P.

YUVARAJ
ADVOCATE Office :: No. 160, G-9, Hussain Plaza,

MADRAS HIGH COURT Thambu Chetty Street, Parrys,

Chennai – 600 001.

Mobile:: 7358339842

To, Date ::

Mrs. Saroja,
Old Door No. 16/1, New Door No. 39,
Market Lane, Royapuram,
Chennai – 600 013.

Subject :: LEGAL NOTICE –REG

Under the instruction from my Client Mrs. S. Nirmala, W/o. Mr. Selvakumar,
aged about ----- residing at Door No. 24/2, Market Lane, Kalmandapam,
Royapuram, Chennai- 600 013, I issue this notice to you as follows,

1. My clients states that she is engaged in the business of ---- and known to
your brother namely Mr. R. Jothi, S/o. Ramanujam, aged about ----
residing at Door No. 16/1, Market Lane, Kalmandapam, Royapuram,
Chennai- 600 013 for the past ---- years.

2. My clients states that In the month of June, 2013 your brother Mr. Jothi
requested me to give sum of Rs. 3,00,000 or above as hand loan since he
was in dire need of money for emergent financial need of his family.
 Subsequently after several request made by your brother, in the name of
humanity my client gave him sum of Rs. 3,30,000 (Three lakhs and thirty
thousand Rupees) by pledging jewels/ from her own saving/ from her
hard earned money and he was also borrowed 2 sovereigns of Chain with
heart shape dollar and 4 ½ sovereigns of Chain which was also recorded
in the deed and agreed by your brother Mr. Jothi and duly signed in an
ON DEMAND PRO NOTE (i.e agreement dated 01.08.2013) and the
same was also witnessed by,
1. Stephen Sagayaraj S/o.
2. Suguna, W/o.

3. My Client states that Mr. Jothi executed promissory note for the said
amount in favour of my client on 01.08.2013 and he was also agreeing to
repay the said amount of Rs. 3,30,000/- with interest at the rate of 3%
(i.e. Rs. 3/- for every Rs. 100/-) to my client or his order on demand. My
client further states that He also promised that he would return the
jewellery and money received from my client on the said date without
any delay and withdraw this Deed of Debt dated 01.08.2013.

4. My Client states that your brother paid a sum of Rs. 9,900/- as interest for
a period of 6 months without any default. Subsequently, thereafter your
brother became irregular after the said period of 6 months. In spite of
repeated requests and demands were made to your brother to make the
payment but your brother failed to make the payment of Rs. 3,30,000/-
and its interest Rs. 9,900 per month in time. In these circumstances my
client met your brother in person and demanded your brother several
times to make the payment of the outstanding amount which is lying
against her but your brother on one pretext or the other avoided to the
 legitimate requests of my client without any cause or reason and has
stopped the payment of the my client.

5. My client states that on-------, your brother came to my client’s home,

promised and also made an oral agreement that he will settle the entire
debt amount by selling his part in the joint property of house and ground
in Old Door No. 16/1, New Door No. 39, Market Lane, Kalmandapam,
Royapuram, Chennai- 600 013 with an extent of 582 sq ft., in this your
brother’s share is ------ sq ft.

6. My client states that your brother agreed that he will repay the said debt
after selling his part in the joint property which belongs to,
(i) Mrs. Saroja
(ii) Mrs. S. Neelavathi
(iii) Mr. R. Jothi
(iv) Mrs. T. Shanthi

7. My client states that after the oral agreement my client have not requested
him to repay the said amount since he made a promise come oral
agreement that he will settle the entire amount after selling his part in his
joint property house and ground in Old Door No. 16/1, New Door No. 39,
Market Lane, Kalmandapam, Royapuram, Chennai- 600 013 with an
extent of 582 sq ft., in this your brother’s share is ------ sq ft.

8. My client states that to shock and surprise your brother Mr. Jothi died on
------. Subsequently after the death of your brother, there is no Class I
legal heir for him and you were the Class II heirs of him u/s. 8 of Hindu
Succession Act, 1956. In such circumstances you were legally bound and
liable to repay the debt amount of your brother as his legal heirs.