Petit Juris

advocates, advisors and legal consultants

02.03.2016

Sh. Ravi Bhateja son of Sh. Baldev Raj

resident of 28/45, Punjabi Bagh West,
New Delhi 26
Reference : Notice to my client in the matter of CS(OS) 1114/2008
Sir,
We are retained by and act under instructions of Sh. Pramod Ahuja, Advocate of
Chamber No. 401, Lawyers Chambers, High Court of Delhi, 110003, who has
shown us a your notice, relevant documents and has instructed us to serve you with
the present reply to the notice of yours.
At the very first instance, my client denies with vehemence and do not admit the
veracity of the contents of your notices letters including the allegations, averments,
contentions and accusations thereof save and except certain factual aspects those are
part of record file in the Courts of Law, as would appearing in the following paras,
as the same are contrary to the facts those are misconceived to you. The contents of
your notice dated 3.2.2016, unless until admitted may kindly be deemed as
vehemently denied and dissented more so intensely opposed.
Since the matter being subjudice and my client has nothing more to say than, he
being practicing advocate for more than 40 years in the legal fraternity has full
regards and respect for the Courts and has never been involved in any controversy
or that he has no personal grudge, ill-will or any bad feeling against parties to the
lis. Your writing the notice under present reply is due to the intonation felt and
personal cadence of my client, which he carried for his client upon the instructions
CORPORATE OFFICE : 3E-34 ‘D’ Bungalow Plot, N.I.T. Faridabad 121 001 (HARYANA)
, INDIA Phone : 0129-2411603, 2427356 Fax . : 0129 4059942, (M) 9899891989
DELHI : Chamber No. 150, Lawyers Chambers Block, New Delhi Courts,
. Patiala House, New Delhi, 110001 IN DIA Ph. : 9560964964
LUCKNOW OFFICE : 115, First Flr, Amrapalee Greens, Vrindavan Yojna Scheme Sec.2 Rae Bareili Road , Lucknow (U.P.) INDIA Phone : 9415105403
Also at Gurgaon, Chandigarh and Allahabad
email : office@petitjuris.com V isit us on : http:/ / www.petitjuris.com
 Petit Juris
advocates, advisors and legal consultants

of the client and nothing else. My client is least bothered if his client has changed
number of counsels before him, or if they were capable/incapable because all he is
concerned is for his client and nothing else.
We have been advised to state to you that already in the Court premises, you have
threatened my client a number of times and by sending the notice dated 3.2.2016
under reply you are not only threatening to launch the prosecution against my client
but also insisting him to withdraw from the case. Apparent object of your writing
such letter is to get the mind of my client deviated from the case. My client once
undertaking the examination of witnesses be it chief, cross or re-examination, is
well aware of appropriate provisions of Law of Evidence or such other law in force.
Your notice in question is a direct threat taking the shelter of Section 31, which has
already been omitted w.e.f. 1.1.1977. All that you have made in the notice dated
3.2.2016 is mere a technique to threaten with casting doubts, aspersions with
apprehensive state of mind.
We have further instructions to state to you that you should not discuss the contents
of your case unnecessarily and with my client, being an advocate of your opposite
side, therefore immediately and without any failure, you should withdraw the
contents of the notice dated 3.2.2016. We have instructions also to state to you that
on your such acts, misdeed and bad conduct, my client may take a suitable action
against you in civil as well as criminal laws, that you are deliberately attempting to
force him to withdraw from case. It is thus too obvious to state that my client is
rather entitled for compensation against you for causing his mental disturbance and
unnecessary harassment. It is however we who have thought professionally and

CORPORATE OFFICE : 3E-34 ‘D’ Bungalow Plot, N.I.T. Faridabad 121 001 (HARYANA)
, INDIA Phone : 0129-2411603, 2427356 Fax . : 0129 4059942, (M) 9899891989
DELHI : Chamber No. 150, Lawyers Chambers Block, New Delhi Courts,
. Patiala House, New Delhi, 110001 IN DIA Ph. : 9560964964
LUCKNOW OFFICE : 115, First Flr, Amrapalee Greens, Vrindavan Yojna Scheme Sec.2 Rae Bareili Road , Lucknow (U.P.) INDIA Phone : 9415105403
Also at Gurgaon, Chandigarh and Allahabad
email : office@petitjuris.com V isit us on : http:/ / www.petitjuris.com
 Petit Juris
advocates, advisors and legal consultants

giving you a chance to withdraw your notice dated 3.2.2016 well within 15 days
from the date of service of the present reply to you, otherwise it may be deemed as a
notice upon you for taking appropriate action against you inter alia seeking
adequate compensation for loss of repute, loss of peace of mind, causing mental
agony and anguishment. Section 80 of Code of Civil Procedure is applicable against
the State or Central Government & not against Individual.
We trust that you shall comply with the requisite of the present one to obviate the
necessity of any unpleasant steps having to be taken against you which needles to
mention shall be at your entire cost and consequences, without prejudice to other
rights and remedies as may be available to my client. You have written so many
threatening letter to my client. You are requested to stop yourself for sending any
letter to my client otherwise my client will file suit for defamation as well as for
damages against you.
By this notice you are interfering with the administration of Justice & in
contimission in nature. My client has liberty to file appropriate application for
contempt of court or other applications before the concerned court of law.
for Petit Juris

Ritesh Khatri
Advocate

CORPORATE OFFICE : 3E-34 ‘D’ Bungalow Plot, N.I.T. Faridabad 121 001 (HARYANA)
, INDIA Phone : 0129-2411603, 2427356 Fax . : 0129 4059942, (M) 9899891989
DELHI : Chamber No. 150, Lawyers Chambers Block, New Delhi Courts,
. Patiala House, New Delhi, 110001 IN DIA Ph. : 9560964964
LUCKNOW OFFICE : 115, First Flr, Amrapalee Greens, Vrindavan Yojna Scheme Sec.2 Rae Bareili Road , Lucknow (U.P.) INDIA Phone : 9415105403
Also at Gurgaon, Chandigarh and Allahabad
email : office@petitjuris.com V isit us on : http:/ / www.petitjuris.com