REPLY TO THE LEGAL NOTICE

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March 19, 2024

Cheque Bounce
March 19, 20240 By Avinash Nandan Sharma

AVINASH NANDAN SHARMA Office: CHAMBER NO.671

Advocate Patiala House Court

En.No. (XYZ) NewDelhi- 1

LL.B. Law Faculty, DU Mob: , XXX

M.A.(Political Science) DU

PG Diploma in Journalism

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Email:advocateavinashsharma@gmai.com

REGISTERED A.D.

To,

Mrs. X

Wife of Late Mr. K

R/o. XX, Janakpuri,

New Delhi

THROUGH

AB, Advocate

Ch. No. 00, Dwarka Courts,

Dwarka, New Delhi

REPLY TO THE LEGAL NOTICE

Dear Sir,

Under instructions and authority from my client Mr. R, Son of Sh.H R/o. H.No.00,
Nagar,Part-0, New Delhi , I serve upon you the following Reply to your Legal Notice :-

1. That you have been misguided by your client and material facts with respect to the deal
between Late Sh. K, and H, R have been concealed from you by your client as K
entered into an agreement with H , the allotee of the flat No. 000, Third Floor, at
Loknayakpuram, New Delhi and my client was just playing the role of a mediator in this
matter.

2. That later on the husband of your client assured my client that when he gets physical
possession of said flat after clearing the disposal cost of Rs.10,55,479 /- with DDA as
this was a Good Will Flat, he would sell it to my client. On his assurance my client had
given to the husband of your client a post dated cheque no.509963 of Rs.1,50,000/- (
One Lac fifty Thousand Rupees only) dt 16.09.2010 as your client had to deposit the
amount of Rs, 10,55,479/- with Delhi Development Authority, Vikass Sadan, Behind,
INA Market,New Delhi-23 on 11.09.2010 as last date.

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 3. That since your client did not deposit the above said disposal cost of the flat with the
DDA by 11.09.2022, the allotment got cancelled. As my client came to know the fact of
non- deposit of the said payment with DDA by you and the cancellation of the
allotment, he was not liable to pay the security cheque given to your client on condition.
That the deal between you and H also failed because of the fault of the non-
performance of above said deposit by the husband of your client.
4. That my client many times requested your client and her husband to return the said
cheque through telephone in the month of September, 2022 but they did not pay any
attention to it. When my client personally went to the house of your client and contacted
her husband on 23.09.2022 , he told that he had destroyed the said cheque and this
matter had come to its end. On his assurance my client came back from there.

5. That the husband of your client was well aware of his faults of non-deposit of the said
DDA amount and that is why he remained silent for last three year. Now after the death
of her husband, your client is dishonestly raising a issue that is time barred as per law.
Your client is trying to get the benefit of her own wrongs by fraudulently using a security
cheque given by me after the laps of three years. Had she been so genuine , she
should have filed a case of dishonor of cheque or a recovery suit at that time only.
6. It is pertinent to mention here that there was a friendly relation between my client and
the husband of your client and as such K had received total amount of 25,000/- as
friendly loan from my client on 28.01.2023, 06.08.2023 & 30.08.2023 giving a paper in
writing duly signed by him which your client is legally bound to pay back to my client
with interest as legal heir and he is legally entitled to file a civil suit in the competent
court of law. Even at the time of receiving of this amount and signing of acceptance
paper , the husband of your client did not raise the issue of making any payment to
him by my client with respect to the said cheque.
7. That whenever my client demanded his said loan money of Rs. 25 thousand, your
client and her husband abused my client and threatened to implicate him falsely in a
criminal and civil case. They many times came to my client’s house and created a
negative picture. However , the relation between the husbad of your client and my
client remained normal but after the death of her husband your client is taking out
personal irritation and anger against my client by sending the legal notice through you
and misusing the legal process.

8. That the above facts in reply to your legal notice make it abundantly clear that your
client has wrongly and fraudulently raised a issue which is without a cause of action
and also time barred as per law and as such she is trying to pursue the illegal design
and plan to oppress my client.

In case of any legal disputes, I have definite instructions from my client to take necessary
actions against you in the competent Civil & Criminal Courts of law and in that event , you
shall be liable for all the costs and consequences resulting therefrom.

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Copy retained for further legal actions.

Yours faithfully

New Delhi

Date: 16 .03.2O24

(Avinash Nandan Sharma)

Advocate

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