Draft 1

Vaishanvi Krupakaran

Advocate , Delhi High court

Email:krupakaranvaishnavi@gmail.com

Ph no. 123456789

Date : 20.04.2021

To ,

Sanjana R,

………………….

……………..

……………….

(address)

Sub : Legal notice for illegal trespass

Madam,

Under the instructions of my client and on behalf of my client Ms Tanvi P . and we hereby serve you
this notice :

1. My client is the owner of the piece of land is the owner of a piece and parcel of land with a tiny
mud hut (having electricity connection) admeasuring 5000 sq ft. located in Plot No. 46, XYZ Nagar,
New Delhi- 411098. The property was purchased by my client vide sale deed dated 01.05.2011, from
Mr. Alexander J. about 10 years ago. She has also been paying the electricity bills for the hut every
month. No person resides in the said plot of land.

2. It has come to the notice of my client on 01.06.2020 while my client visited the property for
inspection she noticed that the thatched hut in the Property had been broken down and 5 storied
apartment building having 20 apartment units was being constructed .My client was shocked to see
the land being excavated .

3. On enquiry my client found out that u started the construction of the property after demolition of
thee hut on the plot which belonged to my client .

4. On further inspection with the Delhi Development Authority my client was shell shocked to know
that you not only misrepresented the title and the ownership of the property but also got the plan
sanctioned for constructing a 5 storied apartment building having 20 apartment units.

5. my client tried to approach you to talk about the illegal activities which were being carried out
but u failed to co-operate for any discussion regarding the above matter , so my client was unable to
speak to you in the premises of the property or else where regarding the matter .

6.My client had never entered into any activities with u at any point of time , if not for my client’s
visit on 01.06.2020 she would not have been aware with the demolition and the construction
activities which are being taken place . my clients rights have completely been infringed upon by you
.This act shall have serious criminal actions due the actions committed by you .

In the light of the above facts ,you are hereby called upon to stop all the illegal construction activities
and trespassing activities within a period of 21 days to do so . If you do not do so my client will be
forced to take legal action which shall involve risks and costs .

7. Adding on to that my client shall has already incurred great losses financially and mentally which
shall sum upto to an estimate of Rs 50,000 additionally .

Yours Sincerely ,

Vaishanvi Krupakran .

(Advocate )

Client

Tanvi P

Draft

Vaishanvi Krupakaran

Advocate , Delhi High court

Email:krupakaranvaishnavi@gmail.com

Ph no. 123456789

Date : 20.04.2021

To ,

Advocate Rana Singh ,

………………….

……………..

……………….

(address)

Reference : response to your legal notice dated 22.02.2021

Sir ,

we address this notice to you for the legal notice sent by you dated 22.01.2021, on behalf of your
client(Sushant Kukreja) . I hereby serve this legal notice under the instruction of my client(AZB
Developers Pvt. Ltd.) :

1. My client AZB Developers Pvt. Ltd and Mr Sushant Kukreja entered into an agreement for
sale of the property on the date 24.08.2018.The Agreement was entered into between the
parties for the sale of Flat No. 224 in Phase II of Neem Tree Apartments.
Your client entered into the agreement out of his own will and wish and decided to take the
understanding of our agreement forward as per the terms of the agreement .
 2. As per the terms of the Agreement, the Purchaser was required to pay the consideration in 6
equal instalments as per the instructions discussed while purchasing , as per schedule b of
the agreement .
3. The purchaser had to make the payment after receiving the invoice within 1 week from the
date of invoice. The Purchaser has defaulted in the payment of the 4th and 5th invoices. In
spite of sending repeated reminders through the purchaser (your client ) defaulted the
payment of the 4th and 5th instalment as captured in schedule B of our agreement .
4. It is brought to your attention that your client has defaulted the payments of the fourth and
fifth instalment against the invoices raised under 01.09.2020 and 01.12.2020.
5. Your client has mislead you by misrepresenting the factual background and has defaulted
the payments of the above mentioned invoices .The amount is still outstanding in our books
of accounts in spite of repeatedly sending out notices and invoices .
6. As per clause ----- of our agreement our client was entitled to terminated all the contracts
and agreements if there was default in the payment beyond raising the invoices beyond 30
date . Pursuant to the above mentioned clause post the defaulted period our client
terminated the agreement as per the non- payment clause -- of the contract .
7. We have sent a reply to the legal notice sent to you following what our client put in our hand
.
8. In response to para 1 :It is denied that your client has made regular and prompt payment as
per the terms of our agreement and the two defaulted payments are still outstanding in our
books of accounts .the termination of the agreement was in accordance of the clause --- of
the contract and the breach of the agreement caused by your client by defaulting of
payments due to non fulfilment of the payment obligations by your client . you are put to
strict proof of allegation as made by your client
9. In response to para 3 :It is completely denied that our client had wrongfully terminated the
agreement and have tried to wrongfully enrich themselves . We have only acted upon and as
per our the agreement clause --- .
10. In response to para 4 :It is once again reiterated that our cancellation of the agreement was
completely lawful and as per the terms of our agreement . Our client is not in a position to
accept the conditions of your client and would now like to deny everything as for you client ,
if your client would have shown us a sufficient cause for the reason of non payment our
client would not have terminated the contract .
11. In response to para 5 :Hence all the obligations stands terminated to handover the
possession of the flat to your client and he has no rights over the ownership of the property
. Therefore if there are any third party agreement created by our client it would be
absolutely legal and valid .Therefore it is our humble request for you to let Our client repay
all dues and advances of payment from our client .
12. In response to para 6 :Bearing this in mind our client has stated that the termination of the
agreement was completely valid . our client does not intend to permit you to let your client
pay any outstanding or claims as your client has lapsed the time period despite receiving
repeated reminders .
Our client says that all refunds and dues shall be paid to your client in accordance the terms
of the agreement .Hence, we strongly advise you to instruct your client to withdraw the legal
notice dated 22.01.2021. As the above mentioned notice has completely been based upon
factual and concocted facts which is completely untrue . Failure to do so within 7 days of the
notice being sent upon can attract appropriate legal notice .

Yours Sincerely ,
Vaishanvi Krupakran .

(Advocate )

Client

AZB Developers Pvt. Ltd.