High Court Ahmedabad

1. That the said notice came to be received by my client on 08.01.2024.

2. That not having specifically dealt with any particular contents of the said notice shall
not be deemed to have been admitted by my client.
3. That at the outset it is submitted that the contents of the said notice which are
contrary to the contents herein, shall not be deemed to have been admitted by my
client.
4. That at the outset it is submitted that the contents of the said notice which are
contrary to the contents herein are denied by my client.
5. That the said notice alleging breach of the non-compete clause i.e. clause no. 18 of the
appointment letter received by my client from Tecso Charge Zone Ltd. is bad in law as
it is a trite position of law that such non-compete clause which restraints anyone from
lawful profession, trade or business are void and not enforceable.
6. That I shall now deal with the notice paragraph wise.
7. That with regard to paragraph 1 and 2, no reply is required at this stage however we
reserve our right to deal with the same.
8. That with regard to paragraph no. 3, no comments are offered at this stage.
9. That with regard to paragraphs no. 4 to 9, the contents therein are specifically denied
in toto.
10. That with regard to paragraph no. 10, my client is not liable to pay any sum of money
to Tecso Charge Zone Ltd. as there has been no breach of clause 18 of the letter of
appointment as alleged by you. Further it is a trite position of law that non-compete
clause which restraints anyone from lawful profession, trade or business are void and
not enforceable.
11. That with regard to paragraph no. 11, my client is legally not liable to pay any sum of
money whatsoever to Tecso Charge Zone Ltd.
12. That only with a view to harass my client and to not clear the full and final payment of
Rs. 41,378/- which has been duly acknowledged by Tecso Charge Zone Ltd.in its final
calculation dt. 05.09.2023 bearing reference no. TCZ/FC/2023/008 such kind of
mischievous and cheap tactics are being played by Tecso Charge Zone Ltd. which
otherwise has very good potential to become a big and successful company and such
kind of cheap tactics affects the goodwill of the company. That at this juncture when
Tecso Charge Zone Ltd. is in process of launching its Initial Public Offering (“IPO”), such
kind of cheap tactics shall be avoided and Tecso Charge Zone Ltd. shall consider
________________________________________________________________________________
Address : C/102, Nilgiri Luxurious Apartment, near Sola Civil Hospital, Ahmedabad
 Mr. Parichay Ashar Advocate.

Email ID- 2807.stkabirnav@gmail.com Chamber : Chamber no. 130 ,

Phone No. – 9016898933 Lawyer’s Chambers, Gujarat
High Court Ahmedabad

whether person advising them to engage in such cheap tactics is actually thinking
about the goodwill of the company or is thinking about settling scores with my client
by engaging in such ego battles.
13. It is an undisputed position of fact that my client is entitled to full and final payment of
Rs. 41,378/- which has been duly acknowledged by Tecso Charge Zone Ltd. and still
after numerous requests by my client to authorized persons of Tecso Charge Zone Ltd.
these dues have still not been cleared.
14. It was in the above factual scenario and non-cooperation from Tecso Charge Zone Ltd.
for clearing the abovementioned dues, my client was forced to intimate the ld. Labour
Officers of Vadodra about the non -payment of the abovementioned dues by Tecso
Charge Zone Ltd.
15. That it is an undisputed position of fact that it was only after my client intimated the ld.
Labour Officers of Vadodra vide e-mail dt. 07.11.2023 about non- payment of the dues
of Rs. 41,378/- by Tecso Charge Zone Ltd, you with an intention to harass my client
have sent the said notice. That the said notice is clearly an afterthought.
16. That my client vide this notice hereby demands that full and final payment of Rs.
41,378/- which has been duly acknowledged by Tecso Charge Zone Ltd.in its final
calculation dt. 05.09.2023 bearing reference no. TCZ/FC/2023/008 with an interest of
18% p.a. from the date of acknowledgment of such dues till the actual payment of
these dues within 7 days of receipt of this notice failing which my client will be forced
to take appropriate legal actions at your peril and cost. That further my client vide this
notice demands Rs. 15,000 as compensation for causing mental agony and Rs. 15,000
being legal expense for this reply cum legal notice.
17. That the present reply cum legal notice is issued without prejudice to the rights of my
client.

________________
Adv. Parichay Ashar

________________________________________________________________________________
Address : C/102, Nilgiri Luxurious Apartment, near Sola Civil Hospital, Ahmedabad