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LEGAL NOTICE To, 1. June 08, 2010 M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt.

Ltd.) 9, Kasturba Gandhi Marg, New Delhi Delhi-110 001 Mr. Ravinder Kumar Taneja Managing Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) 9, Kasturba Gandhi Marg, New Delhi-110 001 Mr. Kamal Teneja Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) 28, Prithvi Raj Road, New Delhi-110 011 Mr. Devkinandan Teneja Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) 28, Prithvi Raj Road, New Delhi-110 011 Ms. Renu Taneja Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) 9, Kasturba Gandhi Marg, New Delhi-110 001 Mr. Gobind Ram Gogia Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) A-13A, Green Park Main, New Delhi-110 016 Mr. Mohammad Yusuf Khan Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) S-378, Panchsheel Park, New Delhi-110 017 Mr. Harish Suri, Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) 2/78, Punjabi Bagh Extension, New Delhi-110 026

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Mr. Omesh Saigal, Additional Director M/s. TDI INFRASTRUCTURE LIMITED (Formerly known as Intime Promoters Pvt. Ltd.) N-130-B, Panchsila Park, New Delhi-110 017

10. Smt. Balvinder Kaur R/o. C-18 Greater Kailash Enclave I New Delhi-110048 Sir(s), Under instructions from and on behalf of my client Mrs. Usha Dhingra, W/o late Mr. R.K. Dhingra, resident of 774 Saraswati Vihar, Housing Board Colony, M.G. Road, Gurgaon, Haryana, we hereby serve you with the following legal Notice: 1. That our client is a housewife and due to the sad demise of her husband in January 2005, she decided that she would invest her money in some project as a source of income that would generate some income for her life time. 2. That you the addressee No. 1 is a duly incorporated and registered company engaged in the business of real estate development and the addressee No.2 is the Managing Director of the addressee No.1 and addressee Nos. 3 to 8 are the Directors and addressee No.9 is the additional Director of the addressee No.1. That you the addressee Nos. 2 to 9 are all managing and looking after the day today affairs of the addressee No.1. That the addressee No.1 company was formerly known as Intime Promoters Pvt. Ltd. That you the addressee No. 10 is the person whose allotment was transferred in favour of my client at the behest of the addressee Nos. 2 to 9 and has been acting in collusion and in connivance with the addressee Nos. 2 to 9. 3. That you the addressee No.1 company is setting up an companies integrated Township, under the name of TDI City at Kundli, Sonepat, (Haryana) and have carved out

commercial plots on the land reserved for the Project and is booking /selling the said plots to prospective buyers. 4. That my client with purpose and intent of making investment in property approached your company lured by the advertisements of the addressee No.1 company of making good returns in property by investing in the project of addressee No.1 company and was referred and sent to the addressee No.2 by the staff/employees of the addressee No.1 Company. 5. That accordingly a meeting took place in the office of the addressee No.2 in the month of February, 2006 between you the addressee Nos. 2 and 5 and Mrs. Usha Dhingra, who is my client wherein both you the addressee Nos. 2 and 5 represented to my client that the addressee No. 1 company has a very viable project by the name of TDI City at Kundli, Sonepat, Haryana and my client shall make good return if it invests in the said project of the addressee No.1 Company. Both you the addressee Nos. 2 and 5 also represented to my client that though the project is in very high demand and already stands completely booked, but you can arrange a plot for my client as the addressee No. 1 company has made some bookings in the project in the name of its own persons including the addressee No. 10 who was also called to the said meeting. The addressee No. 10 also during the said meeting represented to my client that the project of the addressee No. 1 is very viable and my client would make good return by investing in the said project. You the addressee Nos. 2 and 5 further represented that the project is already approved by DTCP HARYANA and that the booked plots shall be immediately handed over upon the completion of project time and also complete payments made by customers as all the necessary and /or statutory approvals/ clearances have been taken from the local authorities. My client lured by the representations and assurances given by

you the addressee Nos. 2, 5 and 10 agreed to book a plot in the project of the addressee No.1 company at TDI City (Sonepat) Haryana and accordingly, made a payment of Rs. 3,50,000/- vide draft dated 28/02/2006 drawn on Union Bank of India, Chakrapur Branch, Gurgaon-122001 (Haryana) in favour of the addressee No. 10 as per the directions of you the addressee Nos. 2, 5 and 10. The addressee No.1 Company upon making the aforesaid payment by my client transferred the booking of Commercial plot No. LC-4/17 of 204 sq. yd. (170.57 sq. mt.) at the basic sale price of Rs. 18,917 per sq. yds. amounting to a total basic sale price of Rs. 38,59,068/- in project at TDI City (Sonepat) Haryana in the name of my client from the name of the addressee No.10. The basic sale price as aforesaid is exclusive of the External Development Charges (EDC). Addressee No. 1 allotted Customer ID No. KCP-212 to my client. 6. That pursuant to the above-mentioned investment by my client in the project of the addressee No.1 company at TDI City (Sonepat) Haryana, my client has made payment of Rs. 21,29,534 out of the total amount of Rs.43,86,000/- to the addressee No.1 towards the aforesaid booking. 7. That my client had a meeting in the year 2008 and again in 2009 with you the above mentioned addressee No. 2 to 9 in the office of the addressee No.2 and expressed her apprehensions and reservations about the project and sought the refund of her money in view of the delay in the implementation of the project. However, all the aforesaid addressees again assured my client that the project is nearing completion and the project has all the necessary statutory clearances and permissions and my client shall be given the plot measuring 204 sq. yds. near and facing the highway as booked by my client. My client reassured by the representations and assurances given by you the above-

mentioned addressees made further payments towards the said booking. 8. That subsequently my client visited the site and found that there is no development in the area and roads and sewers have not been laid down despite my client paying the complete External Development Changes (EDC) for the said plot and the project is incomplete and is not ready for possession at all. The plot offered to my client is at a distance of more that 3 Km. from the Highway and is not situated on the Highway as was falsely represented and shown to my client at the time of making the aforesaid booking. 9. That upon visit to the site, it was further revealed to my client that the addressee No.1 company has only 90 sq. yds. plot at the site whereas the addressee No.1 company has made bookings for 204 sq. yds. plot and has also collected/ demanding payment for 204 sq. yds. plot though there is no plot of 204 sq. yds. at the site. The project of the addressee No.1 Company does not even have the statutory clearances as falsely represented by you the above-mentioned addressees and no plot of 204 sq. yds. has been sanctioned by DTCP HARYANA as falsely represented by you. My client would not have made the investment in the project of the addressee No.1 company and also further payments thereupon but for the false representations and assurances given by you the above-mentioned addressees Nos. 2 to 9. 10. That you, addressees No. 1 to 5 made a false representation that the Haryana Government is asking for Rs. 3694 per sq. yd. towards External Development Charges (EDC) on a plot of 204 sq. yds. plot. However, on the site the plot of my client is only 90 sq. yd. and not 204 sq. yds., as per the Agreement and allotment letter. Therefore, the demand for Rs. 7,53,576/- vide letter dated 22.01.2009 from addressee No. 1 to my client is a false demand. The Haryana Government has

only demanded EDC on the actual size of the plot, which in my clients case is 90 sq. yd. and not 204 sq. yd. Hence, your demand for EDC on my client is false and illegal and the same is being raised with the intention to cheat my client. 11. That other promoters and developers of industrial and commercial plots in the State of Haryana & PUNJAB have also charged EDC from their customers. However, they are charging the EDC based on the actual size of the plots allotted to each respective customer on site and not according to the booking. Secondly, the other promoters and developers of industrial and commercial plots in Haryana have given the same size of plot at site, as booked and as per the Agreement and letter of allotment. 12. That despite the project being incomplete and not having the requisite sanctions as represented by you the above mentioned addressees, you unlawfully, illegally and arbitrarily started demanding instalments with heavy interest without even completing the project. 13. That the addressee No. 1 Company has been demanding payments from my client in accordance with the payment schedule and has also been levying interest charges @ 21% upon delayed payments despite the project remaining incomplete whereas the offer letter stipulates that upon any default on the part of the addressee No.1 company, the addressee No.1 company shall make payment/ refund @ 12% per annum. Thus, the interest clause in your offer letter is inequitable and violative of Section 28 of the Indian Contract Act 1872. Even otherwise, the addressee No.1 Company has no right to demand any interest as the project is nowhere near completion as mentioned hereinabove. 14. That my client was induced by you all the above mentioned addresses to invest and /or to make further payments in the

project of the addressee No.1 company despite being aware of the fact that the addressee No.1 company does not have any plot measuring 204 sq. yds. sanctioned by DTCP HARYANA in its project at TDI City Kundli, Sonepat (Haryana) and, therefore, you all the above-mentioned addressees entered into a criminal conspiracy to cheat my client as well as all other investors who have invested money in the project induced by your false representations and assurances. Your intention from the very beginning was to cheat my client and my client has been deliberately lured in the project by your false representations and assurances so as to defraud her and thereby caused wrongful loss to my client and thereby you have made wrongful gain to yourself at the expense of my client and therefore, my client has no other option but to initiate criminal proceedings against you for the offence of cheating and misappropriation under the relevant provision of the Indian Penal Code, 1860. 15. That my client instead of making any criminal complaint directly to the police officials against you all the addressees has chosen to send you the legal notice in order to provide the opportunity to mend your ways and my client reserves all her rights to make the appropriate complaint against you all the addressees for committing cheating, fraud, criminal misappropriation and criminal conspiracy against my client, if you fail to comply with the demand of my client of allotment and handing over the possession of the plot measuring 204 sq. yds. within 15 days of receipt of this notice. 16. That my client is ready and willing to make the entire balance payment if the addressee No.1 Company gives the agreed plot size of 204 sq. yds. plot, as booked by my client.ONLY AFTER ADJUSTING THE DELAY POSSESION PENALTY IN MY CLIENTS ACCOUNT.

I, therefore, call upon you the addressees through this legal notice to complete and develop the project as assured and represented by you to all customers/ purchasers/ investors in the said project and thereafter to handover the possession of 204 sq. yds.( WITH ALL BY THE YOUR INFRASTRUCTURE READY COMMITTED

COMPANY) plot as booked by my client within 15 days from the date of receipt of this notice, failing which my client shall be constrained to make criminal complaint against you all the addressees for the offence of cheating, fraud, criminal misappropriation and criminal conspiracy committed by you. My client has also instructed me to take all the necessary action available under the Civil as well as Criminal law for all the misdeeds and illegal acts committed by you, if you fail to give the physical possession of the aforesaid plot within 15 days of receipt of this legal notice, you are accordingly. Thanking you (R. S. CHAUHAN) Advocate For ARS CHAUHAN & CO. ADVOCATES& SOLICITORS 308, Block III, Delhi High Court New Delhi-110001 Mobile: (0)9810082960 advised