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Gadhvi & Associates, Advocates

Date: 15/02/2019

To,
Mr. ABC, Advocate
2nd Floor, Arcade Squre,
Paldi,
Ahmedabad.- 380007

Subject: Reply of Legal Notice by Mr. ABC dated 30th Jan;2019 for
Policy No. 10023565

With due instruction of my esteemed client New India


Assurance Limited has directed us to serve upon you the reply aligned with
the your legal notice dated 30th Jan 2019, reference No. 02-786-2010 as
under:

(1) That my client New India Assurance Limited is the well known
reputed company celebrated for its credibility, integrity, honesty and
loyalty with its clients.

(2) That my client has a branch office situated at 4th & 5th Floor, Popular
House, Near Sales India, Ashram Rd, Navrangpura, Ahmedabad,
Gujarat 380014 where your client has sent the legal demand notice for
claim of Insurance Money.

(3) That your client is a Football Player and had taken insurance of the
legs from our client company i.e. New India Assurance Limited.
Moreover, this insurance was taken just before few days of the
Competition wherein he has been injured.

(4) That your client has misrepresented and concealed facts that his leg as
already injured and also the presented forged doctors report before the
my client company as to acquire the insurance fraudulently.

(5) That my client seeing the good repute of your client in sports field
and as a part of credence of your client has provided with this present
cover policy.

(6) That however, your client committed a breach of a pre-condition of


contract by not providing and hiding the factual truth that his leg was
already injured at the time of taking the policy which clearly shows
malafide intentions of your client to misrepresent and cheat my client.

(7) That there exists, prima facie, no any locus standi against our worthy
client i.e. New India Assurance Limited as it is a clear fraud and
concealment of truth on your part, moreover your client has also done
a criminal breach of trust by such actions.

Continuation Sheet -- 02
(8) The company has considered the facts and relevant documents of this
case and has deduced that the company is not legally obliged to honor
the claim of the claimant.

Kindly convey your client that he has a wrong claim.

For, Gadhvi Associates, Advocates

Pruthvi H. Gadhvi
(Advocate High Court)

Copy Forwarded To:-


Your Esteemed Client
Mr. PQR
Plot. C-22/23
Sachin Park Socitey
Vasna, Ahmedabad.

Continuation Sheet -- 03

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