E-mail: - lawexplorer@ymail.com & praveenbhatnager@gmail.

com

MOBILE No. 09412458767 L-L. M., ADVOCATE

COLLECTORATE’S CHAMBER No. 16 & 17

DISTRICT & SESSIONS COURT COMPOUND, FIROZABAD-283203 (U. P.)

Reference No. 23/OCT/2013 Dated: - 15-10-2013
NOTICE OF CLAIMING DAMAGES FOR DEFAMATION

To,
The Branch Manager,
Retail Loan Service Centre, HDFC Bank,
3rd Floor, Block No. 17/2/4, Deeepak Wasan Plaza,
Sanjay Place, Agra.
Dear Sir,
Under the instructions and on behalf of my client Sri Aditya Kumar Agrawal

s/o Late Sri Har Charan Lal Agrawal r/o 98-99, Ganesh Nagar, Firozabad, I hereby,

serve you with the following legal notice for your information and compliance

thereof: -

1. That my abovementioned client Sri Aditya Kumar Agrawal is a big

businessman and he is running many industries in Firozabad city and

besides this he is a social worker and a respectable man of the society.

2. That my abovementioned client is a law-abiding member of the society and

believes in law and further he neither remained in any criminal activity and

nor he has been convicted in any criminal case by any Court.

3. That you, the notice receiver deals in the business of finance of vehicles,

etcetera and during the course of your business you have sanctioned an

auto loan of Rs. 3,10,000.00 (Three Lakh Ten Thousand) to Mr. Sudeep

Agrawal to purchase a car.

4. That according to the terms and conditions imposed by you the said loan

was repayable in the thirty six monthly installments of Rs. 10,023.00 each.

5. That my client named above is the father of loan borrower Mr. Sudeep

Agrawal so he has given his guarantee against the said loan and further he

also given thirty five post dated cheques of his account no. 20165814741

drawn on Bank of Maharashtra with the object of reimbursement of the

loan. In those cheques, the cheque no. 132094 dated 05-03-2013 for Rs

10,023.00 was also given to you for the payment of monthly installment.

6. That the above said cheque no. 132094 was cleared and cashed in by you

on 06-03-2013 but it is a matter of great regret that you have wrongfully

and negligently sent a report mentioning the name of my above client to

the CREDIT INFORMATION BUREAU (INDIA) LIMITED for inclusion of his

name in list of defaulters even after receiving the amount of cheque no.

132094. This report is based on the false allegations and you have acted

maliciously and without reasonable or probable cause in sending the same.

7. That many persons, including a large number of businessman and members

of the society, hearing of your report to the CREDIT INFORMATION BUREAU

(INDIA) LIMITED for inclusion of name of Sri Aditya Kumar Agrawal in the

list of defaulters, and supposing my client to be a defaulter, have ceased to

be treated by and have dealings with my client, whereby my client has

suffered considerable and substantial loss in his business, goodwill and

reputation.

8. That in consequence of the said report, my client suffered physical pain and

mental shock and was prevented from transacting his business besides

being injured in his credit and reputation.

 9. That my client named above is entitled to recover from you as damages,

the amounts detailed below:

(a) Because of loss of business Rs. Five Lakh;

(b) Because of loss of reputation and credit Rs. One Lakh; and

(c) Because of bodily and mental, pain Rs. One Lakh;

10.The remarks made in your report about the said Sri Aditya Kumar Agrawal

are false, baseless and highly defamatory of my client and made with the

intention to defame him and the said Sri Aditya Kumar Agrawal has

suffered in his reputation and has been lowered in the estimation of his

friends, businessman and the general public.

I hereby give you notice to pay a sum of Rs. Seven Lakh to my above

mentioned client as damages and publish an unqualified apology prominently in

the newspaper within seven days from the receipt of this notice. Otherwise, I

have clear instructions from my client to prosecute you in a criminal court for

defamation or to sue you for damages and you will be saddled with the costs of

an unavoidable litigation.

You are liable to pay a sum of Rs. 1100.00 towards charges for the present

notice.

YOURS’ FAITHFULLY

(PRAVEEN KUMAR BHATNAGER)

L- L. M., ADVOCATE

Certified copy to: - HDFC Bank Ltd., MCG E-tech Solutions, P. B. No. 9081,

Goregaon East, Mumbai – 400063.