To,

1.Abha Arya
X198, Regency Park 2,
Near Galleria Market
DLF Phase 4, Gurgaon-122002

2. Vibha Seth

X198, Regency Park 2,

Near Galleria Market
DLF Phase 4, Gurgaon-122002

3. Madhu Arya

X198, Regency Park 2,

Near Galleria Market
DLF Phase 4, Gurgaon-122002

Dated : 10/05/2022

SUB.: Notice for repayment of loan amount of Rs. 55 Lacs taken on 22 nd

November 2019 and refilling of divorce on agreed mutual terms.

Dear Ma’am,

This legal notice is been sent, pursuant to the instructions from and on behalf of my
client, Mr. Anshul Jain ___________________R/o __________________________, I
do hereby serve you with the following legal notice: –

1- That my client Anshul Jain is individual under the name and style of M/s
______________________.
2- That my client is engaged in the business of __________ of the ___ etc.
3- That you have been married to my client on _______________ and other two
persons namely Vibha seth & Madhu Arya are your Sister & Mother,
respectively.
4- That this loan amount was originally requested by Vibha & Madhu and was
initially very promptly rejected by my client.
5- That you having speculated the response to the loan request by my Client,
had already hatched a conspiracy with your Mother & Sister, to extract the
amount on the pretext of loan without having any intentions to return it back.
6- That you emotionally manipulated by client and blackmailed him into
transferring the said amount into your personal bank account.
7- You went on to such an extent that you even threatened to divorce him if my
client fails to give you and your relatives the said amount of 55 lacs.
8- That you even went on to state that if my client cannot support your family
members by giving him the said amount, then he should also forget to get
any mercy at their hands and should not blame you, if you and your family
members do not let my client meet their children, in an event, you decide to
divorce my client and move out with the kids, namely, Madhu & Vibha, into
your parents house.
9- That my client, having been subject to continuous ongoing matrimonial
dispute with you since 2017, in an attempt to safeguard his already troubled
marriage and to be nearer to his children succumbed to the illicit demands of
you and your immediate family members.
10-That it was promised by you at the time of taking this loan amount that the
said shall be returned by you, your mother Madhu and your sister, Vibha, on
a no interest basis within a period of 1 year and was jointly and severally
responsible for the said amount.
11-That my client was not financially sound at that vey instant and in order to,
do away with your constant threats of separating away from him alongwith
the kids made him to transfer 55 Lacs from a business proceeds that was yet
to be finalized.
12-That it is already in your knowledge, that above-stated business transaction
of my client fell into a legal dispute, of which you were also one of the co-
accused.
13-During the inquiry in FIR no. 22/2020, PS Sector 53 conducted against you as
well as my client, you had clearly stated that the said amount has been taken
as a loan by you and your blood relatives and in no manner concerned with
the business deal.
14-That despite repeated requests made by my Client, neither you nor your
sister and mother had not shown any intentions of returning the loan amount
to my Client.
15-That your ill-intentions have been made clear by the averments pleaded by
you in the divorce proceedings, filed just after 8 days from the date on which
you received the said amount of 55 lacs, against my client, wherein you have
stated that the loan amount was given to you as part of mutually decided
alimony.
16-It is categorically stated that you never had the intention of returning the
money and have always found different excuses for not returning the amount.
17-That because of the failure to repay the money by you and your relatives, my
client has suffered enough, both physically and mentally.
18-That despite blackmailing my client into giving you loan of 55 lacs, you have
abstained from fulfilling promise on your part and at present not even
allowing my client to meet his kids.
19-That you dishonestly refused to let my client meet his kids despite claiming
the said loan amount to be treated as a one-time full and final alimony.
20-That despite my client admitting to all your emotional blackmailing and upon
the promised made by you to my client, that if this loan amount is set-off as a
alimony in your favour, then you will not dispute the custody of child and you
will follow a co-parenting model for the kids where my client will be allowed
to meet their kids on weekends.
21-That despite constantly fulfilling all your demands, you went on to file a
contested divorce and didn’t even allow my client to his daughter on his
birthday. You have stooped so low, that when my client sent birthday cake
 and few gifts to his daughter, you not only threw the cake and gifts but also
didn’t even let my client talk to his daughter on her birthday.
22-That neither you have fulfilled your promise to return the money nor you
have complied with the promises made by you, if this loan amount if treated
as alimony.
23-That act committed by you is liable to be penalized under section 406 & 420
of the Indian Penal Code, 860 for dishonestly extracting money from my
client.
24-That in spite of acknowledging the liability of payment of principal balance of
₹ 55 lacs you have been miserably failed to make payment of the said
amount due to my client from you deliberately with an intent, hence you are
liable to pay the said principal balance amount.
25-That my client requested you several times through telephonic message and
by sending a personal messenger to your office for release of the said
outstanding payment, but you have always been delaying the same on one
pretext or the other and so far have not paid even a single rupee out of the
said outstanding undisputed amount.
26-I, therefore, through this Notice finally call upon you to either pay to my client
₹ 51 lacs, together with notice fee of ₹ 5500/- to my client either in cash or
by demand draft or cheque, whichever mode suits you better, within a clear 7
days from the date of receipt of this notice, failing which my client has given
me clear instructions to file civil as well as criminal lawsuit for recovery and
other miscellaneous proceedings against you in the competent court of law
and in that event you shall be fully responsible for the same.
27-That on the alternative, since you claimed this loan amount to be treated as
alimony in the divorce proceedings, you are suggested to withdraw the
contested divorce filed by you and file a mutual divorce in accordance with
the promise made by earlier, of letting my client meet his children on
weekends. This will also have a good impact on kids as they will then be co-
parented by both mother and father.
28-A copy of this notice has been preserved in my office for record and future
course of action.
(____________) ADVOCATE