(Opening statement for prosecution: Aashish)

Council seeks the permission to address the bench as lordship

My lordship my name is aashish dutta representing the plaintiff in this case singer consultants pvt ltd

The plaintiff asks that the defendant company winsoft telecommunication pvt ltd be held liable for
breach of contract

As the facts of the case clearly show that the contract was terminated 18 months prior to completion of
locking period.

The Defendant Company Signed the lease agreement for the property Jubilee Plaza owned by the
Plaintiff Company. The property was one of the Plaintiff Company’s high-end properties and its rent was
Rs. 2,00,000 per month. The lease agreement was signed after several rounds of negotiations and had
the standard terms and conditions, involving what is commonly known as 'Lock-in-Period', which is a
contractually agreed minimum tenure as well as a three month security deposit which would be
forfeited in case of a breach of contract.

* The Defendant Company vacated the premises before the end of the Lock-in Period which constitutes
a Breach of Contract u/s 73 of the Indian Contract Act 1872. The grounds given for the breach by the
Defendant Company cannot hold as they wanted more space to expand their business and shifted
elsewhere immediately in 5 days. This is supported by the judgment K Narayana Kurupu
Sankaranarayanan (AIR 2000 KER 296) where it was held that ‘when a contract is broken, the party who
suffers by such breach is entitled to receive compensation for any loss or damage caused to him by the
party who has breached the contract’. The Defendant-Company’s inability to honour the terms of the
agreement also violate Section 37 of the Indian Contract Act of 1872. The spirit of Section 37 also stems
from the legal maxim ‘pacta sunt servanda’, which translates to ‘agreements must be kept’.

* The Plaintiff company is entitled to claim the lease fee or rent for the remainder of that Lock-in Term,
which is 18 months rent, with 18% additional interest on the same. Also, the Plaintiff is fully entitled to
forfeit the 3 months security deposit as they have committed a breach of contract first.

* The legality, validity, and enforceability of a lock in period clause was ascertained in a Single Judge
Bench of the Delhi High Court in Satya Narain Sharma (HUF) vs Ashwani Sarees Private (2009 ILR 4 Delhi
601). Specifically, the judgment speaks of parties coming to an agreement with ‘eyes wide open’ and
consciously choosing to include and agree to a lock-in period, and there is no reason as to why they
should not be held to the terms of their agreement. The text also significantly notes the lock-in period is
a dual protection for both the lessee and lessor, as the lessee gets protection from eviction for the
extent of the lock-in period, and the lessor gets a guaranteed minimum income.

* The counsel for the plaintiff also avers that the unpaid rent constitutes a ‘debt’ with in meaning of
Sections 433 and 434 of the Companies Act of 1956.

my lordship the counsel has summed up the opening statement and request defence counsel to proceed
with their opening statements

(Opening statement of defence by alagu)

(Examination in chief of Varun singer- by pushp)

Counsel seeks permission to examine prosecution witness no.1 u/s 137 of Indian evidence act.

Q1- For the record of the court, would you please identify yourself?

A1- My name is Varun singer, I am the managing director of singer consultants pvt. Ltd.

Q2- In what capacity are you related to the property in question?

A2- I own this property in the name of my company mentioned earlier.

Q3- Will you please describe this property in brief?

A3- This property by the name Jubilee Plaza is situated in 14 old road, Delhi. It is one of the most
expensive and exquisitely designed properties i own.
Q4- How did you come in contact with the defendant company?

A4- I received a call from Ms. Neena Elizabeth, she “expressed” her desire to rent this property.

Q5- Please inform the court as to how and under what circumstances was the deal finalised?

A5- She wanted to sign the lease deed as soon as possible without even visiting the property.

Q6- Are you saying the deal was finalised even without visiting the premises?

A6- As per our company’s policy she was required to visit the property before signing the lease deed.

Q7- Did she examined the premises what was her feedback?

A7-Ms. Neena was reluctant at first but on my insistence she visited the property with her manager.
Both of them found the property suitable for their purpose.

Q8- When was the lease deed formulated?

A8- We signed it on 12th September 2016 and they shifted to the property by 15th September 2016.

Q9- What were the contents of the lease deed?

A9- The deed contained-

(i)monthly rent of 2 lacs in addition to 8000 for parking space.

(ii)security deposit equivalent to 3 months rent liable to be forfeited in case of breach of contract.

(iii) it also contained a lock-in period of 3 years.

(iv) property would be maintained by my company.

Q10-What was the response of Ms. Elizabeth after shifting in the said premise?

A10-On 20 sept. 2016, I introduced my manager to ms. Neena, she was quite pleased with her new
office and gave a positive feedback.
Q11-Even after such a positive feedback, why was your company served with a termination letter?

A11-On March 25 2018, I received the termination letter, reason stated therein was limitation of space,
it was too small to cater their current and future needs.

Q12- What were the demands of defendant company in termination letter?

A12- they wanted us to adjust the 3 months security for the notice period from April to June.

Q13- What was your response of the termination letter dated 25th March?

A13- This letter was unacceptable to us as it illegally terminated the lease during the lock in period and
therefore they are required to pay the rent for this period and security is liable to be forfeited due to
breach of contract.

Q14-Was their any formal communication after this termination letter?

A14- we received a legal notice on 26th April.

Q15- Please explain in brief the contents of the legal notice of 26th April.

A15- the notice raised grievances regarding maintenance and alleged a breach of contract by us.

Q16-Has the defendant company ever raised any of these concerns prior to the notice of 26th April?

A16- this was the first time I heard about these issues because the property was repaired and
maintained at regular intervals.

Q17-Please tell the court about the events after 26th April.

A17-on 1st sept. 2018 there was a joint inspection and the premises were in a good condition, just as it
was handed over to the company.
No further questions my lordship. I request the defendant counsel to proceed further.

(Cross examination of Varun singer- by Vivek)

1.How long have you been in this business?

- Quite a few years.

2. Is it correct to say that ,The property in question is your most expensive and exquisitely designed
property?

-Y

3.Such an exquisitely designed property a lot of people must be looking to lease it out , correct?

- Y,

4. Is it correct to say that you are aware of know how’s of how to lease out a property?

-Y

5. Is it true that multiple rounds of negotiations were held before the signing?

-Y

6. The final lease deed was a very detailed as it contained clear provision, even regarding rent for
parking and nothing was left to presumption, correct?

-Y

7. Is it true that during these several rounds of negotiations, the lock in clause and penalty for
termination during that time was discussed?

-Y

8. Is it true that the deed doesn’t contain any provision for penalty or liquidated damages?

-Y
9. So it is correct to to say that the penalty clause was left out after due consideration?

-Y

10. Can it be assumed that your maintenance department failed to inform you about the complaints
that were raised?

-N

11 .Is it true that a 3 month termination notice was provided to you?

-Y

12.Is it true that purpose of this 3 month termination period is to give you enough time to look for new
tenants?

-Y

13. Did you make any attempts to look for new tenants?

-Y

14. Can you provide any proof that you tried looking for new tenants?

-N

15. According to your statement the property remained unitized and unproductive for rent till feb when
a new client approached you?

-Y

16. Is it possible that it was unproductive because of the maintenance issues?

-N

17. So you are saying you tried but couldn’t find a tenant for your most exquisitely designed property
from April last year to february this year i. e 10 months?

-y
(Examination in chief of sunny Singh- Aashish)

My lordship I would like to call sunny singh to the stand.

Q1) Please introduce yourself to the court:

my name is sunny singh aged 35 and a resident of flat no. 12, medium apartments delhi and I'm
employed with singer consultancy from the past 8 years as a manger of their properties.

Q2)What is your relation to the property in question:

I have been managing jubilee plaza since August 2016

Q3)When was the property leased out to the defendant company :

Jubilee plaza was leased out to winsoft telecomunication in September 2016 and they shifted to the
property by mid of the month.

Q4)How was Ms. Elizabeth's feeling according to you about moving into the new office:

She seemed excited.

Q5)How did you find Mr. Krishan's attitude?

He seemed to be a trouble maker as he went on complaining about everyone to Ms. Elizabeth.

Q6)What conversation did you have with Mr. Krishnan in December 2018?

He told me how the business was running very well and they decided to employ more staff.
Q7)Did Mr. Krishnan complain about anything?

No not at all. Neither did I receive any intimation from Ms. Elizabeth about any problem.

Rather I received positive feedback from everyone and hence communicated the same to Mr. Singer

Q8)How was your reaction when you got to know about the termination of lease deed by the defendant
company?

I was astonished because no one from winsoft telecom had ever told us about any problem.

Q9) Have you seen the notice yet?

Yes I have seen the notice and can confirm that all the allegation therein are false. Common area has
never faced the problem of water logging or poor lighting. Neither have there been any complaints from
any other occupants in this property.

Q10)What do you think is the reason behind them terminating this lease?

They only want to shift to a new place in order to accommodate more staff which they cannot at this
property.

I Conclude my examination my lordship

Thank you my lordship

(Cross examination of sunny Singh- by alagu)

1. Generally, How many properties do you look after at a time? 2

2. How many right now? Only 1

3. Why is it so? Bcoz it’s a huge complex

4. That means it’s your only workplace right now? Yes

5. From your first impression, did you see Sooraj as a troublemaker? Yes

6. What actions of Sooraj gave you this impression? He kept on complaining about everything

7. Did Sooraj admit before you that their business is running well while they were in Jubilee Plaza? Yes

8. Then what do you think be the reason for Winsoft to vacate this property? Bcoz they employed more
staff so it is unable to accommodate

(Examination in chief of Neena- by alagu)

Examination in chief

1. Can you please take your name for the Court? Neena Elizabeth

2. What do you do? Managing Director of WinSoft Telecommunications Pvt. Ltd.

3. How are you related with the property in question? The lease deed was signed on 12 September,
2016 for the monthly rent of INR 2L and security deposit of INR 6L between Singer Consultant and
Winsoft Telecommunications.

4. Who is responsible to take care of maintenance of the property according to the lease deed? It was
the responsibility of Singer Consultants Pvt. Ltd to maintain the property, for which they billed us the
maintenance charges, and WinSoft Telecommunications Pvt. Ltd. has duly paid all the charges is billed.

5. Did the lease deed have provision of lock-in period? Yes the lease deed contained a lock-in period of
3 years.

6. Did it contain any provision regarding damages? No the lock-in period clause did not provide for any
penalty or liquidated damages in case WinSoft Telecommunications Pvt. Ltd. terminated the lease
within the lock-in period. This was done deliberately after negotiations, and with the consent of
Mr.Singer and his company.

7. Who was the authority from your side for that office? Mr. Sooraj Krishan, is the manager for that
office.

8. What were the problems you faced related to this property? Within few days of my return, I received
calls from Sooraj about the problem with the central air conditioning of the premises, which was not
working properly. He also informed me about the poor state of the maintenance of the property
which was having issues of water logging and bad lighting in the common areas. He further informed me
that the maintenance department of Singer Consultants Pvt Ltd. was not sorting out the issues, even
after repeated requests.

9. What was the effect of these problems on your business? Our clients frequently visit the office and
such poor maintenance was creating embarrassment to our company and was damaging the reputation
of the business. We could not hold business meetings at the premises or accommodate employees due
to these maintenance issues.

10. What was your side reaction for this? My company spent money out of its own pocket to install air
conditioning unit and to carry out other repair works, which were the responsibilities of Mr. Singer and
his company.

11. Then Why did you decide to leave the property? Being fed up with all these issues.

12. Did you take any step from your side? WinSoft Telecommunications Pvt. Ltd. sent a three month
notice through courier on 25 March, 2018 to Singer Consultants Pvt. Ltd. terminating the lease deed
with effect from 30 June, 2018. We requested Singer Consultants Pvt. Ltd. to adjust the rent for the
months of April-June, 2018 against the security amount deposited in the beginning.

13. Then when did you hand over the possession of the property? On March, 2018
14. Did they try to look for a tenant after that? No, upto February, 2019 they didn’t.

15. What’s your final take on this case? I underwent immense mental trauma and financial loss during
this time while dealing with SC. I believe in Justice. Hope the truth triumphs.

(Cross examination of Neena- by pushp)

My lordship, prosecution counsel seeks permission to cross examine the defence witness

Q- You’ve stated that you were looking for a spacious property. Is that true?

A- yes

Q- Do you admit it was you who first approached the plaintiff to lease out the property?

A- yes

Q-Is it true that you liked the property instantaneously when you visited it?

A- yes

Q- Did it cater all your needs and requirements?

A- yes

Q- Can this be said you did a thorough inspection of property before signing the lease deed?

A- yes

Q-Were there any relevant facts and information concealed or manipulated by the plaintiff?

A- not that I’m aware of

Q- Was the agreement signed by you with full consent and free will?

A- yes

Q- Can this be said that you were well aware of the contents of the lease deed and clearly understood
it?

A- yes, I clearly understood it.

Q- Was Maintenance of the premises the legal duty of the plaintiff as per the deed?

A- yes, it was mentioned in the deed.

Q- And due to the alleged poor maintenance your company borne the expenses of maintenance. Is that
true?

A-yes, that’s true.

Q- But you still duly paid the full maintenance charges. Why is that so?

A- yes.

Q- Since you understood the contents of the deed, could it be said that you were aware of the lock-in
clause?

A- yes I was aware of it.

Q- As per the deed, would the non compliance of lock-in clause amount to a breach of contract?

A- yes.

Q- Is it also true that the lease was terminated during the subsistence of the lock-in period?

A- yes, it was.

Q- Does this mean that the termination amounted to a breach?

A- Maybe.

Q- Letter of 25th March stated lack of space to cater your current as well as future needs. Is that true?

A- yes. That’s true.

Q- Haven’t you already stated that the property suited your purpose and only after this you finalised the
deal?

A- yes.

Q- So you were not able to anticipate your future needs and expansion plans before signing the deed?

A- yes/ maybe

Q- Should the plaintiff suffer due to your lack of care and farsightedness?

A- No.

(Examination in chief of Suraj- by Vivek)

Q-Please state your name and job for the record.

_ I am Sooraj Krishan, i work as a manager for win soft telecommunications ltd.

Q - How long have you worked for them?

- Since inception

Q Thats a long time. So Ms. Neena. must really value you for the business and listen to your advice.

- I was appointed to look after the new expansion i. e Crown plaza so i believe she does.

Q- How did you like the property in question when you saw it?

I thought it was small and rent was too high.

Q- Did you also think it wouldn’t able to cater to your future needs?

- not just future needs but i believed it was small for our current needs as well.

Q- Why did you continue for 2nd a half year before leaving then?

- Because we signed a contract and we don’t deal bad faith as a company.

Q- What kind of problems did you face during your tenure there?

there was problem of water logging and lighting . The air conditioning unit also used to malfunction
frequently .

Q- What did you do about it.?

-I complained to Mr. Sunny singh personally and maintenance department of singer consultant
regularly.
Q- How often did you make these complaints and how did mr Sunny take them.

- whenever there were issues i told, mr sunny who was usually present at the site. But he always gave
me a cold shoulder and went around calling me notorious for doing my job with due diligence and
pushing him to do his.

Q- Were there any other measures taken from your side to resolve these issues.

- Air Conditioning was something which we could have resolved as tenants as other issues like water
logging and lighting were structural, so we paid and brought a new one.

Q If we go through your company record books, will we find proof?

- Yes you will

Q What happened in March 2018 that you decided to leave abruptly .

- Our business started taking a heavy toll because of poor maintenance. A few of our clients who had
raised issues before now refused to come to our office all together and others threatened to leave us.
Had we continued to operate there we would have gone out of business and would have had to shut the
Delhi branch all together.

Q- Why should the court believe that this wasn’t just a move to save money and move to a new place
since you never liked this place?

We stayed there for 2 and half years and were always prompt in our duties. We were required to give a
notice of 3 months during which we were entitled to stay at jubilee plaza. But when our clients started
threatening to leave us we had to take an immediate step which is relocate within 5 days . We paid rent
for 3 months equaling 6 lakhs coupled with rent for the new place. Had it been about the money we
could have stayed there and saved lakhs of rupees in the process.

Q- Why did you file a legal notice on after giving the notice for termination of lease..
- We were not planning on filing anything as we thought that we have readily given up our our security
deposit of 3 months equalling 6 lakhs as a sign of friendly gesture and things would be resolved
amicably. But when Mr Sunny taunted us that they won’t even look for a new tenant till September as
they will extort the money from us using bogus claims, we realized he is likely to deny we ever made any
complaints to him regarding maintenance so we had that take the legal recourse.

Q- Did they look for a tenant after you left.

NO, they did not. it was only after new tenants approached them in feb that the property was occupied
again.

(Cross examination of Sooraj krishnan- by aashish)

Q. Are you the Office Manager at the Delhi Branch of the Defendant-Company?

A. Y

Q. Is it your testimony that you inspected the premises BEFORE the lease was signed?

A. Y

Q. Are you also the Managing Director of the Defendant-Company?

A. N

Q. Is your name on the lease agreement on the side of the Defendant-Company?

A. N

Q. Is it your testimony the property was too small and the rent was too high?

A. Y

Q. Is it your testimony that you conveyed the same to the MD of the Defendant-Company BEFORE the
signing of the lease agreement?

A. Y

Q. Did the MD of the Defendant-Company finally listen to your advice?

A. N
Q. Is the MD of the Defendant-Company, your immediate employer, bound to listen to and act on your
passing opinions?

A. N

Q. It is your testimony that you repeatedly MADE complaints regarding maintenance of the property to
the Plaintiff-Company. Can you say with ABSOLUTE certainty that they RECEIVED and RESPONDED to
your complaints?

A. N

Q. Have you expressly mentioned this in your written testimony?

A. N

Q. You requested the MD of the Defendant-Company to send notice to terminate the lease agreement
and send a legal notice to the Plaintiff-Company. Is the MD of the Defendant-Company, your immediate
employer, bound to take action on unsolicited advice given to her by her employees?

A. N

Q. Do you think as an Office Manager, you know better than the MD of the Defendant-Company in
making integral decisions regarding the functioning of a large and complex company?

A. N

Q. It is the testimony of Ms. Neena Elizabeth that her company sent 3 months notice to the Plaintiff-
Company on the 25th of March, 2 years ago. Is it your testimony then that you vacated the premises and
shifted to a new office a mere 5 days later, on the 30th of March?

A. Y

Analysis: May it please the Court, Counsel for the Plaintiff humbly submits that the testimony of Mr.
Sooraj Krishan is as irrelevant as it is unreliable. Mr. Sooraj Krishan neither knows the particulars of the
lease agreement nor can he point to any clause for maintenance within it. Mr. Sooraj Krishan is not privy
to the details of the agreement because he is a mere Office Manager, and hardly has a finger on the
pulse of the actual reasons for Defendant-Company’s citing non maintenance of the premises to
constitute breach of contract. The Defendant-Company has attempted to distract the Court and Plaintiff-
Company by using the false excuse of non maintenance of the premises when in fact their reasons for
doing so were to terminate the lease while avoiding costs in damages for terminating before the expiry
of the 3 year lock-in period, and move to a location more suitable to them. Mr. Krishan himself has
unwittingly exposed the pre-planning on the Defendant-Company’s part by admitting to the short gap
between sending the notice (25th March 2 years ago) and vacating the premises (30th March 2 years
ago), as it is extremely difficult to search for a new office location, decide on the same, then come to an
agreement with the other party, and then pay the initial amount all within a span of 5 days. The move
on the Defendant-Company’s part was clearly pre-conceived, and casts a large amount of suspicion as to
whether their intention was to see out the extent of the lock-in period in the first place.

Counsel for the plaintiff rests my lordship

(Closing statement of prosecution by pushp)

My lordship, the counsel seeks permission to present its closing statement-

Firstly, Ms. Elizabeth has testified that there was a lock-in period and she was aware of it and very well
understood it. She has also admitted that the termination letter was served to the plaintiff during the
subsistence of the lock-in period and as per the lease deed which was signed by Ms. Elizabeth with her
free will, this action was non compliant with the conditions of the deed and it amounted to a breach of
contract.

That being said, counsel would like to bring to the notice of this honourable court an authority of
Bombay High court, in INDIABULLS PROPERTIES V. TREASURE WORLD DEVELOPER 2014, the court
categorically held that contractual provisions in a leave and license agreement for a lock-in period is not
per se illegal, unlawful, void or even voidable. It’s a common business practice in rental business.
(Emphasis supplied). It is mutually understood to mean that both parties cannot terminate the lease
unilaterally before the lock-in period expires.

S-42 of specific reliefs act, gives the power to this court to compel specific performance of the negative
part of the agreement, which in this case would be the responsibility to not terminate the lease before
the lock-in period.

Furthermore. S-30 of the specific reliefs act, states that, On adjudging the rescission of a contract, the
court may require the party to whom such relief is granted to restore, so far as may be, any benefit
which he may have received from the other party and to make any compensation to him which the
justice may require.
Secondly, The counsel then deems it appropriate at this stage to mention some of the loopholes in the
fabricated story of the defendants that the lack of corroboration from other occupants of jubilee plaza
regarding the ill maintenance as well as no records whatsoever of any such previous complaints from
any other occupants.

It is pertinent to mention that jubilee plaza is one of the most expensive and exquisitely designed
properties of plaintiff, is an undeniable fact.

The defendants claim to have borne the maintenance expenditure which was the responsibility of the
plaintiff but the evidence on record shows that they have duly paid the full maintenance charges till
date. Counsel would like to bring to the notice of my lordship that the general business practise is to
forfeit the amount of maintenance expenditure incurred by the lessee before paying the maintenance
charges to the lessor.

At this point, it is pertinent to know that the legal notice of 26th April was the first time when the
grievances of poor maintenance was raised, and this contention never found any mentions in the
termination letter of 25th March. The termination letter only consisted of one reason that is, limitation
of space to cater their current as well as future needs, the sworn testimony of the defence witness 2, Mr
Krishnan also corroborate this, as he specifically told to Ms. Elizabeth that this premise was too small for
their needs.

Considering all these contentions, there is only one logical explanation that after realisation that the
building would not suffice to fit in new staff and cater their future expansion, the defendants terminated
the lease during lock-in period, which amounted to a breach of contract, and to escape the liability of
such breach, they have fabricated false claims against my client which the defendants have failed to
establish.

Lastly, regarding the forfeiture of security deposits, the plaintiffs are well within their rights to forfeit the
security because the lease deed clearly stipulates the forfeiture in case of a breach of contract, and it
has been sufficiently established above that there was a breach of contract by the defendant company.

And hence, the same should not be adjusted as the rent for the notice period of April-June. What the
plaintiff seeks is to get its rightful claim and not to extort money from the defendants, this contention is
warranted by the authority of Bombay high court judgement in CORPORATE MANAGEMENT COUNCIL V.
CRAWFORD BAYLEY AND CO.

Counsels appearing for the plaintiff humbly pray your lordship to bring justice to them, and In
conformity with the laws and legal precedents cited above, allow the plaintiff’s claim for rent from April
2018 till the unexpired lock-in period along with an 18% interest p.a. till the date of payment so as to
ensure timely payment of the same. Or pass any other order, decree which your lordship deems fit in
complete dispensation of justice.

Prosecution rests its case and request opposite counsel to proceed for their closing statements.

(Closing statement of defence by Vivek)

May it please the court?

your honour kindly allow me to make a brief and distinct submission as part of my closing statement.

one of the most basic principle of law is he who comes into equity must come with clean hands.

maintenance of the property for proper functioning of the business was an important part of the lease
deed and thus an essential part of the contract. the amount for such maintenance was specified and
paid regularly. as a defence of shown singer consultants failed to maintain the property even after
repeated requests and my client even had to pay from their own pockets. this is a clear case of prior
breach of contract and therefore no liability arises on my client whatsoever.

secondly multiple rounds of negotiations took place before finalizing the deal and during these
negotiation lock-in period was discussed at length multiple Times as shown during the proceedings. so it
is clear that the provision for penalty was left out deliberately. after such detailed discussion no prudent
man can presume any liability for termination of the lease during the lock in period would arise.

Mr. singers attorney kept stating that are requirement of space fell short for our needs and that is the
real reason for sending the termination notice. in defence against this I would like to point out that we
continued occupying the property for two and half years and duly fulfilled all the duties. it was only
when the clients started threatening us to leave and my clients business was put into jeopardy because
of poor maintenance on the behalf of plaintiff that we had to take immediate steps to move out. my
client moved out within 5 days and paid the rent for Jublie plaza for 3 months without even occupying it.
Simultaneously they paid rent for the new property as well. anyone looking to expand would not move
out in such a hurry and incure such a huge loss in the process.
my lord section 73 of the Indian contract act dealing with loss or damage caused by breach of contract
provides for one prove that there was actually loss and secondly it places a duty on the plaintiff to take
steps to mitigate the losses

also according to the legal president set in towervision India private limited versus procall limited , "A
mere breach of contract would not entitle one to claim damages."

the opposition council has failed to prove both.

after telling the court that Jubilee plaza is the most expensive and exquisitely designed property and the
number of tenants are always lined to rent it, they did not find a new tenant for 10 whole months.

the only logical explanation for this is that they did not try to look for a tenant or the property was unfit
for the purpose of renting due to maintenance issues.

it would be against the principle of natural justice to punish my client for or something which was
deliberately left out of the contract and secondly for the wrongs done by mister singers company.

my client has already suffered a dent in her reputation , harrassment and mental stress coupled with
payment of 600000 rupees as rent without even occupying the jublie plaza.

if anyone should be claiming damages it should be my client.

therefore my client please your lordship to bring justice to miss Mina and dismiss the plea raised by Mr
singer.