LAL CHAND VERMA & RAJAN VERMA

ADVOCATES,

Chamber No. 114, Ground Floor, Yadavindra Lawyer’s Complex,

District Courts, Patiala. (M.No. 98155-10678, 98159-12180)
Office-cum-Resi: # 5085, Phase-I, Urban Estate, Patiala. (Pb.)

To

Sh. Sandeep singh kaura, Managing director, Shri Balaji literary and
charitable society, Rayat Bahara group of institutions, Affiliated to MRSPTU,
Bathinda, Patiala Sangrur National highway, Village bherpur, district
Patiala.

SUBJECT :- LEGAL NOTICE

Sir,
I have instructions from my client Ms. Gurpreet Kaur D/o Sh. Bhag
Singh # 59,Chinar Bagh, Phase 2,near Punjabi University, Patiala, to serve
you with following legal notice:-
1. That my client had served your institute as an Assistant Professor
with sincerity and dedication in the department of computer science
at Rayat Bahara group of institutions, Patiala.
2. That my client was issued appointment letter on 31/08/2017.
3. That initially the services of my client were on adhoc basis till
30/04/2018 only, but Later on due to her good performance you
continued with her services even after 30.4.2018.
4. That my client was continuously serving your institution with
dedication and sincerity but the conduct and behaviour of the
management towards my client was not appropriate. She was not
treated with respect and was not paid salary on time. At times when
my client wanted to resign from her job due to above reasons your
management threatened, coerced and intimidated my client by
pressurizing her to continue her services with the institute. It was
under compelling circumstances my client had to submit her notice to
resign by stating the personal problem and it was not possible for her
to render her services, considering this situation she tendered her
notice to resign from the post of assistant professor. The said notice
was duly served upon the campus director, Rayat bahara group of
institutions, Patiala campus on 21/05/2019 by my client.
 5. That my client was relieved from her services on 12/06/2019 and a
relieving letter in this regard was issued to her 11/07/2019.
6. That in this regard an information letter regarding the good conduct of
my client and period of services rendered by her with you was issued
by you on 11/07/2019.
7. That even after serving the institution to the best of her ability my
client was not treated by you and your officials with respect and
humbleness.
8. That it is unfortunate and disgraceful on your part that on one count
you claim your institute to be one of the finest educational institute
where the education is priority but on the other count you are
disrespecting, disgracing, maltreating and misbehaving with the
faculty which is expert in their respective fields and you never care for
them mentally and financially. Your disrespectful behavior has led to
mental stigma on my client and she is unable to concentrate on her
studies due to the treatment given to her by your officials.
9. That during her service with you, you have failed to pay the salary of
my client on time and whenever she demanded it, you postponed the
matter on one pretext or the other.
10. That you have not even paid her the security deposit standing credited
to her name till date.
11. That my client has following balance outstanding against you:-
Sr. no. Particular Month /year Amount in Rs.
1 Security deposit 21600/-
2 Salary Nov. 2018 21600/-
3 Salary Dec. 2018 21600/-
4 Salary Feb. 2019 21600/-
5 Salary April 2019 21600/-
6 Salary May 2019 21600/-
---- ------ Total due Rs. 1,29,600/-

Interest To be calculated
accrued on remittance.

12. That my client has approached you many times after being relieved
from services for claiming her salary and security deposit which is her
 legal right and you have got a corresponding duty/liability to pay the
same but you have failed to pay the same till date.
13. That even during meeting with the Principal, Engineering Department,
Mr. Sandeep Sharma which was called to discuss regular issues of the
faculty members, your officials conducted the meeting in a sarcastic
manner while insulting my client along with her peers.
14. That after being relieved my client visited the institution for claiming
her dues, the concerned officials of your institute misbehaved with my
client and threatened her not to come to the campus again for claiming
her salary as she will not get the same. Even the said officials used
abusive language with my client. My client reserves her right to sue
those officials separately in another litigation.
15. That as you have failed to remit salary and security deposit of my
client in time and you have misappropriated the salary of my client and
converted it to your own use, you are liable to face criminal as well as
civil action as per the procedure prescribed under law if you will not
remit the salary of my client within the time provided under this notice.
My client is also entitled to interest accrued on the amount pending
against you which is also claimed by my client through this notice.
Therefore, this notice to you is served for 15 days wherein you are asked to
remit the salary as well as the security deposit with interest of my client in
her account or in any other manner of remittance, failing which my client
shall be constrained to file civil as well as criminal proceedings against you
and you will be held liable for all the litigation expenses incurred thereon by
my client.
No word is vague therein
Note: - A copy of this legal notice has been retained in my office for record
and further action.
DATED 23/09/2019
LAL CHAND VERMA & RAJAN VERMA
ADVOCATES
DIST. COURTS, PATIALA