S W A P N I L V.

A B H A N G
B. L.S. L.L.M

A d v o c a t e, B o m b a y H i g h c o u r t

Residence: D-402, Raj Mandir Complex, Near Maruti Suzuki Showroom, Mira Road (E), Thane 401107

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To,

M/s HT Media,

18-20, Hindustan Times House, K G Marg,

New Delhi- 110001

Under instructions and given authority of my client M/s Flamingo Communications India Pvt

Ltd having office at 401-402, Rex Chamber WH Road, Ballard Estate, Mumbai 400001, notice

you as follows:

1. That my client is carrying business of _________________________. My client had

availed services of advertisement on Fever FM and/or Radio Nasha and Punjabi Fever.

Bill of Rupees for advertisement played towards my client is Rs 2,36,456/-.

2. That there was a barter cum cash agreement/understanding between you and my client.

That my client will provide you accommodation, conference room, dance floor. My client

had to bear expenses of accommodation, conference room, dance floor for you. You

agreed to pay in cash Rs 3,99,000/- (Rs Three Lakhs Ninty Nine Lakhs only) and

remaining amount was to be bartered. Purchase order was also raised by you.

3. You approached my client at my client’s office for providing accommodation, conference

rooms, food, dance floor. Accordingly my client made booking at Relax Adventure resort

and country. You had informed date of event i.e. on 11February 2020 to 13 th February
 2020. The arrangement was ordered by you for 70 to 80 people. Services included food

but excluded liquor. Our client had informed you that in case of any changes or

cancellation you had to inform thirty days prior. You had also agreed this on email. You

and my client agreed these services for a price of Rs 13,80,000/- i.e. Rs Thirteen Lakhs

Eighty Lakhs only. As stated above You agreed to pay in cash Rs 3,99,000/- (Rs Three

Lakhs Ninty Nine Lakhs only) and remaining amount was to be bartered. Purchase order

was also raised by you.

4. That accordingly my client paid for preparations for food and other services. No advance

payment was made by you. Hence my client had to bear all expenses. Food and all other

arrangement was prepared. Charges were paid. Extra manpower was deployed. However

your plan was changed and you cancelled to attend due to your internal corporate

reasons. On phone your employee/coordinator informed my client that though

programme is cancelled the costs will be paid/bartered by us i.e. M/s HT Media. You

were liable to pay Rs 13,80,000/- i.e. Rs Thirteen Lakhs Eighty Lakhs only as my client

had to pay for it.

5. That my client is a prestigious organization. There were many inquiries on date of event

i.e. on 11February 2020 to 13th February 2020. Many prestigious persons, celebrities and

organizations had inquired for booking 11February 2020 to 1 3th February 2020. However

my client had to deny as it was reserved for you. When those people visited on above

dates there was no programme and resort was not occupied. Due to which my cleint’s

reputation is defamed in market. Many clients felt that my client had intentionally denied

them. This has affected severely on my client’s business.

6. Accordingly my client sent you invoices for the above-mentioned services. Thereby you

were liable to pay Rs 13,80,000/- i.e. Rs Thirteen Lakhs Eighty Lakhs only. Out of which

you had played advertisement for value Rs 2,36,456/- (Rs Two Lakhs Thirty Six

thousand Four Hundred Fifty Six only). Therefore outstanding on your account is Rs

11,43,547/- (Rs Elevan Lakhs Forty Three thousand Five hundred forty seven).

7. My client requested you to pay the due bills time to time. However you have not paid the

due remaining amount.

8. That I therefore by this notice I address you to pay an amount of Rs 11,43,547/- (Rs

Elevan Lakhs Forty Three thousand Five hundred forty seven) only within 15 days from

receipt of this notice. Failing of which my client shall be constrained to initiate legal

action against you, which includes defamation, cheating criminal breach of trust and

civil, criminal and other relevant provisions as per law.

9. That this notice is sent to you for your breach of your commitments, hence cost of this

notice of Rs 5,000/- is placed upon you.

Date

Place Advocate for