Adv.

Shilpa Saini Rawal

(B.S.LL.B, LL.M, D.C.C.L, D.I.C.I, M.S.W.C)
Contact: +91 9028322334
Mail id: info@advocateshilpa.com
Office Add: Apex Hospital Building, Beside Mauli
Pathology Laboratory, Kalewadi Phata, Thergaon
Pune -411033.

To,
• Samkit Pharma Biotech,
Ashok Nagar,
Nipani -591237.

• Shri B.R. Yadav Advocate

R/o Behind Bus Stand,
R.K Colony Chikodi,
Tal-Chikodi, Dist-Belgaum,
Chikodi -591201.

(SUB: REPLY TO YOUR LEGAL NOTICE DATED 16.11.2023).

Sir,
That this reply to your legal notice dated on 16.11.2023 has
been placed before me by my client Shri Ravindra Barku Pawar
residing at, Shop No C 1, Ground Floor, Prestigious Classic,
Pune, Milakat No.01859, Pune–Mumbai road, Chinchwad
Station, Chinchwad, Pune, Pin No- 411019, and I undersign and
I have been instructed to reply to your said notice by my client on
his behalf as under:
• That , at the outset you send the notice, you have sent on
behalf of your above said client, contains false facts and
information provided by your said client, about false claim
demand from my client on the basis of false account’s detail’s
and information. There is no claim amount as per the detail’s
given by your client.
• That, in fact, my client Ravindra Barku Pawar gave a Cheque
to your client on 01/12/2021. Cheque No.000003 from my
client’s Account No.50200058631244 with HDFC Bank
 Branch, Nigdi Pune.
• That, in Fact my client returned, extra stock amount adjusted
on 01/12/2021 and returned to ‘Windberry Life Sciences &
Research Pvt. Ltd, Kolhapur, Medical Representative Mr.
Kulkarni the DEBIT NOTE amount Rs. 63,283 only paid.
• That, my client returned ‘EXPIRED STOCK’(GOODS),of
amount Rs. 24500 only, but still the payment of the returned
expired stock(goods) pending from your client and the
pending payment has to be cleared by your client till date.
• Medical Representative of ‘Windberry Life Sciences &Research
Pvt. Ltd. Kolhapur, Mr. Kulkarni has also not paid amount of
Rs. 11000 by Party No.01 Samkit Pharma Biotech, Ashok
Nagar, Nipani till date.
• That after settlement by Mr. Kulkarni A ‘CHEQUE STOP
INSTRUCT’ was proceeded and Party No.01 was instructed not
to deposit cheque as the amount was settled but Party No.01
is still in due of amount which is still not cleared by Party
No.01 to my client.
• That, however, your client has cheated my client by misusing
that cheque even after settlement. As a matter of fact, your
client has committed fraud in the matter and, consequently, is
liable to be proceeded under the relevant provisions of law.
• That, therefore, it is denied that the cheque in question was
issued by my client to your client in discharge of any liability.
Rather, your client has misused that blank cheque with
ulterior motives, after forging the same.
Adv.Shilpa Saini Rawal
(B.S.LL.B, LL.M, D.C.C.L, D.I.C.I, M.S.W.C)
Contact: +91 9028322334
Mail id: info@advocateshilpa.com
Office Add: Apex Hospital Building, Beside Mauli
Pathology Laboratory, Kalewadi Phata, Thergaon
Pune -411033.

However, it is denied that my client committed any offence

whatsoever.

In view of aforesaid facts and circumstances Party No.02 is

being advised to further advice to Party No.01 to withdraw the
said notice under reply and further advise him not to drag my
client in any frivolous litigation, failing which my client shall be
constrained to contest the same, besides proceeding against your
client under the relevant provisions of law, at the costs, risks and
consequences of your client only. Copy kept for future record and
reference.

PUNE (Shilpa Saini Raval)

DATE Advocate, Pune