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Bhanu Pratap Singh Ch.

No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001

12/05/2023
REGISTERED POST/ SPEED POST
To
Nazma Bano,
D/o- Samshuddin,
R/o- Chotpur Colony,
Near Abubakr Mosque,
Sector- 63, Noida, UP.
LEGAL NOTICE

Madam,
Under the clear instructions from and on behalf of my
client Sh. Aavid khan S/o. Sh. Fakhruddin khan, R/o. House No.
2153, Gali No 19/28, Block- I, Ratia Marg, Sangam Vihar, New
Delhi- 110080; I, undersigned, do hereby serve you the
following legal notice, the contents of which are set forth herein
below:-
1. That you were married with my client on 5th December
2022 at Chotpur Colony, Sector 63, Noida, UP (Near
Abubakr Masjid), according to Muslim rites and
ceremonies in the presence of friends, relatives, and family
members of both the parties.
2. That after the marriage you and my client lived together as
husband and wife and cohabited with each other at House
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
No. 2153, Gali No- 19/28, Block- I, Ratia Marg, Sangam
Vihar, New Delhi- 110080.
3. That at the time of solemnization of this marriage, there is
no demand of dowry or any article whatsoever on behalf of
my client. The amount for Mehr was fixed as Rupees
11786/- only (Elevan Thousand Seven Hundred Eighty Six
Rupees Only).
4. That you stayed with my client at your matrimonial home
at the above mentioned address at Sangam Vihar, New
Delhi only for a month between the 5th December, 2022 till
the 9th January 2023.
5. That on 9th January 2023 you left your matrimonial home
without the permission of your husband i.e. my client and
even without informing him that you were leaving your
matrimonial home and you left the matrimonial home in
the absence of my client without his consent.
6. That on 9th January, 2023 your brother Mustaq abused and
scolded the sister of my client, Shahnaj Bano and insulted
her but you did not interrupt and not even try to stop your
brother.
7. That on 9th January 2023 you have deserted my client and
left your matrimonial home without any sufficient reason
whatsoever on the instigation of your family as your
brother namely Mustaq and his wife Saina came in my
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
client’s house in the absence of my client and without his
permission and without any information to him.
8. That you have taken all the jewelry of my client kept in his
custody without his permission on 9th January 2023.
9. That you start troubling my client in various ways and
whenever my client tried to pacify you, then on the advice
of your brother you insult my client by abusing and
threatening him to slap and implicating him in false
criminal case.
10. That your attitude towards my client was very rude and
indifferent from the very beginning and it has not changed
despite my client tried his best fulfilling all your legal
demands from time to time.
11. That your brother mustaq has threatened my client with
dire consequences if my client has taken to you in his
native village but you did not utter any single word against
your brother.
12. That your brother Mustaq insulted my client in numerous
occasions but you always remain silent. On 9th April 2023
when your brother Mustaq abused, slapped, pushed &
thrashed my client in the Gali no 19/28, Sangam Vihar,
New Delhi, 110080 and you came to know about this
incident by my client and other person then you did not
care of it, not even after complaining to you by my client.
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
13. That on 11 April, 2023 you told my client that if he was
th

interested to live in this relationship then he would have to


bear all these sufferings because ‘you are not a Hindu wife
so that you have to obey your husband’.
14. That my client, Aavid khan is continuously receiving
threats from you that you will commit suicide and you will
kill herself so that my client may be implicated in any false
criminal case of dowry demand, cruelty and/or abetment to
suicide.
15. That my client Aavid khan could not join his work place
for 17 days because of your threat and face dire
consequences.
16. That you threatened my client that you will send my client
to jail at any cost even framing my client in any false case
of abetment to suicide by killing herself or making suicide.
17. That you were troubling my client by harassing him after
making mobile calls to unknown persons at late night.
18. That your brother Mustaq also abused and threatened my
client on phone call on 9th April 2023.
19. That my client, Aavid khan is continuously receiving

threats from your brother Mustaq and other family


members and associates namely sameer khan and ansar
that they may kill my client as they are threatening him for
taking his life or face dire consequences.
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
20. That on 9 January 2023 you and your above said brother
th

Mustaq and sister-in law Saina are black mailing my client


and his family members by asking 10 lacs rupees or a plot
otherwise my client will face dire consequences.
21. That you have deserted my client on 9 th January 2023

without any valid reason and returned back to your


matrimonial home on 11th April 2023 for harassing and
torturing of my client and his family members.
22. That it is said that out of the said wedlock of you and my
client, you got conceived and have pregnancy of 5 months
still you are not living peacefully with my client and don’t
escape any opportunity for picking a quarrel.
23. That on 24th April, 2023, a common relative of both the
sides namely Mr Sahid Khan came to the house of the
petitioner at Sangam Vihar to get understand her that how
to live in house after marriage but you did not understood.
24. That on 29th April, 2023, you left your parental home at
Noida and without the consent of my client, even after
refusing to go there as they did not invited your husband
and in laws family still you left parental home and
attended the marriage at Village Runkata, Agra, UP.
25. That on 1st May 2023, you again visited a village Junesar
at district Mainpuri without any information to my client
and his family.
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
26. That you are roaming here and there without the consent
and permission of my client and your behavior is troubling
my client and creating cruelty upon my client.
I, therefore, call upon you through this legal notice
that either you will stop insulting, abusing, maltreating and
misbehaving with my client and also stop threatening to
commit suicide and also implicate my client in a false
criminal case or to execute the divorce deed and papers
etc. for initiating the dissolution of this marriage within a
period of 15 days from the date of receipt of this legal
notice, failing which my client will constrained to file
appropriate proceedings against you in the court of law and
in that event you shall be responsible for all costs, risks
and responsibilities which you please note well.

You are also liable to pay Rs. 21,000/- towards the cost
of this legal notice.
A copy of this legal notice is retained in my office
for record and further necessary action.

Bhanu Pratap Singh


Advocate
Supreme Court of India
supremecourtadv@gmail.com
Bhanu Pratap Singh Ch. No
416,
Advocate New Lawyers’
Chamber,
D/1868/2011 M.C. Setalvad
Block,
Mb: 8383850121 Supreme Court of
India,
supremecourtadv@gmail.com New Delhi-
110001
Mb: 8383850121

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