SHOW CAUSE NOTICE FOR ANKUR CHAND

PUBLICY JURIS
Advocates and Solicitors
Chamber no. 475 4th Floor Lawyers Block Saket Court New Delhi 110017
Office H no. 47 2nd Floor Khirki Village near Select City Walk Mall New Delhi 110017 Email:
adv.madhav.chaturvedi@gmail.com Ph:8802515640/7289919287
By Registered AD
May ____, 2019
To,
Capt Chan (Grekdej Kamlesh Chand)

Ankur Chand
5 Arun Amrin Road,
Wat Kallya, Thonburi,
Bangkok, Thailand
Also At:
Bipin Singh,
Peeli Kothi, Rustampur,
Gorakhpur 273016
Sri Kamlesh Chand,

87A, Chand Bhawan, Canal Road,
Daudpur, Gorakhpur 273001
SHOW CAUSE NOTICE
Without Prejudice
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PUBLICY JURIS
Sir,
Under the instructions of and on behalf of our client Mrs. Anjali
Singh, W/o Shri Ankur Singh R/o 249 A, Sahadatpura, Maunath
Bhanjan, Mau 275101 (hereinafter referred to as “Our Client”), we
hereby serve upon you Mr. Ankur Chand S/o Sri Kamlesh Chand
R/o 5 Arun Amrin Road Wat Kallya Thonburi, Bangkok, Thailand the
following Show Cause Notice for and on the behalf of Our Client:-
1. Our Client is journalist by profession and a resident of Mau
district. Our Client got married with you on February 22,
2016 according to Hindu Rites and ceremonies.
2. Ever since April 2016 you are trying to get away from your
marriage obligations and Our Client. You unfriended Our
Client on facebook in May 2016 and blocked all her
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numbers. Soon thereafter your mother blocked Our Client on
facebook and stopped taking Our Client calls.
3. Though Your father was in touch with Our Client from
December 2016 till March 2017 he always demanded mutual
divorce. When Our Client expressed her inability to maintain
herself due to heavy loans and financial burden of her
parents, also the fact that Our Client has no job though
qualified, he also stopped conversation and blocked her
number and whatsapp account. You along with your family
are willfully and deliberately trying to close all means of
communication including phone call, whatsapp and facebook
with Our Client.
4. The numerous incidents of physical abuse, verbal abuse,
emotional abuse, economic abuse committed by you on Our
Client are described hereunder:
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PUBLICY JURIS
a) Our Client and her parents at the time of marriage
were made to believe that you and your family are very
well to do. Believing your family, marriage was
arranged between you and Our Client. A lavish wedding
was held at St. Andews Degree College Civil Lines
Gorakhpur 273001 by Our Client’s parents. Our Client
parents spent around 1 Crore in the wedding to meet
your status and demands.
b) All the demands of your family as regard to household
items, and other items for them, as well as your
relatives were met by Our Client’s parents. However,
you were not happy with the Lucknow property. You
wanted the Lucknow property of Our Client’s father to
be transferred in your favour. You constantly taunted
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PUBLICY JURIS
and insulted Our Client and her parents for not giving
the Lucknow property to you.
c) Soon after reaching Bangkok Our Client realized that
you were very aggressive, angry and wanted to control
the Our Client in every respect. Our Client was not
given any space or freedom to do anything in the house
and was specifically told that Our Client can’t pursue
Journalism as profession. Our Client was made to work
with a big businessman in his beauty product company.
Our Client found this very difficult to deal with this, as
the man use to physically abuse Our Client. But Our
Client always made every effort to deal with the
miserable situation and keep quiet for the peace of
mind of her and her parents. Our Client totally molded
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PUBLICY JURIS
herself according to your ways, which was very
different from her side of the family.
d) You started beating Our Client soon after reaching
Bangkok because you had no chance for physical
intimacy during the stay in Gorakhpur for a period of 3
days after marriage. You also expressed your disgust
for Indian values and culture.
e) Our Client was made to believe that you have high
values for Indian culture and rituals. However on
reaching Bangkok Our Client was surprised to know
your drinking and eating habits. Besides this Our Client
was pressured to make physical relations with other
men as part of Bangkok culture. Our Client was also
pressurized to eat meat of cow and pig which is not a
part of Indian culture and values.
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PUBLICY JURIS
f) Our Client’s health started deteriorating after reaching
Bangkok. Despite consulting any doctor you and your
family members cursed and condemned the Indian
food. Our Client was forced to have potatoes cooked on
pork on Navratri days, due to this incident Our Client
felt broken from inside and cried helplessly. Our Client
on many occasions would cry after getting into bed
because no one could understand the physical and
mental pain she was being put through by you and
your family. On Mahashivratri you ate fish in the
morning after worship. Upon this your mother beaten
up Our Client mercilessly with sandals.
g) Even on reception ceremony held on 02.04.2016 Our
Client was disallowed to call her parents to attend the
same by you and your family. The Parents of Our Client
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PUBLICY JURIS
were disallowed considering they would come to know
torturous behaver of your and your family.
h) Our Client was mentally tortured and physically abused
on number of occasions by you for giving a baby. Our
Client was also humiliated by you for belonging to a
middle class Indian family.
5. That this act of yours smacks of your malicious and
dishonest intentions of indulging in unjust means by
depriving Our Client of her legitimate right to live in a
peaceful manner in her matrimonial home. Various attempts
have been made by Our Client for reconciliation on promise
that the act of physical abuse, verbal abuse, emotional
abuse, economic abuse would not be repeated.
6. Since Our Client belong to an educated family and has high
value for relationships therefore despite the abovementioned
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inhumane behaviour towards Our Client, Our Client wish to
give you hereby a final opportunity by this show cause
notice, why appropriate legal action shall not be taken
against you.
7. That you are hereby directed to respond to this show cause
notice within a period of 15 days from the date of receipt of
this notice, failing which it would be construed the
abovementioned instances are within your knowledge and
are admitted by you. Further Our Client reserves her right to
take appropriate legal action against you.
Please note that this show cause notice is without prejudice to
any other legal rights and remedies available to Our Client.
Further nothing contained in this show cause notice shall affect
Our Client’s right to initiate appropriate legal proceedings (both
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PUBLICY JURIS
civil and criminal). A copy of this notice has been retained in our
office for record and future necessary action.
Yours faithfully,
Madhav Chaturvedi
Advocate
10

SHOW CAUSE NOTICE FOR ANKUR CHAND

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PUBLICY JURIS

Advocates and Solicitors

May ____, 2019

Capt Chan (Grekdej Kamlesh Chand)

Sri Kamlesh Chand,

SHOW CAUSE NOTICE

Under the instructions of and on behalf of our client Mrs. Anjali

Singh, W/o Shri Ankur Singh R/o 249 A, Sahadatpura, Maunath

Bhanjan, Mau 275101 (hereinafter referred to as “Our Client”), we

1. Our Client is journalist by profession and a resident of Mau

district. Our Client got married with you on February 22,

2016 according to Hindu Rites and ceremonies.

marriage obligations and Our Client. You unfriended Our

Client on facebook in May 2016 and blocked all her

numbers. Soon thereafter your mother blocked Our Client on

facebook and stopped taking Our Client calls.

3. Though Your father was in touch with Our Client from

December 2016 till March 2017 he always demanded mutual

divorce. When Our Client expressed her inability to maintain

herself due to heavy loans and financial burden of her

qualified, he also stopped conversation and blocked her

number and whatsapp account. You along with your family

are willfully and deliberately trying to close all means of

communication including phone call, whatsapp and facebook

with Our Client.

4. The numerous incidents of physical abuse, verbal abuse,

emotional abuse, economic abuse committed by you on Our

Client are described hereunder:

a) Our Client and her parents at the time of marriage

well to do. Believing your family, marriage was

arranged between you and Our Client. A lavish wedding

was held at St. Andews Degree College Civil Lines

Gorakhpur 273001 by Our Client’s parents. Our Client

parents spent around 1 Crore in the wedding to meet

your status and demands.

b) All the demands of your family as regard to household

items, and other items for them, as well as your

relatives were met by Our Client’s parents. However,

you were not happy with the Lucknow property. You

wanted the Lucknow property of Our Client’s father to

be transferred in your favour. You constantly taunted

the Lucknow property to you.

c) Soon after reaching Bangkok Our Client realized that

you were very aggressive, angry and wanted to control

the Our Client in every respect. Our Client was not

given any space or freedom to do anything in the house

and was specifically told that Our Client can’t pursue

Journalism as profession. Our Client was made to work

with a big businessman in his beauty product company.

Our Client found this very difficult to deal with this, as

the man use to physically abuse Our Client. But Our

Client always made every effort to deal with the

miserable situation and keep quiet for the peace of

mind of her and her parents. Our Client totally molded

herself according to your ways, which was very

different from her side of the family.

d) You started beating Our Client soon after reaching

Bangkok because you had no chance for physical

intimacy during the stay in Gorakhpur for a period of 3

days after marriage. You also expressed your disgust

for Indian values and culture.

e) Our Client was made to believe that you have high

values for Indian culture and rituals. However on