Legal Notice

Draft a legal notice by advocate for purchaser to the Vendor calling upon him to
specifically perform an Agreement to Sell i.r.o. immoveable property.

Date: 19/10/2021
To
Ms. Anusha D/o Raghav Sharma, 
R/o., Flat. No. 1319,
Sector 01, Greater Noida -201303

Under the instructions from our Client, Mr. Swadesh Kumar Kesarwani S/o. Shri
Krishna Prasad Kesarwani, aged about 50 years, R/o 1-7-63, Arunoday, Kamla Nagar,
Dhantoli, Dist. Nagpur Maharashtra-440070, we issue this Notice.
1. Our Client informs us that you were the absolute owner of the property situated
at Flat No. 102, First floor, Tower Athena B, Samartha Nagar, Nagpur 440024,
Maharashtra. On 28th November 2020, you approached our client regarding the
sale of your aforementioned immovable property. You conveyed that you
desired to sell the said property as you would be moving to Noida the following
year and therefore you thought it wise to dispose of the property. 
2. Thus you entered into an agreement to sell with our client on 10th December
2020. The mutually agreed upon consideration between the parties was Rs.
90,00,000/- [Rupees Ninety Lakh only], out of which an amount of Rs.
45,00,000 [Forty-five Lakhs only] towards advance was to be paid at the time
of execution of the agreement to sell and it was duly paid by our client too. The
remaining balance was to be paid at the time of transfer of possession which
was agreed to happen in the month of June 2021.
3. It has been almost four months now since the agreed upon time of transfer of
possession has passed. It is pertinent to note that even after multiple repeated
attempts from our client’s side, there has been no communication whatsoever
from your side regarding transfer of the said property. At the time of entering
into the agreement, our client intimated that they would need the flat in the
month of July as the lease on their existing flat was to end in June 2021 itself
so you knew of the helpless situation our client would be in if you reneged. Our
clients put their trust in you, were dependent on you and now they are in a
precarious position because of your dishonouring the contract.
4. So we hereby give you notice that my client is still willing to pay the whole of
the remaining balance amount and complete the purchase, as they are in need,
provided that you complete your part of the same agreement and transfer
possession within 30 days of receipt of this notice.

Hence, our Client calls upon you to reply to this notice forthwith and transfer
possession of the premises within 30 days of receipt of this Notice, failing which, our
Clients will be constrained to file a suit against you for specific performance of the
said agreement for sale with damages and costs.
Avoid unpleasantness.

        Advocate