To,
1. Seema U. Rathod
Advocate
Rudraksh Residency R5/F3, Tamjainagar,
Satara-415002
(M) 8668457460
Email- [email protected]
2. M/S Dhyan Associates
Through its owners
Having its registered office at
Flat No.7, A-Wing, Vasundhara Garden,
Daulatnagar, Karanje Tarf, Satara-415001
3. Mr. Suraj Pawar
Owner of M/S Dhyan Associates
Having its registered office at
Flat No.7, A-Wing, Vasundhara Garden,
Daulatnagar, Karanje Tarf, Satara-415001
4. Mr. Abhijit Mane
Owner of M/S Dhyan Associates
Having its registered office at
Flat No.7, A-Wing, Vasundhara Garden,
Daulatnagar, Karanje Tarf, Satara-415001
My Client: - 1. M\s. Shivam Infocom Pvt.Ltd,
Having its registered office at
185, DSIDC Complex, Okhla
Industrial
Area, Phase -1, New Delhi -110020.
2. Mr. Naresh Yadav
Owner of M\s. Shivam Infocom Pvt.
Ltd,
Having its registered office at
185, DSIDC Complex, Okhla
Industrial
Area, Phase -1, New Delhi -110020.
3. Mr.Kamal Puneri
Pan India Project Head of M\s.
Shivam
Infocom Pvt. Ltd.
Having its registered office at
185, DSIDC Complex, Okhla
Industrial
Area, Phase -1, New Delhi -110020.
REPLY TO LEGAL NOTICE DATED 17.11.2024
Dear Sir/s
Under the instructions from and on the behalf
of my has placed before us your notice dated
17.11.2024 sent by you on behalf of your client i.e.
M/S Dhyan Associates (hereinafter referred as
“Your Client”). We serve upon the following reply
to your notice on behalf of our client: -
PRELIMINARY OBJECTIONS
1. Without Prejudice, it is to state here that your client
has misused your good office by concealing the
material facts from you and got issued the false and
fabricated notice based upon the concocted story,
hence, we on behalf of our client deny outrightly all
the allegations and contention mentioned by you on
behalf of your client against our client and our client
reserves it’s all rights to sue your client for causing
losses and damages to our client as and when
necessary.
2. That before responding to the various facts and
averments as stated by you in the Notice, we wish
to inform you that our Client is a distinguished
company that operates with a commitment to
ethical practices and excellence in its field. Our
client maintains transparency with all stakeholders
and customers, ensuring adherence to prescribed
industry protocols and fostering a fair and
responsible working environment.
3. That the claims and allegations made in the present
notice are entirely baseless, misleading and devoid
of merit. They appear to be an attempt to unjustly
pressure our client into payment of an amount that
is neither due nor payable.
4. That the quality and quantum of work performed by
your client were substandard and grossly
inadequate resulting in severe losses to our client.
Accordingly, the payments made to date are more
than commensurate with the value of the services
rendered.
5. That your client’s failure to meet the agreed
standards and expectations has already been
communicated on multiple occasions. Despite
several opportunities to rectify the deficiencies your
client had failed to take corrective measures
causing further detriment to our client.
6. The alleged remaining amount of Rs. 2,94,332/- is
unequivocally denied. In fact, our client’s
independent calculations reveal that only a
negligible amount of Rs. 16,958/- remains in
dispute, which is not payable due to the poor quality
of work delivered by your client.
PARA WISE REPLY
1. That the contents of para under reply are incorrect
and denied. It is submitted herein that while your
client may have completed certain work, it was not
done within the stipulated time or as per the agreed
standards, causing significant operational and
financial losses to our client.
2. That the assertion in the para that the total cost of
the work was mutually agreed upon at Rs.
32,04,144/- is false, fabricated thus denied in toto.
However, your client’s inability to meet the quality
standards has rendered a significant portion of the
work unusable, thereby diminishing its value.
3. The statement in para regarding disbursement of
Rs. 29,09,812/- is false, fabricated thus denied in
toto. However, this payment represents more than
the value of the substandard work delivered by your
client. The alleged claim of Rs. 2,94,332/- is
therefore denied in its entirety.
4. That the claim in the present para that our client
assured payment of Rs. 2,94,332/- is categorically
denied. Our client has consistently communicated
their dissatisfaction with the quality of work and has
provided detailed explanations for withholding any
further payments.
5. The allegations in paragraph 5 regarding calls,
emails, and alleged non-responsiveness are
baseless and denied. On the contrary, it was your
client who failed to respond to our client’s repeated
requests for rectification of the substandard work.
As the greed has no limits, the real intent
behind issuance of this notice is clear that under the
garb of notice under reply, your client wants to
extort money from our client. It is submitted that
there is no iota of truth in the notice under reply. It
is submitted that the question of payment of
amount to your client on any count does not arise at
all as mentioned in the present legal notice under
reply. Please note, that your client is liable to pay
the amount of Rs. 50,000/- (Rupees Fifty Thousand
only) towards the legal charges for sending reply of
your legal notice.
Therefore, we under the instruction of our
client call upon you to your client to advise your
client to withdraw the notice under reply, with
intimation to the undersigned, within 3 days from
the date of receiving of this reply. However, in case
your client still chooses to initiate any legal action
against our client, the same shall be contested at
your risks, costs and consequences, which please
may note.
A copy of this reply of Legal Notice is retained
in my office for record in my office for record and
future references.
JATIN SHRAMA
D/951/2012
Advocate for Complainant
For Jurist &Jurist International
(Advocates and Legal Consultants)
E-26, Greater Kailash-1,
New Delhi -110017
M:9811881981
www.juristandjurist.com
Email: [email protected]
