EKTA RAI & ASSOCIATES

ADVOCATES & SOLICITORS

WITHOUT-PREJUDICE
BY SPEED POST/WHATSAPP/EMAIL
18.12.2023
To,

Mr. Sushil Kukkar (ADVOCATE)

Office cum Residence:
Bagh Colony, Jalabad (W)
District: Fazilka, Punjab

Manoj Kumar
S/O Late. Sh. Gian Chand
R/o Residential Flat/ Quarter, situated at
Tehsil Complex, Jalabad (W)
Tehsil Jalabad (W)
District: Fazilka, Punjab

Our Client:
(i) MR. DEEPAK BACHANI, Director of Vishuddha Nutriol Pvt.
Ltd., at E-63, RICO Industrial Area, Khairthal, Alwar-301404,
Rajasthan.

SUB: REPLY TO YOUR LEGAL NOTICE DATED 01.12.2023

ADDRESSED TO OUR CLIENTS.

Dear Sir,

We have been instructed by MR. DEEPAK BACHANI, Director of Vishuddha

Nutriol Pvt. Ltd., at E-63, RICO Industrial Area, Khairthal, Alwar-301404,

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM
 EKTA RAI & ASSOCIATES
ADVOCATES & SOLICITORS

Rajasthan (hereinafter referred to as, “Our Client”), to serve upon you the
following reply to your legal notice dated 01.12.2023 received on 08.12.2023:

PRELIMINARY SUBMISSIONS

1. At the first instance I would like to reply to you that either your client had
not disclosed to you the true facts or circumstances or you are deliberately
trying to avoid and twisted the matter on false and frivolous grounds just
to harass and extort money from my client. In fact, sending of the legal
notice through you the addressee no.1 on behalf of your client i.e. addressee
no.2 shows the mala-fide and dishonest intention of your client to
misappropriate the business and money of our clients.

2. That while replying to your legal notice and narrating you the correct facts,
at the outset, our clients vehemently deny every content, allegation,
averments, and statement in the above-captioned legal notice under this
present reply, unless otherwise specifically admitted herein. We have
received the above-referenced notice dated 01.12.2023 on 08.12.2023, the
content of which is incorrectly riddled with factual errors, unsubstantiated
allegations and damaging imputations, misrepresentation of facts and
blatant attempt to coerce our clients.

That without prejudice to the aforesaid contents the para wise reply to the notice
is hereunder:

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM
 EKTA RAI & ASSOCIATES
ADVOCATES & SOLICITORS

A. That the contents of para 1 of your legal notice are matter of record
and hence does not warrant any reply.

B. That the contents of para 2 are specifically and vehemently denied

for want of knowledge and your client be put to strict proof to prove
the same. It is specifically and vehemently denied that your client has
purchased V-Pure Dalia packed and marketed by our client from the
concerned business place.

C. That the contents of para 3 are specifically and vehemently denied. It

is specifically denied that your client has seen any dead lizard in the
pack of V-Pure Dalia. It is respectfully submitted that the process of
manufacture and packing was done with utmost care and caution and
there is no possibility of any foreign body entering the packet. It is
pertinent to mention here that the manufacturing plant of our client is
well equipped with the safety standards and procedures as laid down
by FSSAI for running a manufacturing plant. It is respectfully
submitted that when a food particle has to go under processing and
manufacturing, it requires a quality-controlled environment
including but limited to the process of disinfestation services, rodent
and pest control and fumigation. That for the sake of the same our
client has hired qualified professionals who time to time helped our
client in keeping his manufacturing plant safe, and sanitized and has
developed detailed procedures for all food product contact surfaces
as well as non-product portions of equipment, overhead structures,

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM
 EKTA RAI & ASSOCIATES
ADVOCATES & SOLICITORS

shields, walls, ceilings, lighting devices, refrigeration units and

heating, ventilation and air conditioning (HVAC) systems, and
anything else which could impact food safety. It is specifically and
vehemently denied that our client has not shown any concern towards
the complaint made by your client, our client suggested your client to
send the alleged packet of the V-pure Dalia to our client in order to
send that packet for getting it examined at proper laboratory but your
client instead of sending those packets continued demanding the
extortion money.

D. That the content of para 4 are specifically and vehemently denied. It

is specifically and vehemently denied that our client is playing with
the health of General Public by way of selling the poison proprietary
food under the logo of V-Pure. It is submitted that our client is
involved in manufacturing a quality approved line of Breakfast
Cereals, Whole Spices, Rice Poha, Flattened Rice, Rice Flakes, etc.
and has taken every possible steps to ensure the range of products
manufactured and traded by our client succeed in surpassing quality
expectations of clients through taste, aroma, appearance and safety.
It is also pertinent to mention here that we possess the appropriate
invoices of fumigation process or other quality standard
documentation, which are obtained on regular intervals and will be
put forth at appropriate stage in case you and our client enter into any
litigation as alleged by your client.

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM
 EKTA RAI & ASSOCIATES
ADVOCATES & SOLICITORS

E. That the contents of Para 5 are specifically and vehemently denied. It

is specifically denied that our client is involved in any kind of unfair
trade-practice or deficiency of service. It is submitted that if there had
been any manufacturing defect in the said Dalia, it is practically
impossible that it would affect just one packet as the same is prepared
in huge batches and if there was any such manufacturing or
production defect, then we would’ve received multiple complaints
throughout the country where the V-Pure Dalia have been shipped to,
however no other complaints of any sort pertaining to the said
product has been received by our client, except for the one which
your client is alleging. In order to ascertain whether the said Dalia
contained lizard and what is the cause of such contamination, it
should have been tested at the earliest instance when such alleged
contamination was detected by your client. That our client has offered
your client to get the product tested in any forensic lab to exactly
ascertain whether any foreign body had ever entered into our client’s
product, but your client neither has allowed our client to inspect the
product nor has produced any such report with the present notice to
prove that any foreign body/lizard was ever present in our client’s
product which could prove the fact that any lacuna was there from
our client’s end. And finally, it is conveyed to your good self that our
client is not responsible for any sort of contamination which is
supposed and fictional. It is further conveyed that until and unless it
is proved that the alleged contaminant/lizard was in the food packet
before it was opened, there is no deficiency of service on the part of
our client.

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM
 EKTA RAI & ASSOCIATES
ADVOCATES & SOLICITORS

F. That it is germane to state here that your client is twisting the correct
facts just to harass and extort money from our client.

We, therefore, advise you to withdraw your false and baseless notice with
immediate effect. In case any litigation is being filed on the baseless and false
claims of your clients the same shall be defended with full force solely at your
costs, risks and consequences. Our clients reserve their right to file appropriate
legal proceedings against your client. Our client may initiate a criminal and civil
case against your client according to established law.

The impugned legal notice does not enumerate the cause of action as well as does
not fulfil/highlight the ingredients of offences as well as legal wrong. Your client
is put to strict proof about true and correct facts of the deal of the expired stock
between your client and our clients.

Therefore, considering the above, we call upon you immediately:

(i) To withdraw and retract the notice dated 01.12.2023 and its contents
thereof, with immediate effect. However, in case your clients still choose
to file any litigation, the same will be defended by our client solely at your
clients’ costs, risks, and consequences.

(ii) To pay us the advocate’s fees i.e., Rs. 21,000/-.

Please note that the present notice is limited to the issues herein and the contents
hereof are illustrative rather than exhaustive of any points available to our client
concerning the above matter, either at law or in equity. Our client's rights are
expressly reserved in this regard.

ADVOCATE EKTA

OFFICE AT: D-12, 143-144, SECTOR-8, ROHINI, DELHI - 110085

Contact number: 8860945588, 9711457354
Email: VPURELEGAL@GMAIL.COM