KETAN KUMAR & ASSOCIATES

Advocates & Legal Consultants

Phone: 8384006676; 8285404894 Email: ketankumaradvocate@gmail.com
Law Firm: A-596, Gali No. 17, Mahavir Enclave, Part-2, Dabri Dwarka Road, Delhi-110059
Reference No. LN/ 20240627/01 Date: 27.06.2024

SPEEDPOST/ WHATSAPP/ EMAIL

To,
MR. NARENDER SOLANKI,
S/O LATE SH. RAM CHAND,
R/O HOUSE NO. 145, MATIALA VILLAGE,
UTTAM NAGAR, NEW DELHI - 110059
MOBILE: 9971074646

ALSO, AT:
RZ – 13, JAIN PARK, MATIALA ROAD,
MATIALA VILLAGE, UTTAM NAGAR,
NEW DELHI – 110059

LEGAL NOTICE
Dear Sir,
I have been instructed on behalf of my client namely
Sh. Rahul Kumar S/o Late Sh. Devinder Kumar, R/o House No.
898, J.J. Colony, Pankha Road, Uttam Nagar, New Delhi - 110059,
to serve you with the legal notice as under: -

1. That you are the owner of godown located at plot no. RZ –

13, Jain Park, Matiala Road, Matiala Village, Uttam Nagar,
New Delhi – 110059, which was taken on rent by my client
at Rs. 11,000/- (Rupees Eleven Thousand only) per month.

2. That my client was diligently and regularly making payment

of rent to you every month without fail. However, during
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 KETAN KUMAR & ASSOCIATES
Advocates & Legal Consultants
Phone: 8384006676; 8285404894 Email: ketankumaradvocate@gmail.com
Law Firm: A-596, Gali No. 17, Mahavir Enclave, Part-2, Dabri Dwarka Road, Delhi-110059
corona pandemic and lockdown i.e., in the year 2020 – 21,
my client was out of work due to which he failed to make
payment for few months, and he had an outstanding rent
payment of Rs. 1,00,000/- (Rupees One Lakh only) but as
soon as corona pandemic period was over my client again
started making timely payment to you.

3. That on 13.05.2024 you demanded full payment of

Rs. 1,00,000/- (Rupees One Lakh only) at once from my
client, after which my client told you that he can pay you the
payment in monthly instalments of Rs. 5,000/- to 10,000/-, to
which you agreed, and you asked my client to execute an
affidavit affirming the same, which was also countersigned
by you.

4. That on 17.05.2024 my client made a payment of

Rs. 15,000/- (Rupees Fifteen Thousand only) to you, after
which you reached the godown where my client’s employees
were working but my client was not present there and you
ousted my client’s employees and locked the godown and
kept the keys.

5. That my client immediately approached you and sought time

to clear the payment, but you did not pay any attention to my
client request and after two days you also disconnected
electricity connection of the godown.

6. That my client had furniture, raw material, appliances/

machinery, electronic items and computer worth over
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 KETAN KUMAR & ASSOCIATES
Advocates & Legal Consultants
Phone: 8384006676; 8285404894 Email: ketankumaradvocate@gmail.com
Law Firm: A-596, Gali No. 17, Mahavir Enclave, Part-2, Dabri Dwarka Road, Delhi-110059
Rs. 10,00,000/- (Rupees Ten Lakh only) at the time when
you locked the premises.

7. The items as mentioned in the list below were lying at the

godown when it was locked by you, and you will be held
responsible for any loss or damage to the items. That
following items were present at the godown when it was
locked by you:

S.No. Particular Quantity

1. Screen Printing Machine 1
2. Iron Rack 5
3. Aluminium frames (28x35 inch) 100
4. Doom Almirah 1
5. Monitor+ Keyboard + Mouse + CPU 1
6. Medium Size office table 2
7. Computerized Plotter Machine 1
8. Large Size workshop table 2
9. Wall mounted cabinets affixed in walls 4
10. Office chair 1
11. Standard chairs 4
12. Wooden office tables 4
13. CCTV Camera along with DVR 8
14. Monitor for CCTV Camera 1
15. Raw Material Rs. 3 Lakh

8. That my client requested you several times to permit him to

take out his items kept in godown, and he also promised you
that he will make full payment to you after selling some of
the items, but you did not pay any attention to my client’s
requests.

9. That you have unlawfully locked the belongings of my client

at the godown and my client can file a complaint against you
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 KETAN KUMAR & ASSOCIATES
Advocates & Legal Consultants
Phone: 8384006676; 8285404894 Email: ketankumaradvocate@gmail.com
Law Firm: A-596, Gali No. 17, Mahavir Enclave, Part-2, Dabri Dwarka Road, Delhi-110059
to recover the possession his items as per the list mentioned
above.

10.That you have illegally dispossessed my client from the

possession of the godown without giving any prior notice
and without following due process of law and my client
reserves right to reclaim the possession of the godown.

I, therefore, call upon you, through this legal notice to

handover the peaceful possession of abovesaid godown to my
client alongwith all the items as per the list mentioned above within
7 days from the date of the receipt of the legal notice, failing which
my client has given me clear instructions to start proceedings
against you in court of law, civil as well as criminal, and same
shall be done entirely at your cost, risks and consequences, which
you please note.

Cost of this legal notice i.e., Rs. 5,000/- (Rupees Five

Thousand only) will be put to your account.

Copy of this Legal Notice is retained in my office for future

purposes.

New Delhi KETAN KUMAR

Dated: 27.06.2024 (ADVOCATE)

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