Ref. No. ADV-GUNJAN/RUBI-AJEET/138-N.I.

A/2023-24 Dated: 15/03/2023

REGISTERED A.D. /SPEED POST/ WHATSAPP

To
Mr. Ajeet Gautam
R/O:-41 JAI SHREE COLONY,
SHASTRI PURAM ROAD AGRA,
BICHPURI AGRA,UTTAR PRADESH-283105
Mob. No.:-8535004605

Subject: Legal notice under Section 138 Negotiable Instruments Act, 1881

Dear Sir,
I have been instructed and authorised by my client Ms. Rubi Devi, W/o
Subodh Paswan, R/o Mohammadpur, Jharsa, Narsinghpur, Gurugram,
Haryana-122004, to serve you the legal notice and the present notice is
without prejudice to the rights of my client and my client reserves her right
to make necessary amendments/ clarifications at any, initiated against
you ,the notice, and also raise any such other/further claims against you in
succeeding paragraphs:
1. That my client is the resident of the above-said address and a law –
abiding citizen who has never been involved in any criminal and
immoral activities whatsoever.

2. That you, the addressee, is the well- known personality in the

vicinity of Fatehpur, Agra, Uttar Pradesh and you always visited
regular basis on the work place of my client’s husband i.e FCI
Warehouse (Godam) Fatehpur.

3. That my client’s husband was working as a labour in FCI Warehouse

(Godam) from 2015 to 2021. That you, the addressee, took my

Chamber No. 123, Shahid Bhagat Singh Block, District & Sessions Court, Gurugram (Hr.)
Ph: 9582240279, 9818077868 Email: adv.gunjan83@gmail.com

Page 1 of 5
 client’s husband in your trap and demanded of Rs. 16,00,000/-
(Rupees Sixteen lakhs only) to get my client’s husband a permanent
Government job. You tricked my client’s husband that nothing was
kept in the labour job of this FCI Warehouse (Godam), and you said to
my client and her husband that they just arrange the money , and you
will get my client’s husband a Govt Job.

4. That in order to get a permanent Government job for her husband, my

client and her husband fell in your spell, and when my client and her
husband came under your false pretence, my client took loan from
her relatives, women’s group Banks and selling her jewellery article,
it is pertinent to mention here that my client is totally doomed to
arrange the above said rupees 16,00,000/- (Rupees sixteen lakhs
only). My client has given total cash sixteen lakhs till November 2020
to you.

5. That when you the above named addressee took rupees 16,00,000/-
(Rupees sixteen lakhs only) from my client , you started to showing
your true colours and intentions, you started abusing my client’s
husband and threatening to get him fired from the labour job of the
FCI Warehouse (Godam), it is pertinent to mention here that you the
above named address knew your deception, and you are doing this
because you know that if you did not provide Govt Job to my client’s
husband, they would demand their hard-earned money Rs.
16,00000/- (Rupees sixteen lakhs only)

6. That when my client and her husband started talking to you the above
named addressee regarding the Govt Job , you started threatening
them more, and when my client told you that if you can’t get the job
for them, then return their hard earned money. But when my client
started asking for money again and again, first you threatened my
client and her husband, but when you thought that they might
complaint about your cheating , then you started giving them false
assurance that you will give their hard earned money.

7. That in order to fulfil your liability you, the addressee, issued three
cheques in favour of my client after repeatedly demanded back the
money given for her husband’s Govt. job and said that you can
withdraw the money by depositing the cheque. The details of the
cheque are as follows:

Chamber No. 123, Shahid Bhagat Singh Block, District & Sessions Court, Gurugram (Hr.)
Ph: 9582240279, 9818077868 Email: adv.gunjan83@gmail.com

Page 2 of 5
 a. First cheque bearing no. 082310 on dated 30/12/2022 of Rs.
3,00,000/- (Rupees Three Lakhs only)
b. Second cheque bearing no. 374641, on dated 21/01/2023 of Rs.
3,00,000/- (Rupees Three Lakhs only) cheque bearing no.
000001 on dated 24/02/2023
c. And last cheque bearing no. 000001 on dated 24.02.2023 of Rs.
3,00,000/- (Rupees Three Lakhs only) banker Kotak Mahindra
bank

8. That when my client deposited this above-said last cheque bearing

no. 000001 dated 24.02.2023 of Rs. 3,00,000/- (Rupees Three Lakhs
only) in her account with Bank of Baroda, to the great dismay of my
client the said cheque also got dishonoured. That my client received
return memo dated 27.02.2023 with specific comment of “PAYMENT
STOPPED”.

9. That you, the notice, were not diligent, serious or responsible on

your part to return amount. That my client tried to communicated
with you, the addressee, several times, but you, the addressee, paid a
deaf ear to it and didn’t fulfil the legal obligation, due to which my
client is running from pillar to post in order to recover the hard-
earned money of my client.

10. That it is apparent on the face of it that you have been deliberately
avoiding to fulfil your legal obligation with a view to cheat by not
returning the hard- earned money. Further, your mala-fide and ill
intentions have caused immense financial loss as well as mental
torture to my client. Hence, in utter disregard to my client’s interest
and rights, you have wrongfully and illegally refused /failed to comply
your obligation and liabilities. Further, you the addressee,
fraudulently took services from my client with no intention to return
her hard –earned money.

11. That after repeated requests on the part of my client, you addressee
delaying the matter on false and frivolous pretexts without any
reason or rhyme and thereby intentions of you addressee are clear,
that you addressee having malicious intent to usurp the above
mentioned payment.

Chamber No. 123, Shahid Bhagat Singh Block, District & Sessions Court, Gurugram (Hr.)
Ph: 9582240279, 9818077868 Email: adv.gunjan83@gmail.com

Page 3 of 5
 12. That you addressee are lingering the matter on one pretext or the
other and my client was forced to run from pillar to post to get back
the above said payment.

13. That you addressee willfully, knowingly and intentionally are not
paying the above said amount to my client despite the fact that there is
no mala-fide intention on the part of my client. You addressee in
order to cause unlawful loss to my client and to cause unlawful gain to
yourself.

14. That you, the addressee, are lingering the matter on one pretext or
the other and my client was forced to run from pillar to post to get
back the amount. That by deliberated and intentional act of yours, you
are illegally withholding the hard- earned money of my client, which
shows your malafide intention to usurp the above mentioned entire
amount which is detrimental for my client. Further by your deliberate
act you are also liable to prosecuted for the criminal breach of trust
which is an offence under the criminal law.

TAKE NOTICE

Now under the circumstances, I hereby call upon you to make payment of
sum of Rs. 16,00,000/- (Rupees sixteen lakhs only) along with interest 9%
p.a, within seven days of receipt of this notice either by cash or through
demand draft, failing which my client has instructed me to necessary civil
and criminal action against you in the competent court of law and in the
event you, the addressee, shall be liable for all cost and consequences
resulting therefrom along with civil and criminal liabilities.

Conduct yourself accordingly.

I have retained copy of this legal notice in my office and you addressee
advised to keep the original intact to enable my client to get the same
produced from you in the Court of law, if need may arise.

Chamber No. 123, Shahid Bhagat Singh Block, District & Sessions Court, Gurugram (Hr.)
Ph: 9582240279, 9818077868 Email: adv.gunjan83@gmail.com

Page 4 of 5
 GUNJAN BHARDWAJ
ADVOCATE

Chamber No. 123, Shahid Bhagat Singh Block, District & Sessions Court, Gurugram (Hr.)
Ph: 9582240279, 9818077868 Email: adv.gunjan83@gmail.com

Page 5 of 5