Deepak Notice Reply

Reference No.
RS/118/289/16
Dated: 20.12.2016
Regd. AD / Speed Post
To,
Sh. K. S. Bhati
Advocate
Chamber- 813, Dwarka Court Complex,
Sector-10, Dwarka, New Delhi- 110075
REPLY TO NOTICE DATED 12/12/2016

Dear Sir,
My Client Sh. Deepak Bhargava R/o C-301, Plot No.-4, Sector9, KKCGHS Ltd., Bhrigu Apartment, Dwarka Phase-1, New
Delhi- 110077 has placed in my hand legal notice dated 12 th
December 2016 sent by you on behalf of your client Mr. S. P.
Singh for its reply and I hereby reply the same as under:That without prejudice to the right and argument of my Client
and anything foregoing, the content of the aforesaid notice are
noted and my Client hereby deny all the allegations, statements
and contentions set out in the aforesaid notice specifically those
which are contrary to and / or inconsistent with what is stated

hereinafter.
Notwithstanding anything else, to provide clarity on the subject
matter of the notice, we would like to apprise you of the true
facts, which are detailed in as under.
Preliminary Objections:
1. That the aforesaid Legal Notice dated 12.12.2016 is based on
sheer ignorance/mis-comprehension of facts and the same has
been issued to my client in order to cause him inconvenience
and discomfiture.
2. That mere perusal of the notice reveals that some extremely
serious allegations have been leveled against my client without
having any factual basis whatsoever.
It appears that your
clients is either thoroughly ignorant or has knowingly

concealed material information from you with regard to the
status of my client.
That your client has mis-stated the true facts to you, which
are outlined as under
1. That your client made false allegations against my client
without providing any conclusive proof.
2. That your Client was also previously employed with the same
society as an Office manager/Care Taker for nearly eleven
months in 2013-14 and was discharged from his duty by the
managing committee due to misbehavior and irregularities
during employment. That your Client used to misbehave with
the members of the managing committee and other society
members. That your Client who self-accumulated his weekly
offs had one day, suddenly disappeared from the job without
proper official sanction of any leave or without taking prior
permission from the competent authority. It was only after one
to two months later that your client came back and illegally
demanded the salary for all those months for which he was
absent on the pretext that he had accumulated the weekly offs
and had right to use those leaves as per his own sweet will.
That the managing committee didnt want to create any
further ruckus thus decided to pay him the amount
demanded by him and professionally discharged him from
service with immediate effect.
3. That presently the managing committee is not functioning and
the society is being governed by the Administrator and the
administrator solely works on the aid and advice of the
advisory Board. That in the present circumstances advisory
board has the power to appoint an Office manager/Care Taker
for day to day running of the affairs of the society. Any
unwanted recommendation from an outsider can create
hurdles in the smooth functioning of the society and can also
create potential legal hurdles. That any appointment which is
prima facie under the scanner has to be avoided at all costs
and my client his fellow members were discussing that aspect

only and had thereby made the said statement/comment.
4. That it is pertinent to mention you that during the said
conversation, my client had also pointed out on your clients
closeness to one Sachdeva and party and their counsel i.e.,
and this notice from you directly confirms the truthfulness of
the said statement/comment.
5. It is pertinent to mention here that the said alleged
defamatory statement/comment should have been read in
context to which the said clause was made. That the same
comment was given, due to the outcome of the impression
formed
after
knowledge
all
acts
of
misbehaviour
and
irregularities with respect to your client.

6. That this notice sent is only a part of a chain with regard to
the local politics being played by the other members and
defaulters of the society.
7. The notice under reference has been issued to my client by
you on behalf of your client in a whimsical and arbitrary
manner and the same is a veiled attempt to blackmail /extort
money from my client by leveling against him, false and
frivolous allegations.
Parawise Reply:
1. That the contents of para 1 of the notice are not related to

my client hence needs no reply.
5. That the contents of para 5 of the notice are wrong and
thus are denied. It is denied that your client left the job
after he noticed certain irregularity in the functioning of the
managing
committee.
That
the
real
reason
about
employment status of your client is already mentioned in

the notice hence no need to repeat here for the sake of
brevity. It is true that father of my client was the officer of
the said managing committee and also pertinent to mention
that despite noticing the alleged irregularities your client
never made complaint or report about the functioning of the
managing committee and conduct of the father of my client.
Your Client hereby to put strict proof to those bogus and
false allegations.
thus are denied. That the reasoning behind the said
comment was already mentioned and it is reiterated that
deceased son of your client was in jail due to some theft

case.
7. That the contents of para 7 of the notice are admitted.
thus are denied in toto. It is pertinent to mention that it is
sachdeva and party who pressurizing Mr. S. P. Singh i.e.,
your client to send this notice otherwise they will throw him
from the present job. It is pertinent to mention that your
client has utmost respect for father of my client.
thus are denied. That the reasoning behind the said
statement/comment
was
already
mentioned
and
statement/comment should be read in that context only.

10.
That the contents of para 10 of the notice are wrong and
thus are denied. It is denied that your client is under deep

trauma and is highly demoralized, disappointed and under
tremendous stress. It is pertinent to mention here that your
client attending office daily and in constant touch with my
client and father of my client.
Thus, through this communication and response to the
Answering notice, our Client called upon your client in the first
instance to withdraw the present notice and despite this if your
client chooses to initiate any legal action against my client, it
will be at his risk, cost and consequences and in that event I
have clear instructions from my client to initiate appropriate

legal proceedings against your client for fraud, defaming and
harassing my client at his risk cost and consequences which
you may please note.
You are also hereby directed to pay the amount quantified
as under:
A. INR
10,00,000/-
for
causing
mental
and
physical
harassment
B. INR 10,00,000/- for causing loss of reputation
You are hereby called upon to consult your Client and comply
with the above mentioned legitimate demand of my Client.
(Please remit Rs. 11000 /- as a professional fee of this notice
along with the above stated amount.)
Your(s) truly
RAJIV SINGH
ADVOCATE
Chamber No. 706, Lawyers Block,
Dwarka District Courts, Delhi - 110075

Deepak Notice Reply

Uploaded by

Copyright:

Available Formats

Deepak Notice Reply

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Deepak Notice Reply

Uploaded by

Copyright:

Available Formats

Reference No.

Regd. AD / Speed Post

REPLY TO NOTICE DATED 12/12/2016

which are contrary to and / or inconsistent with what is stated

It appears that your

clients is either thoroughly ignorant or has knowingly

and my client his fellow members were discussing that aspect

irregularities with respect to your client.

1. That the contents of para 1 of the notice are not related to

employment status of your client is already mentioned in

deceased son of your client was in jail due to some theft

statement/comment should be read in that context only.

That the contents of para 10 of the notice are wrong and

thus are denied. It is denied that your client is under deep

have clear instructions from my client to initiate appropriate

You might also like

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.