Raj Kumar Yadav Chamber No.
630,
Lawyer’s Chamber
Advocate Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi-110075
Mob.9899302317
Date: ___________
(SPEED POST)
To,
Ekant Singh
Advocate
Chamber No 90,
Saheed Sukhdev Singh Block
District Courts, Gurugram,
Haryana
MY CLIENT: MR. MUKESH SINGH, OWNER OF DRY CLEAN SHOP,
ADDRESS – B-44/2, IGNOU ROAD, NEB SARAI, NEW DELHI-110068.
YOUR CLIENT: M/s VIKHUSH ENTERPRISES PRIVATE LIMITED
(REVIVO DRY CLEANERS).
REPLY TO LEGAL NOTICE DATED 04.09.2024
Sir,
My above mentioned client has received a notice dated
04.09.2024 issued by you on behalf of your above mentioned
client through Post. The copy of said notice has been given by my
client to me with the instructions to reply the same properly.
Accordingly I am sending you this reply on behalf of my above
named client.
At the very outset, I would like to bring in your kind notice
that your, client has not approached you with clean hands and
has suppressed the material and true facts from you at the time
of drafting the said legal notice. The parawise reply are as under:-
PRELIMINARY OBJECTIONS & SUBMISSIONS:-
1. That your client provided the work to my client from
29.05.2024 to 31.06.2024 and thereafter your client has not
given any work to my client. Your client called my client for
payment to my client on 10.07.2024 but due to some
reason, your client has not paid the payment to my client
and extend for further. Thereafter your client again called
my client, then my client reached at the shop of your client
on 17.07.2024, but your client never paid any payment and
requited for extend time again and again.
2. That after repeated request from my client to your client for
the payment, then your client again told to pay the same on
02.09.2024, after reaching at the shop of your client, your
client said that he will pay the whole amount after deducting
some amount but did not pay the single penny to my client
and deny for payment as he told that he has not satisfied the
work of my client.
3. That your client is trying to grab the hard earned money of
my client and your client is liable to pay the same
immediately.
PARAWISE REPLY ON MERITS:
1. That the contents of para 1 of your notice is matter of
record.
2. That the contents of para 2 of your notice is wrong, false and
hence denied.
3. That in reply to this para is wrong, false and hence denied. It
is submitted that my client requested many times to release
his payment from your client but your client intentionally
linger on the matter on one pretext or the other, lastly your
client refused to pay the same and leveling false allegation
against my client.
4-7. That the contents of paras No.4 to 7 of your notice is also
wrong and hence denied. It is submitted that my client
requested many times to release his payment from your
client but your client intentionally linger on the matter on
one pretext or the other, lastly your client refused to pay the
same and leveling false allegation against my client. It is
further submitted that my client has given the reply of this
also at preliminary objection and submission and the same
may be perused.
8-12. That the contents of paras No.8 to 12 of your notice is also
wrong and hence denied. It is submitted that my client
requested many times to release his payment from your
client but your client intentionally linger on the matter on
one pretext or the other, lastly your client refused to pay the
same and leveling false allegation against my client.
13-15. That the contents of paras No.13 to 15 of your notice is
also wrong and hence denied. It is submitted that your client
has not discussed or told about the negligency of work on the
part of my client earlier but my client requested for his
payment to your client, then after lapse of many days, when
my client pressurized for release the payment as your client
totally refused to give work to my client, then your client
tried to level allegation of negligence of work upon my client
and the same are totally false and incorrect. It is further
submitted that your client is applying the tactic for non-
payment to my client, so your client sent this false and
fabricated notice.
16-18: That the contents of paras No.16 to 18 of your notice is
also wrong and hence denied. It is submitted that your
client instructed you for sending the notice to the address of
my client which is totally wrong, false, incorrect. The notice is
nothing but a blackmailing device, so as to extort money
from my client by extracting undue pressure upon my client
because there is no concern about the allegation upon my
client as per the story mentioned by your client in the said
notice.
In the light of foregoing, I the undersigned hereby advise you to
revoke/withdraw the said legal notice under reply immediately,
tender unconditional apology to your client within 15 days from
the date of receipt of this reply and told to your client to release
the pending payment to my client, failing which my client with
the liberty to take appropriate legal action, both civil and criminal
against your client.
If by ignoring the aforesaid advice/ direction, your client still
persists to go ahead with the proposed/ contemplated action i.e.
frivolous and vexatious litigation, the same shall be contested and
defended by my client with full force entirely at the risks as to
costs and consequences of your client.
Copy of the reply of this notice has been kept in my office for
further reference, if any.
[RAJ KUMAR YADAV]
Advocate
