KRRISH GUPTA
(ADVOCATE & CONSULTANT)
HIGH COURT OF DELHI
Date: 02.01.2025
To,
1) Devender Singh @ Bindu
S/o Sh. Kalyan Singh
R/o Village Bhinwar, Tehsil: Morni,
Distt. Panchkula, Haryana – 134205
Mob: 9466378292; 7027778292
2) Satya Devi
W/o Sh. Deep Ram
R/o Village Badyal, Tehsil Morni,
Panchkula, Haryana -134205
3) Amit Sharma
S/o Sh. Balwant Sharma
R/o Village Samlotha, P. O. Tikkar
Tehsil : Morni, Distt. Panchkula,
Haryana – 134205
Mob. : 9817090597; 8930158758
LEGAL NOTICE
Under the instructions or on behalf of my client Mr. Nar Singh Sehrawat S/o
Sh. Risal Singh Sehrawat, R/o H. No. 176, Village Pochanpur, Dwarka, South
West Delhi, Delhi-110077 (hereinafter referred to as ‘my client’), I the
undersigned do hereby serve upon you with the present notice to the following
effect:
1. That my client is the law-abiding, religious minded as well as peace-loving
citizen of India and has an unblemished social life of past many years by
virtue of which carries a respectable image in the society and my client is
presently residing at the abovementioned address along with his family.
Regd. Chamber No. 348, 3rd Floor, Lawyers Chamber Block, Saket Court, New Delhi – 110017
Mob: 8010838485 E-mail: [email protected]
KRRISH GUPTA
(ADVOCATE & CONSULTANT)
HIGH COURT OF DELHI
2. That you the adressee no. 1 and adressee no. 2 are alleged to be the absolute
and rightful owner of Waka Moja Bhoj Nangal hadbast no. 326, Tehsil
Morni, Khewat No. 516, Khata No. 833-834, 1200/5860 Bhag of Salam
Khewat Khasra Kite 6 Tadadi 14-13, Hissa Bakdar 3-0 (Three Bigha)
Rakba (hereinafter referred to as the “subject property”).
3. That you the addressee no. 3 is working as a real estate agent and mediator
cum dealer at Village Samlotha, P.O. Tikkar, Tehsil-Morni, Distt.
Panchkula, Haryana – 134205, involved in various real estate services.
4. That you the addressees in connivance with each other approached my
client somewhere on dated 12.09.2023 and offered for sale of the subject
property for an agreed consideration amount of INR 43,00,000/- (Rupees
Forty Three Lakhs only). That you the addressees after making
representations to my client that the subject property is free from all
encumbrances like sale, mortgage, lien, court order etc. dishonestly
induced my client to enter into an “Agreement to Sell and Purchase” dated
13.09.2023 against an earnest cum full amount of INR 43,00,000/- (Rupees
Forty Three lakhs Only), which my client duly paid to you.
5. That my client, time and again has requested you the addressees to make
available the original title documents and to start the process of registration
but you the addressees exploiting the innocence and infirmity of my client,
abstained from showing the original title documents of the subject property
even for the inspection on one pretext and another by giving false,
indistinct and frivolous promises and assurances while stating that you will
surely start the registration process of the subject property soon and also
assured my client that the said documents will be made available soon after
execution of this agreement.
Regd. Chamber No. 348, 3rd Floor, Lawyers Chamber Block, Saket Court, New Delhi – 110017
Mob: 8010838485 E-mail: [email protected]
KRRISH GUPTA
(ADVOCATE & CONSULTANT)
HIGH COURT OF DELHI
6. That you the addressees have deceived my client by fraudulently and
dishonestly inducing my client to deliver INR 43,00,000/- (Rupees Forty
Three Lakhs only) in the form of earnest cum full payment of the property
to you the addressees while making false promises and fake assurances to
my client to execute the sale deed in favour of my client.
7. That even more than 1 (One) year has passed and till date the process of
registration has not been started even after repetition of the calls and
messages to you addresses. That you all make false promises and
procrastinate.
8. That after sensing your ill intentions as well as the nefarious designs and
tactics to usurp unlawfully the earnest cum full amount of the property
deposited with you the addressees, my client through numerous telephone
calls requested you to return the earnest money and rescind the “Agreement
to Sell and Purchase”; however, all such demands have proved futile and
all such efforts went in vain.
9. That you shall take notice that my client is rescinding the “Agreement to
Sell and Purchase” with immediate effect and you are advised to restore
the status quo ante. You are further advised that my client shall hold you
responsible for all actual and consequential losses or damages arising from
your above stated deceitful conduct.
10. That without prejudice to other legal remedies available to my client, you
the addressees are hereby called upon to refund the afore-mentioned sum
of INR 43,00,000/- (Rupees Forty Three lakhs Only) to my client within a
period of 15 days of receipt of this demand notice, should you fail to accede
to the humble requests of my client as have been enumerated, my client
Regd. Chamber No. 348, 3rd Floor, Lawyers Chamber Block, Saket Court, New Delhi – 110017
Mob: 8010838485 E-mail: [email protected]
KRRISH GUPTA
(ADVOCATE & CONSULTANT)
HIGH COURT OF DELHI
shall be constrained to initiate appropriate legal action before the
appropriate Courts of law and other forums having the jurisdiction under
the provisions prevailing under the law against you the addressee at your
risk and peril.
11. That the foregoing is not intended nor shall it be construed as a complete
recitation of the facts and events concerning the above-referenced matter,
nor it be construed as a waiver of any rights, remedies or claims, legal or
equitable, which my client may have.
12. Please note that this notice is being issued at your costs and consequences,
which you may please note with care and caution.
13. This is without prejudice to all other legal rights and remedies available to
our client for the above-stated purpose.
14. You are also liable to pay the necessary cost and expenses of sending the
present legal notice to you of Rs. 5000/- (Five Thousand only).
Copy of this legal notice is also kept at our Advocates Chamber for further ready
reference it required in future.
Advocate
Regd. Chamber No. 348, 3rd Floor, Lawyers Chamber Block, Saket Court, New Delhi – 110017
Mob: 8010838485 E-mail: [email protected]
