KARTIKEYA MUDGIL

Advocate & Solicitor

Ch.: 295 B, Old Lawyers Chamber Block, Delhi High Court, Sher Shah Road, New Delhi – 110503
Off: T-307, 3rd Floor, Arjun Plaza, Plot No. 7, Sector 5, Dwarka, New Delhi – 110075

WHATSAPP
Dated: 06.06.2023

To,
SH. DEEPAK KALRA,
S/o Sh. Gulshan Kalra
R/o 2482, 2nd Floor, Greenfield Colony,
Faridabad, Haryana 121010
Mob. 9810600800
e-mail: Deepak.kalraa@gmail.com

LEGAL NOTICE

Sir,

For and on behalf of my client namely Mrs. Shweta Kalra, W/o Sh. Deepak Kalra,
R/o 2482, 2nd Floor, Greenfield Colony, Faridabad, Haryana, 121010, presently at
1203, Barberry Tower, Omaxe The Forest Spa, Sector 43, Faridabad, Haryana
121010 (hereinafter referred to as “my client”) and under authority and instructions,
I serve upon you with the following notice, the contents of which are set forth herein
below:

1. That the marriage between you, the noticee and my client was solemnized
according to Hindu rites and customs in the presence of friends and family
members of both the parties on 05.10.2009.

Mob.: +91 9971885087

e-mail: adv.kartikeyamudgil@gmail.com
 KARTIKEYA MUDGIL
Advocate & Solicitor
Ch.: 295 B, Old Lawyers Chamber Block, Delhi High Court, Sher Shah Road, New Delhi – 110503
Off: T-307, 3rd Floor, Arjun Plaza, Plot No. 7, Sector 5, Dwarka, New Delhi – 110075

2. That you, the noticee and my client lived cohabited with each other as
lawfully wedded husband and wife at the matrimonial house bearing no.
2482, 2nd Floor, Greenfield Colony, Faridabad, Haryana 121010. Out of the
said union, two children namely Arnav Kalra and Aadya Kalra were born on
15.01.2011 and 24.06.2015 respectively.

3. That you, the noticee, during the course of the said marriage, have blatantly
neglected all the responsibilities arising out of the said marriage. It is stated
that you have never tried to fulfil any obligations of the shared household and
have caused mental agony towards my client.

4. That my client has incessantly fulfilled her matrimonial and maternal

obligations and has always shown love and affection towards you, the noticee
but the same has been done in vain as you, the noticee, have failed to express
any concern or affection towards my client.

5. That my client has at many instances, tried to contact you and has begged you
to amicably settle your differences in order to save the said marriage but you,
the noticee have never paid any heed to her requests.

6. That due to such indifferent demeanor towards my client and her children by
you, the noticee, my client has been made to leave the matrimonial house on
many occasions. It is germane to state that owing to such toxic antics by you,

Mob.: +91 9971885087

e-mail: adv.kartikeyamudgil@gmail.com
 KARTIKEYA MUDGIL
Advocate & Solicitor
Ch.: 295 B, Old Lawyers Chamber Block, Delhi High Court, Sher Shah Road, New Delhi – 110503
Off: T-307, 3rd Floor, Arjun Plaza, Plot No. 7, Sector 5, Dwarka, New Delhi – 110075

the noticee, my client was made to leave the matrimonial house on 29.03.2023
along with her daughter namely Aadya Kalra.

7. That my client, being left with no alternatives, had to move in temporarily to

her brother’s house in Faridabad. It is pertinent to state that my client’s
employment, owing to the needs and welfare of you, the noticee and her
children, since the date of marriage, has never been stable. It is further stated
that my client lacks the financial capacity to maintain herself and her daughter
and she is wholly dependent on her brother’s income for subsistence.

8. That the daughter of my client is at a nascent age and my client lacks the
appropriate resources to maintain the standard of living of herself and her
daughter. It is pertinent to mention that my client and her daughter deserve
the right to maintain a standard of living at par with you, the noticee.

9. That you, the noticee, have been intimated many times about the needs of my
client and her daughter but are yet to pay any heeds to such contentions. That
from your above stated conduct, it is evident on your part that with malafide
intention and ulterior motive you, the noticee, are not willing to resume the
responsibilities of being a husband and a father.

10.That from this notice you, the noticee, are hereby requested to pay monthly
maintenance amount to my client. It is stated that the said maintenance amount
will be reasonably calculated and negotiated as per your income and the needs
of my client and her daughter upon your valid representation to my client

Mob.: +91 9971885087

e-mail: adv.kartikeyamudgil@gmail.com
 KARTIKEYA MUDGIL
Advocate & Solicitor
Ch.: 295 B, Old Lawyers Chamber Block, Delhi High Court, Sher Shah Road, New Delhi – 110503
Off: T-307, 3rd Floor, Arjun Plaza, Plot No. 7, Sector 5, Dwarka, New Delhi – 110075

within 7 days of receipt of this notice, else my client is fully constrained to

initiate legal proceedings for monthly maintenance under relevant section of
the Criminal Procedure Code, 1973, against you, the noticee. That the
aforesaid legal action will be taken against you, the noticee entirely at your
risk and costs without any further notice to you the notice.

You may please note that in case of failure of your client to do the following as stated
in the above paragraph, my client shall be resorting to all such other legal measures
against your client in competent court of law, which shall be entirely at your client’s
cost and consequences without any further reference to you, the noticee.

It may be noted that the present legal notice is expressly without prejudice to all the
rights and remedies which are open to my clients under law, which have arisen or
may arise at any point of time in the future.

Copy of the present legal notice will be retained for further and necessary action as
per law.

Mob.: +91 9971885087

e-mail: adv.kartikeyamudgil@gmail.com
 KARTIKEYA MUDGIL
Advocate & Solicitor
Ch.: 295 B, Old Lawyers Chamber Block, Delhi High Court, Sher Shah Road, New Delhi – 110503
Off: T-307, 3rd Floor, Arjun Plaza, Plot No. 7, Sector 5, Dwarka, New Delhi – 110075

KARTIKEYA MUDGIL,
Advocate

Mob.: +91 9971885087

e-mail: adv.kartikeyamudgil@gmail.com