Date : 22.03.

2024

To,
Gopal Krishna
Advocate
Bar association Hazaribagh
Civil court compound, Hazaribagh
Mob : 9818954280
Copy to :-
Nand Kishore Dangi
Son of Lalo Kamal Dangi
Resident of Village – Baghmundi
P.O. – Karni, P.S. Itkhori, District Chatra
Pin - 825408
Subject – Reply notice

Sir,
Under instruction from my client Nitesh Kumar son of Jitendra
Dangi, resident of Tetariya, Pathalgadda, District Chatra, and after
perusing the papers placed before me as well as after going through
the contents of notice sent upon my client I find that my client and
your client were in friendly terms and as such used to lend money to
one another and in process to the same my client on mutual
understanding had taken a sum of ₹ 50,000/- from your client on
25.06.2020 by way of friendly loan and in lieu of the same you have
taken a blank cheque no. 000016 of my clients account in HDFC Bank,
Branch Matwari, Hazaribagh of the same day as security deposit with
a clear understanding that on payment of the amount of ₹ 50,000/-
your client will return the said cheque as given to your client by way
of security will be duly returned to my client.
That my client being a generous person has refunded the said
amount taken by him in the same year i.e. by way of Phone Pe and
Google Pay through online into your client’s account having mobile
number 9987254834 and as such after payment of entire amount as
taken by my client, he requested your client to return the said
cheque as given to your client by way of security deposit but as it
appears that your client instead of returning the aforesaid cheque
your client firstly took time on the pretext that your client was busy
in some personal affairs and as soon as your client get relieved your
client will return the said cheque but even after persona request your
client did not returned the aforesaid cheque with ulterior motive and
thereafter your client started to avoid my client with a sole purpose
to misuse the said cheque for his illegal gain though as stated above
my client has already refunded the aforesaid amount of ₹ 50,000/-
long back and an endorsement of handing the aforesaid cheque
showing the amount of ₹ 50,000/- taken by my client can be very
much verified from the cheque book duly filled by my client at the
time when he has taken the loan.
That as it appears from your notice that your client being a
mischievous person and having a set up mind has taken a total sum
of ₹ 02,09,250/- (₹ 87,500/- from Google pay and ₹ 01,21,750/- by
way of Phone Pe) from my client though my client has taken a sum of
₹ 50,000/- only by way of loan as stated above and thereafter your
client instead of returning back the said cheque withheld the same
for his malicious gain and thereafter after a lapse of four years
presented the said cheque by filling the same from his own pen by
giving an anonymous amount as ₹ 05,65,500/- on the blank cheque
as given to you in lieu of the amount of ₹ 50,000/- which was even
refunded three years back by paying a hefty amount of ₹ 02,09,250/-
(₹ 87,500/- from Googlepay and ₹ 01,21,750/- by way of Phone Pe).

That it would be relevant to state here and bring to your kind notice
that your client has received a sum of ₹ 01,59,250/- from my client by
harassing and blackmailing my client, hence it is made clear that as
your client is always giving open threats to my client and demanding
money time to time by using the cheque as a weapon given to you
two years back and as such your client has played fraud upon my
client which is apparent from the documents as placed before me
and as such my client has also advised me to initiate appropriate
legal proceedings against your client for demanding money by
playing fraud upon my client in the competent court of
law/jurisdiction and it is further advised that if your client initiates
any legal proceeding against my client then the same will be
defended by my client by placing all the relevant facts as stated
above and all the expenses borne in will be recovered from your
client.

A copy of this notice is kept in my office for future reference.

Bhaiya Uttam Kumar

(Advocate)
Kali Bari Road
Hazaribagh
Mob : 7091788131