Ref: Date: _______

To

The Secretary
Mr. Deshmukh
_______

_________

Dear Sir,
Our Client, M/s Soul Kitchen Hospitality Services [SKHS] having its place of business at – A-
_________________________ Pune – 46, has instructed us to serve you as under;

1. Our client states that vide the contract dated 19th July 2018, between our Client and
__________________ Co-operative Hos. Soc. Ltd, it was agreed upon that you will
allow our client to run and manage a restaurant within the premises of the Society in an
area demarcated in the Club House of the Society, lying and situated on the ground floor
and named as _________. Our client states that as part of terms and conditions of the
Agreement, our client was asked by you to deposit with the Society, a refundable deposit
amount of Rs. 50,000/- (Rupees Fifty Thousand only) as the security for the use of the
said premises for running a Restaurant. That the deposit was to be refunded to our client
on termination of the agreement / as provided in the Agreement.

2. That our client vide its letter dated 8th September, 2018 informed the Society that they are
facing severe shortage of manpower and therefore they are unable to commence the
operations. They further proposed and stated that you may engage any other hospitality
service to start the facility. In the mean time they also mentioned that they shall be
putting in all efforts to put a team together and shall inform you the moment they are
prepared to start operations at the facility.

3. Our Client states that the said letter of 8th September 2018 was addressed to one Wg Cdr
_____________ ( Retd.), the former Secretary of the Society and also to Col.
____________, the Treasurer of the Society. Our Client state that the contents of the said
letter were subsequently discussed with you and one Mr. Suman at a meeting in your
society office held in the month of November, 2018. Our client reiterated at the meeting
that they did not want the society member to face any further hardship due to the facility
not being operational and yet again categorically informed you that you could look for
alternate options.
4. Our client has at all times been considerate towards the interest of the Society. Our client
did not restrain you from looking for any alternative hospitality services, and they always
showed clear and true intentions at all times. It was due to some genuine shortage of
manpower that they could not start the facility, which our client had always informed
you.

5. Our client states that somewhere in the month of February, 2018, you had called upon
our client and asked them to remove all their belongings which had been placed in the
premises, which our client agreed to do and again our client extended their sincere thanks
for the opportunity provided.

6. Our client states that at the time of removing their belongings they found that lot of the
items were missing. Our client further states that, when your society office manager, one
Mr. Pradeep was questioned about those missing items he feigned ignorance of the same.
The responsibility of security of the items was always on the society. However although
the loss of these items was of significant value our client in the interest of cordial
relationship and looking at this as business loss at that moment chose not to raise this
concern with you. Under the changed circumstances, our Client reserves the right to
claim loss for the same.

7. Our client states that during the last telephonic discussion with you, our client was
informed that they were to speak to the Manager about the security deposit. Mr. Pradeep
informed our client that the security deposit would be returned within 10 days. Our client
was further informed that the security deposit would be returned with the deduction of
Rs. 5000/- (Rupees five thousand) without giving any just and lawful reason for the same.

8. Our Client states that it was shocking and surprising for our Client to hear about such
unilateral decision to deduct the said amount. Our Clients further states that such act /
decision on your part is totally arbitrary without any rational thinking and is completely
condemned by our Client.

9. Further our client states that nowhere in the agreement or during the course of subsistence
of the agreement our client was informed of any such deduction, although our client has
been in continuous touch with the secretary of the Society.

10. Our client states that there is no reasons for you retaining Rs.5000/- as there has been no
loss or damage caused to the Society due to any activity on part of our client. On the
contrary it is our client who has suffered the loss, arising from the loss of materials and it
is the society who is liable to indemnify our client for such losses.

11. Our Client hereby calls upon you to refund the entire amount of Rs. 50,000/- deposited
with the Society, without any deduction.

12. Further our client states that any action in furtherance to such deduction shall leave our
client with no option but to take up appropriate legal proceedings against you.
 13. The cost of this notice of Rs.20,000/- shall lie upon you. You are therefore called upon to
reply to this notice within 15 days of receipt of the same, failing which our client will be
compelled to initiate appropriate legal proceedings against you.

Regards

Akash Richard Katawati

Advocate