Preliminary Draft for Discussion L&L Partners Law Offices

Attorney – Client Privileged August , 2021

[On Letterhead of L&L Partners]

THROUGH COURIER & E-MAIL

August ____, 2021

To,

Passionate Futurist Solutions Pvt. Ltd.,

DLF Galleria, Room No: DK1405,
Action Area 1, Newtown,
Kolkata, West Bengal - 700156
Mob: +91 8420202891

Subject: Legal Notice for recovering the principal amount paid for developing an
e-commerce website.

WITHOUT PREJUDICE
Dear Sir,

Under instructions from and on behalf of Our Client, Basic Attention, having an office at
New Shivpuri Colony, South of Aerodrome, Tilkamanjhi, Bhagalpur, Bihar – 812001,
represented through its proprietor Mr. Akash Aryan (“Our Client”), we, hereby serve you
with the present legal notice, contents of which are as under: -

1. Our Client is a proprietor firm engaged in the business of Marketing and Sale of Men
Clothing Merchandise, such as Shirts, T-Shirts, Trackpants, Shorts etc. It was
established in the year 2020 and has a prospering business ever since. In a very short
span of time, Our Client has managed to make its name in the clothing industry and
has built a very strong presence on certain e-commerce giants, like Amazon.

2. That in order to boost the online sale of its goods with customers and augment the
presence of its business in the internet world, Our Client had decided to obtain an e-
commerce website for the business under its own name. It was further expected that
the presence of wholly-owned personalized website for the business will strengthen
the brand and enable Our Client to sell online their goods directly with their
customers without any indulgence of an intermediary in their business. It will also aid
them in learning more about their audience and allow them to personalise the website
at their own will to get in terms with the demands of their customers. Henceforth,
with the purpose of getting their e-commerce website developed, Our Client,
approached you, the addressee namely, Passionate Futurist Solutions Pvt. Ltd.; an
Online Marketing Company in Kolkata, providing a variety of marketing services like
Digital Marketing, Graphic Design, Web Design, App Development, Website
Preliminary Draft for Discussion L&L Partners Law Offices
Attorney – Client Privileged August , 2021

Development, Content Writing etc.; on [Insert date] by a reference of a mutual

friend, Mr. Sandeep Dutta. Our Client availed the Web Development Services offered
by you, the addressee, wherein Our Client requested you, the addressee to develop a
website for its business with all the requisite details to be incorporated in it as
specified by Our Client.

3. That you, the addressee agreed to develop a professional e-commerce website for Our
Client for a consideration of INR 25,000/- (Rupees Twenty Five thousand). Our
Client acceded to the amount demanded and gave its approval to you, the addressee
for commencing the work of development of their brand’s website. It was assured to
Our Client that the website developed by you, the addressee will define the brand of
Our Client and increase products or services demand through a customer-
centric and data-driven approach. The said work was guaranteed to be
completed and shared by you, the addressee, on [Insert date]. However, the same
was not done on the stipulated date. Our Client contacted you, the addressee on
numerous occasions for sharing the website told to be developed for the expansion of
its business, but there was no response from your side.

4. That on [Insert date], you, the addressee was able to share the details of website with
Our Client. However, Our Client was appalled to see the sub-standard quality of
website developed by you, the addressee. It was jerry-built and not fully completed.
Some of the basic details like [Insert the details] were missing in it. Henceforth, Our
Client tried contacting you, the addressee umpteen times through phone calls and
WhatsApp to know the rationale behind the sharing of such a shoddy quality of
website. . However, to Our Client’s dismay, you, the addressee neither picked up any
of the phone calls made nor replied to the WhatsApp Messages sent by Our Client
seeking justification for such a poor quality of service from your end. The details of
follow-ups happened on Phone & WhatsApp on [Insert dates] are as follows:

a. [Insert the details of phone calls and WhatsApp messages]

b.
c.

5. Kindly note that Our Client had paid the entire sum of consideration, i.e. INR 25,000/-
(Rupees Twenty Five thousand) at once for the development of their website to you,
the addressee in a bonafide belief on [Insert date] via [Mention the mode of
payment] because you, the addressee was referred to Our Client by a mutual friend.
However, Our Client never knew that you, the addressee will breach their trust and
never complete the work undertaken. The said inaction on the behalf of you,
addressee is malafide and bad in law. In fact, such an omission of providing service
on the part of you, the addressee makes make it abundantly clear that you, the
addressee engaged in criminal acts of fraud, cheating, criminal breach of trust,
amongst others. Please take note that these are criminal offences which are punishable
Preliminary Draft for Discussion L&L Partners Law Offices
Attorney – Client Privileged August , 2021

under the provisions of the Indian Penal Code, 1860 and we have specific instructions
to initiate appropriate criminal action against you the addressee.
6. That, in the light of above, you are hereby called upon to return the principal amount
of INR 25,000/- (Rupees Twenty Five thousand), paid by Our Client on the account of
developing an e-commerce website for them, along-with an interest of [Insert
Interest]. per annum. You are also called upon to pay a sum of [Insert Cost] towards
cost of issuance of the present legal notice. Kindly note that the same should be acted
upon within a period of 15 days from the date of receipt of the present notice failing
which we have specific instructions to initiate appropriate civil as well as criminal
proceedings against you, the addressee which will be at your sole cost and peril.

A copy of this communication is retained at our office for further reference and future action.

Yours sincerely,

L& L Partners
Law Offices