J a i d e e p Malik & A s s o c i a t e s

US,' Punjabi Baqh Enclave 1

JAIDEEP MALIK Shiv Mandir Road,
Advocate West Punjabi Ba4h,
Supreme Court. of India New Dolhi-63i
Delhi High Ccur.L Mob: 9811106556, 9311106556
D/1151/1995
Dated:: 08.06.201Z_ S P E E D

POST/COURIER

Sh. Narender. alias Kala

S/o Lte Sh. Mahender Singh R/o >> i 1
lage Neelwal,
Post Tikri Kalan,
De1!A1-110041

LEGAL NOTICE FOR ILLEGAL OCCUPATION AND FOR M E S N E .

P R O F I T I N C A S E O F N O N E V I C T I O N O F PROPERTY OF ANKIT
KUMAR.

Sir,
Under instructions: from and on behalf of my
clients Ankit Kumar S/0 Late Sh. Dhan
Singh, R/o H.No/Kh.NO.201 Village Neelwal, Post Tikri
Kalan, Delhi-110041, I do hereby serve upon you with
the following legal notice:-

1. That the My . client is owner of land/built

. up
property of Khasra No.201, of the area 0-18 Biswas,
s i t u a t e d i n V i l l a g e N e e l w a l , Post Tikri Kalan, in
Tehsil Punjabi Bagh, Delhi-1100041, the copy of
the r e p o r t o f P a t w a r i a n d a s p e r c o p y o f K h a u t a n i
i s s u e d by Patwari showing the m y c l i e n t a s o w n e r /
Khatedar of the above said property has b e e n
r e t a i n e d i n m y o f f i c e f o r f u r t h e r proceedings
as and when required and a c c o r d i n g t o t h e s a m e
m y c l i e n t i s . t h e share holder/owner of half of
the property
 of Khasra No.201 of area 0-18 biswas and
whereas his uncle Sh. Sandeep is the share
holder/owner of half of the property of
Khasra No.201 of area 0-18 biswas'situated
in Village Neelwal, Post Tikri.Kalan, in
Tehsil Punjabi Bagh Delhi-110041 and . West
Portion of this Khasra has come to the
shre of my client by way of a family
s e t t l e m e n t . •
2. That 'my client is ,residing in the
same
village and has given various. rooms on
rent to various tenants and the said
tenants are regularly paying the rent of
their respective rooms.
3. That it is matter of record that you
the noticee is also in the occupation. of
one room in the area which comes to share
of my client, but you are not paying any rent
or mesne profit to my client since last
two years when my client became major and
started looking afte'r his properties.
4. T h a t i t h a s c o m e t o t h e k n o w l e d g e o f
my client:that in the past with . ulterior
motives you alOngwith one Pradeep had
tried to make constructions on the land
near your room without seeking permission
from the family members of my client and
you were restrained from doing such
illegal acts with ulterior motives and
were also evicted from there in the year
2013 and thereafter, you the noticee was
evicted and the same was admitted by - you
even before the court during litigations.
5. That despite being evicted you the
noticee i s n o t h a n d i n g o v e r t h e l o c k a n d
k e y ' o f the room to my client and during
last two years whenever my client required
you the noticee to pay him the charges for
the use and occupation of the said
premises you avoided the same on the
pretext that some suit is to be decided

6. That you the noticee has no_ right to

remain in deemed possession of the
between you and the family members of my
client.
 of Khasra No.201 of area 0-18 biswas and
whereas his uncle Sh. Sandeep is the share
holder/owner of half of the prciperty of
Khasra No.201 of area 0-18 biswas's,ituated
in Village Neelwal, Post Tikri .Kalan, in
Tehsil Punjabi Bagh Delhi-110041 .and West
Portion of this Khasra has come to the
share of my client by way of .4a family
settlement.
2. That 'my client is residing in the
same
village and has given various' rooms on
rent to various tenants and the said
tenants are regularly paying the rent of
their respective rooms.
3. That it is matter of record that you the
noticee is also in the occupation. of one
room in the area which comes to share of
my client, but you are not paying any rent
or mesne profit to my client since last
two years when my client became major and
started looking afte'r his properties.
4. That it has come to the knowledge of my
client:that in the past . with . ulterior
motives you alOngwith one Pradeep had
tried to make constructions on the land
near your room without seeking permission
from the family members of my client and
you were restrained from doing such
illegal acts with ulterior motives and
were also evicted from there 'in the year
2 0 1 3 and thereafter, you the noticee was
evicted and the same was admitted by - you
even before the court during litigations.

5. That despite being evicted you the

noticee is not handing over the lock and
key'of the room to my client and during
last two years whenever my client required
you the noticee to pay him the charges for
the use and occupation of the said
premises you avoided the same on the
pretext that some suit is to be decided
between you and the family members of my
client.
6.That you the noticee has no, right to
remain in deemed possession of the
 3

property of my client without paying the

occupation charges and hence you are in
illegal possession in the property of my
client and are occupying the property of
my client through illegal means. and.the
same shows that you have developed
malafide intentions and ulterior motives
with regard to the property of my client,
as you are not handing over the of
the rooms to my client.
7.That you are enjoying the property of my
client by way of illegal means and my
client is at liberty. to initiate proper
legal action against you and your above
said conduct has made you liable to be
dealt with strictly and .my client is at
liberty to file suit for damages/mesne.
profit as well as • to get an F.I.R.
registered .against you for illegally
occupying his 'property since last two
years.
8. That you the notio.ee after
having I
developed illegal designs : • and malafide
in tentions have forcibly and without the
consent and Wishes of my client, occupied
the room of my client and you the noticee
has no right to occupy the same and rather
the same is a criminal offehce and my.
client is at liberty to get an FIR
registered against you the notiCee.
That now. my client does not wants to keep
y(7 , 11 the noticee in the :..room of his
property in any manners ;And you are
immediately requirgd to vacate the room
ii -Hr the convenience of my client.as the
r c i o m if given on rent like any other
property are likely to attract a rent of
PE.;.5,000/- per month like other properties
which are given on the rent and hence; you
are causing a loss of Rs.5,000/-'per month
to my client and since you are in use and
occupation of the property of my client
sincelast two years you are liable to pay
a sum of Rs.1,3g10.00/- for illegally using
 the property of my client for the last two
years and in case of non payment of the
same it would be considered that'you are
trying to usurp the legitimate dues of my
client and in the past. have also
demolished the structure tried to raise
illegal constructions on the property of
my client which is a criminal offence for
which you are liable to dealt with
strictly and the same would attract an
F.I.R. against you in case the offence is
further repeated and it is further made
clear that my client does not wants you to
remain in possession of the above said
property and in c a s e y o u s t i l l o c c u p y . t h e
property of my client you are illegal
occupant and as such, you should handover
the keys to my client.

TAKE NOTICE that I hereby call upon you

the noticee through this legal notice to vacate
and handover the keys of two rooms situated in
Khasra No.201, Village Neelwal, Delhi to my
client within one month from the receipt of
this notice, failing which I have d e f i n i t e
instructions from my client and I am
constrained to take the appropriate action .

against you before the competent court of law

including getting : an FIR registered against
you, at your risk,• costs and consequences as
well as penalties and the conviction thereof,
as envisaged in the statutory law as well as
Indian Penal Code.
•

TAKE FURTHER NOTICE that you ar . e•..hereby

-
called upon, through this notice tooRay . a sum
of Rs.1,30,000/- to my client for using and
occApying the premises of my client since last
twc. years.
TAKE FURTHER NOTICE that you • are hereby
ca]]ecl upon, through this notice Co pay a sum
of *i:::i.5,000/-- per month as the mesne profits
wh:h' my client 'would have earned, failing
wh:h. I have definite instru;'4ions from my
clrit and I am constrained to take the