NARESH TALWAR CHAMBER NO C 1

ADVOCATE C.L JOSEPH BLOCK

TIS HAZARI COURTS
DELHI 110054
MOB - 9811257563

REFERENCE NO DATED -22-06-2020

REGD.A.D

TO ,

1.SH.NAVDEEP SHARMA
S/O S.P SHARMA
2.SMT CHARU SHARMA
W/O NAVDEEP SHARMA
BOTH R/O-A-1 /68A KESHAVPURAM
DELHI -110035

ALSO AT
1624-C BLOCK POCKET B
PALAM VIHAR ,GURUGRAM
HARYANA 122017
LEGAL NOTICE
Sir
Under the instruction for and on behalf of my client Sh Hitesh Ghai S/o Sh S
S Ghai R/o A-2 / 87 B Keshav Puram Delhi 110035 .I hereby serve upon you
with the following legal notice:-

1. That you both are owner of property number A-2/15c S/F Keshav Puram Delhi
and entered into agreement to sale /purchase of above said property with my
client on 26-02-2020 .In pursuance of above said agreement you had agreed to
sale your property number A-2/15c S/F Keshav Puram Delhi for consideration of
RS 57,00,000/- (fifty seven lacs only). Out of which Rs 6,00,000 (Six lacs only) in
which Rs 3,00,000(Three lacs) paid by cash and Rs 3,00,000(Three lacs) paid
through cheque no. 66243 SBI BANK Lawrence road Branch on 26-02-2020 and
agreement to sale and purchase was executed between you both and my client.
It was agreed that balance amount of RS 51,00,000(Fifty one lacs) will be paid
by my client to you on or before 26-06-2020 at the time of execution of sale
deed of the above said property .

2 . That due to COVID -19 (Crona Disease) complete lockdown was imposed by
the Govt since 25-03-2020 and all business and other activites are Shutdown
even till date only necessary work/activities are going on .My client business is
totally shutdown since 25-03-2020 and financially crises are going on due to
Covid 19 and my client is not in the position to arrange balance amount of RS
51,00,000(Fifty one lacs) on or before 26-06-2020 .and in present circumstances
I herby inform you on behalf of my client that you may extend the date of
registration of sale deed for atleast 6 months after expiry of 26-06-2020

3. That my client number of times requested you to extend the date of

registration of sale deed due to Covid 19 financial crises but you state away
refuse to extend the time and lastly on 20.06.2020 my client request you to
extend time for registration of sale deed and balance payment to you through
whatsapp message from his phone number but you refused to extend the
timeframe .From above said act it is crystal clear that you played fraud upon my
client and you want to grab had earned money of my client and on account of
above facts you are liable to be prosecuted for fraud/ breach of trust breach of
contract and larceny. That in present Covid 19 situation law is very clear and you
are duty bound to extend the time limit for balance payment as well as
registration of sale deed

I, therefore through this legal notice hereby call upon you to extend the
timeframe of six months from 26-02-2020 for registration of sale deed and
making balance payment failing which return the earnest money of Rs 6,00,000
(six lacs) which you have received from my client on 26-02-2020 at the time of
execution of the sale /purchase agreement of property number A-2/15c S/F
Keshav Puram Delhi. along with cost of this legal notice which is Rs 11000
(Rupees Eleven thousand) within a period of 15 days from the date of receipt of
the this legal notice , failing which my client has given me definite instruction to
initiate legal proceeding before the appropriate and competent court of law
against you at your cost, risk and consequences which please note
A copy of legal notice kept in my office for further references and action

NARESH TALWAR
Advocate