To

SHRI PINKU DEY

S/O -Late Jagneshwar Dey
R/o- Parvati Path,Via Ashok path
Mohan path,Kadma Bhatia Basti
P.O+P.S-Kadma, Jamshedpur-831005
Jharkhand

Sub : Legal Notice Under section 406,420 IPC

Dear Sir
Under instruction and on behalf of my client Mr.Anthony Kevin Ryan , S/o-
Benjamin Ryan,and Mrs,Dimitilla Ryan ,W/o- Anthony Kevin Ryan ,R/o- Flat
st
no-D-1,1 Floor ,Mittal Apartment,B-block, Bhatia Basti ,uliyan ,Kad,ma ,P.o
+P.s0 Kadma, Jamshedpur ,East singhbhum ,Jharkhand do here by serve you with
the following notice-
1. That my client stated that you both know each other since long .

2. That on basis of it . upon conversing you noticee offered own have a land
for sell. The same ,my Client decided to buy aforementioned land.

3. That on 4th June 2022 you had entered into a Agreement to sell your Raiyati
land where you mentioned you are absolute and lawful owner of the Raiyati
landed property which is situated of Mouza Uliyan. Bhatia Basti ,Thana
No- 1158, P.S- Kadma, recorded Khata No-11 bearing R.S
 Plot No- 1176 within the Jurisdiction of Jamshedpur District East
Singhbhum, you executed the agreement to sell in the presence of witnesses
thereof the same day.

4. That the sell consideration amount of the above mentioned land was
settled at Rs. 50,00,000/- (Fifty Lac Rupees only). Out of the total sale
consideration ,you have received the Advance amount of 15,00,000\-
(Fifteen lac Rupees only) from my Client and executed the agreement of
sell.

5. That after it has came to the knowledge of my client that your are trying
to sell the aforesaid land property by manipulating ,forging some false
documents illegally ,dishonestly ,fraudulently and in gross violation of
the term in which the property you were never the absolute owner of the
aforesaid land property, that you have no right to deal in any way before
Registry and mutation of the name of seller of the said property.

6. That it has come in notice to my client that you have you have cheated,
forged in the following manner –

# there is no where entered agreement on 13 june2022.

# As on 4th june 2022 you had entered into agreement ,you have mentioned
as which purchase by the first party (Sri Pinku Dey) by executing the sale
agreement on dt 03/11/1992 and the 1st party in peaceful possession of the
same property. It was totally false statement.
You noticee have again given new plot number aforesaid property which
is 2271,which has been mutation in the name of Shri Ram Rati Chatterjee.
# nd
As 22 Nov 2022 you had entered into agreement, you noticee refunded
only 12,00,000/- by deducting 20% of the advance amount i.e 3,00,000/- (
Rs. Three Lakh only)which left amount out Advance Money.

7. That at the time entered into agreement ,you were fully aware that you have
made forged documents.

8. That you are further requested to refer the attached documents in

Annexure 1,2,3, proving the fraud and cheat on your part.

9. That you notice do not want to return rest amount Rs 3 lac only of my
client intentionally and deliberately and wants to grab the money of my
client ,which was received by you as earnest money.

10.That thus you are liable to return the rest advance amount to my client .

I, therefore, through this legal notice call upon you noticee to receive the
balance advance amount which 3 lakh from my client and to return 3 lakh
along with future interest @ 20% P.A from the date of notice. That my
client mentions that if you fail to comply with your legal obligations as
has been pointed out to you through this Legal Notice, my Client will be
left with no alternative but to approach the judicial forum for redressal of
aforementioned grievances at your sole risk and peril.

Advocate