By Regd Post with Ack-due

Kadapa,
10-11-2018.
From:-
Sri.K.Venkata Reddy B.Com. B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District.
To:-
Shri Ram Transport Finance company LTD
First floor, east to R.T.C bus stand, Kadapa city.
Sir,
Sub:- Legal notice as to seizure and sale of lorry No. AP27Y0108
illegally - Reg.
Under the instructions and on behalf of my client Smt. Shaik Zareena
wife of Shaik Rafi residing at door No.63/155-10-1 Marti street, R.V Nagar
post, Kadapa-3, I hereby issue this legal Notice to you with the following facts:
***
1. My client purchased lorry bearing registration No. AP27Y0108
lorry from you during March 2018 for Rs.5,85,000/- under hire purchase
agreement. My client paid Rs.12,839/- on 27-03-2018 and Rs.24,000/- on 14-
05-2018 towards that lorry sale consideration.
2. The hire purchase agreement is in force and not cancelled by my
client. You seized that lorry from the possession of my client on 04-09-2018
without giving any seizure notice. Further you sold that lorry for Rs.4,55,000/-
without serving any sale notices to my client in the absence of my client for
very very low price for causing loss and injustice to my client even though that
lorry is worth about Rs.6,16,000/- with the motive to cause loss and injustice
to my client.
3. My client is entitled to run that lorry and pay the installments to
you within the period of three years as agreed upon in the hire purchase
agreement. You seized the vehicle without serving seizure notice to my client
and sold the vehicle without serving sale notice in the absence of my client
within the period of three year by violating the terms and condition of hire
purchase agreement and the provisions of the Hire Purchase Act of 1972. My
client is not liable to pay any balance amount to you in future over that vehicle
since you alone seized the vehicle and sold that vehicle by violating the
provisions of Hire purchase Act of 1972.
4. Therefore please take this legal notice and my client is not liable to
pay any amount to you as dues towards that vehicle and that you have to treat
the money transaction relating that vehicle is completely closed.

ADVOCATE