Jahnavi Gopaluni, Associate, ABC Law partners

Sarojini Nagar, New Delhi, 500032

Shraddha Das,

Green Hills, New Delhi, 367712

Priyanshu Saklani,

Red street, Gurgaon, 1222678

Subject: Legal Notice for Cruelty under Section 498A of the Indian Penal Code

Dear Priyanshu,

I, Jahnavi Gopaluni, representing Shraddha Das, hereby serve this legal notice to bring to your attention the
grave matter of cruelty perpetrated against my client, Ms. Shraddha Das by you, Mr. Priyanshu Saklani. This
notice is issued in accordance with the provisions of Section 498A of the Indian Penal Code and seeks to
address the unlawful actions and consequences thereof.

Background:

1. Ms. Shraddha Das and Mr. Priyanshu Saklani were married on 21/07/2020 in Goa. A copy of the
marriage certificate is enclosed herewith as Annexure A.

2. Following the marriage, Shraddha has been subjected to relentless acts of cruelty by you, Varun.

3. These acts of cruelty have caused severe mental and physical trauma to Shraddha, leading to an
irreparable breakdown of the marital relationship.

Instances of Cruelty:

a. On [12/09/2021], at approximately [9:30 am], at your residence, you physically assaulted Ms. Shraddha,
by repeatedly hitting her, causing severe injuries to her face and body. And later when my client tried to
move out of the house, you apologized by assuring that it would not repeat.

b. On [17/10/2021], at approximately [18:10 pm], at a park nearby your house, you subjected Ms. Shraddha
to verbal abuse, demeaning her character and hurling derogatory remarks at her in public.

c. Repetitive verbal abuse to my client and her family has happened throughout the year 2022.

Legal Consequences:

1. The aforementioned acts of cruelty are in violation of Section 498A of the Indian Penal Code, which
criminalizes cruelty by a husband or his relatives towards a married woman.
 2. Section 498A imposes penalties on those found guilty, including imprisonment for a term that may
extend to three years and/or a fine.

Demand:

1. I hereby demand that you immediately cease all acts of cruelty, harassment, and abuse against Ms.
Shraddha.

2. You are further required to provide a written undertaking within 14 days, from the date of receipt of this
notice, assuring that you will refrain from engaging in any further acts of cruelty against Ms. Shraddha.

3. In the event of your failure to comply with the above-stated demands, my client reserves the right to
initiate appropriate legal proceedings against you, seeking appropriate remedies, including but not
limited to filing a criminal complaint under Section 498A of the Indian Penal Code.

Please be advised that any further communication in this matter should be directed to my office. Failure to
comply with this notice may result in legal action being taken against you without further notice.

Yours sincerely,

Jahnavi Gopaluni, Associate, ABC Law partners

Enclosures:

 Annexure A: Copy of Marriage Certificate