Advocate Sana Parveen

CHAMBER NO.14,SK GARG LAWYER CHAMBERS, SUPREME COURT OF INDIA

, NEW DELHI-110001,
Mob. No. 9717460151 , 9312246175
E-mail: Sananoah007@gmail,com
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Ref No:- Dated: 11th November, 2023

LEGAL NOTICE

THROUGH SPEED POST/EMAIL/ WHAT’S APP

To,

Mr. S. Parvinder Singh

S/o Lt. Sh Ranjit Singh,

R/o BC-5 Shalimar Bagh,

West Delhi, 110008.

Subject: - Reply to Legal Notice

Dear Sir,
1. We are in receipt of the aforesaid notice issued by you in connection
with the subject matter cited hereinabove and in reply thereto, we have
to place before you the facts mentioned hereinafter in the form of
reply cum grievance.
2. The cited notice is received by us on 7th November, 2023 via Post. I on
behalf of Mr Praveen Kumar S/o Sh. Ram Swaroop, House No. 74
street No. 4 Karawal Nagar Extension, Delhi 110094. have also
acknowledged the receipt of the same.
3. At the very outset claim made by you seems to be false, frivolous,
baseless and devoid of merits and filed with mala fide intention to
harass and extort and grab money from our company. The entire story
created by you is fabricated and concocted and same is not acceptable.
4. You have levied baseless and false allegations with ulterior motive
against us. The claim of yours deserve to be dismissed.

5. With reference to para 1, My Client denied approaching you for the

sale of the Plot Purchased by him in Rohini Residential Scheme 1981,
by the Delhi Development Authority. That my client informed you
that he was assigned priority number 4944, against which an allotment
cum demand letter in the year 2014 was issued to my client by DDA
Alloting him Plot No. 2773 admeasuring 26 sq. meters situated at
Pocket C-1, Sector 34 Rohini, Delhi, in confidentiality in reference to
this, nothing withstand to your false allegations towards my client in
your claim.
6. With reference to para 2, due to mis-information/incomplete
communication by you to us, made us face a lot of shack and uncalled
repercussions as you stated my client that you will help him in getting
the possession from DDA as my client being a poor and ill-educated
person played by your foul play.

7. With reference to para 3, the allegations are baseless, fraud, frivolous

with malafide intentions to usurp the plot from my client on such a
nominal price, as my client unaware of the Fraudulent activity done by
you behind the back of my client, for which legal actions are
considered to be taken against you.

8. With reference to para 4, The information given in good faith by my

client is matter of facts and should not be used against him in any
scenarios, my client denied making such assurance of sell the plot to
you.
9. With reference to para 5, several details were concealed by you and
did not revealed or intimated us even after several calls and follow ups
for the same. As you promised my client to assist him in handling the
matter of possession in favour of him, it is true to say that several
documents were handed over to the concerned person, intentionally,
which included bank challan and original demand letter by DDA for
the same and got signed in the “Bayana Receipt” fraudulently.

10. With reference to para 6, except from few confidential details

everything is well and explained by us and also the position can be
seen clearly. As condition of the my client does not look good on the
papers and you are trying to benefit from the situation, in reference to
this, nothing withstand to your false allegations towards my client in
your claim.

11. With reference to para 7, that my client have not signed any agreement
in his memory that you have forged the documents against my client
in order to achieve unjust gains for the best reasons known to you.
Also you transferred Rupees 30,000/- as an NEFT transaction, as soon
as you realized that my client is aware of your actions and going to
take actions about your fraudulent practice to frame him and usurp the
plot. As my client does not have access to his account transactions and
lives 6 days out of his home because of work, since had no knowledge
of any monetary payment made to him, also he’s ready to give it back
and no need such money from you.
12. With reference to para 8, That my client went to the Police Station
shahbad Diary to inform for the same as soon as he realized about the
fraudulent practices done by you and it took a reasonable time for him
to get the FIR registered. At the time of filling the FIR my client had
no information about receiving any payment through any mode. That
it appears that in order to cheat and defraud my client and without
any intention on your part to help him, You used his innocence
against him and trying to implicate him for the same which amounts
to mental harassment and defamation.
 Under these circumstances, I am instructed to call upon you, which
hereby I do and therefore instruct you to desist from sending any kind
of such notice to arise a dispute or else we shall be left with no other
option than filing a suit against you for defamation and mental
harassment.
For which you will be held liable for all costs and consequences which
please take note Kindly.

You are also liable to pay cost of this notice to my client i.e. Rs.51,00
(Fifty one hundred Rupees Only/-) on instructions of our client.

Date: 11th November, 2023 SANA

PARVEEN

(Advocate)

14, SK GARG
CHAMBERS,

SUPREME COURT OF
INDIA

DELHI 110006
.