REGISTERED A.D.

POST
To,

Name- Hostel Paradise

Address- [●]

LEGAL NOTICE
Sir,
Under instructions, and on behalf of my client, Tara Bakshi, F/o, Bijli Bakshi R/o [●]
(“Client”), I DO HEREBY, serve upon you, the addressee, to the following notice:

1. That my Client Mr. Tara Bisht F/o Bijli Bakshi is a resident of ______ and on behalf
of my client I want to bring this to your notice the recent dealing of my client Mr.
Tara Bakshi with your establishment, Paradise Hostel. It is with great disappointment
that I bring to your attention the grievous breach of contract and false representations
made by your hostel, causing significant distress and financial loss to us.

2. Mr. Tara Bakshi’s daughter Bijli Bakshi, got enrolled at India’s leading Fashion
Designing School, University of Tomorrow but it was a bit disappointing for my
client’s family as the University do not provide any accommodation.

3. Therefore, after searching different hostel’s near University my Client searched upon
your hostel called Paradise which claimed to be a premium hostel exclusively for girls
and promises to give various facilities such as round the clock security, queen size
beds, daily general hospitality service, healthy and nutritious vegan food, convenient
and comfortable transport to and fro from the Hostel to the University, high speed wi-
fi, five-star laundry service, highly equipped gym, sauna, and most importantly, a
decently sized swimming pool.

4. That thereafter looking into all the pros and cons my client selected your Hostel
Paradise to be the best suitable place of stay for his daughter Ms. Bijli as it offers a
decently sized swimming pool as it would help Ms. Bijli (a prolific swimmer) to
practice for LA Olympics 2028.

Page 1 of 4
5. Consequently, my client secured an accommodation at Paradise Hostel by paying an
advance booking fee of Rs. 2,50,000 and a security deposit of Rs, 5,00,000 with
agreement for an annual rent of Rs. 20,00,000/- paid the entire fees in one go.

6. That, at the beginning of the session in March my client went to drop her daughter
Ms. Bijli at your Hostel Paradise claimed to be itself a state of art and a premium
hostel allotted her temporary room for a week. After the completion of first week Ms.
Bijli was allotted a terrible permanent room. Despite of assuring a plethora of
facilities including a swimming pool, round-the-clock security, and comfortable
accommodations with king size bed, the reality was starkly different. The absence of a
swimming pool, substandard living conditions, and a lack of basic amenities not only
violated the terms of our agreement but also jeopardized my client’s as well as his
daughter’s aspirations, particularly her pursuit of professional swimming training for
the LA Olympics 2024.

7. That, my client’s daughter is a 16-year-old which is almost equal to a minor child.

After getting the admission to this university Ms. Bijli will be leaving her home for
the first time in her life without her parents. At this point of life she will not be having
any easily approachable life with caretaker’s and helping hands like that of her
parents. During her college life she might have many ups and downs in her day-to-day
life and at the end of those tiering days Ms. Bijli must satisfy herself with some good
quality food and a relaxing sleep.

8. Also, it is pertinent to highlight that my client’s daughter's decision to select Paradise

Hostel was primarily influenced by the promise of a swimming pool, which is crucial
for her unbeatable swimming training to build herself for the future competitions. But
instead of swimming pool there was a ditch filled with dirty water where instead of
Human Being tadpoles were swimming.

9. Therefore, the hygiene issues with your premium hostel and sub-standardising your
promises make my client worry about his daughter. Consequently, after so much of
trouble my client calmly requested the Hostel Manager thrice a day to fix all these
problems but the addressee’s hostel didn’t pay any attention to the requests. Also, Ms.
Bijli was taunted several times by the hostel staff that she should “stop being entitled
to her parents and that you should learn to live the hard life”.

Page 2 of 4
10. That, it was not legitimate and ethical at the part of your hostel accommodation to put
up such a statement to my client and his daughter as they paid for this accommodation
in advance and fulfilled all the terms and condition but the services given by the
addressee’s accommodation were ridiculous. After Ms. Bijli’s hometown this hostel
and its staff was a second home to her in which she has to spend all the remaining
year of her college life but instead of treating Ms. Bijli as a client they taunted and
misbehaved with Ms. Bijli and her father.

11. The failure on your part to deliver on this promise not only constitutes a breach of
contract but also demonstrates a deliberate misrepresentation of facts, leading to
undue financial loss to my client Mr. Tara Bakshi and emotional distress to Ms. Bijli
Bakshi.

12. That, the refusal by your Hostel staff to perform the promise of the contract between
my Client and your hostel Paradise caused an Actual Breach of Contract for which the
compensation is asked as per section 73 of the Indian Contract Act,1872 and all the
misrepresentations of the list of facilities made by the addressee at the time of contract
is a fraudulent misrepresentation as per section 18 of Indian Contract Act, 1872.

13. In light of the aforementioned breaches and misrepresentations, we hereby demand

the follow:

 Full refund of the advance booking fee of Rs. 250,000.

 Immediate return of the security deposit of Rs. 500,000 along with Rs. 17,50,000
paid in one time my client Mr. Tara Bakshi.

 Compensation for the mental anguish, inconvenience, and disruption caused to my

daughter's academic and athletic pursuits, amounting to INR 10,00,000.

14. That you, the addressee, is also liable to pay the sum of INR 6,500/- (Rupees Five
Thousand Five Hundred Only) as a cost of this notice.

That by means of this notice, you are HEREBY CALLED UPON to compensate the
whole amount my client Mr. Tara Bakshi within 15 (fifteen days) of the receipt of this
notice to you, the addressee, failing which my Client shall be constrained to initiate legal

Page 3 of 4
proceedings against you, the addressee, under the relevant provisions of the Indian
Contract Act, 1872 before a competent court of law at your cost and consequences.

Dated: 12th April 2024

Copy retained.

Confirmed by [Mr. Tara Bakshi] over e-mail

[Mr. Aditya Gupta]

Advocate

Page 4 of 4