Through Regd. Ad Post
Through Regd. Ad Post
Date: 5-4-2019
To,
Harjinder Singh,
Jalandhar 144001.
We have been handed over your legal notice issued on behalf of your client Harjinder Singh dated 25-
03-2019. You are hereby referred to the contents of Legal notice issued dated 25-03- 2019 by your
client.
PRELIMINARY SUBMISSIONS/OBJECTIONS:
1.At the outset, we have instructions to state that your client has not apprised you the correct facts
and has also concealed the facts, which resulted into issuance of this frivolous notice. It
appears that your client has misrepresented the true facts deliberately and has concealed his
own misdeeds and wrongs done against our client. It is further stated that averments made
against our client in the subject notice are wrong, frivolous and misconceived, hence they are
denied.
2. In reply to para no.1 of the notice, it is pertinent to mention here that your client has concealed
the material facts from you that the contents of Para No.1 of the notice under reply are
admitted to an extent that our client knows your client and has regularly entered in business
contract. But however, it is ardently denied that my client took any loan of the said amount. It
is further denied that Balwinder Singh, a friend of my client was even present as there was no
such transaction.
Saa & Partners
Jalandhar, Punjab 1444003 Office: 1/1511A, Model Town,
Mob No: 7013213330 Jalandhar Punjab 1444003
Email-Id: [email protected]
3. That the contents of para 2 of the subject notice are wrong and incorrect, therefore, are
emphatically denied. It is vehemently denied that our client issued cheque no. 006584 favoring
your client and it is reiterated that the cheque was meant for security purposes only and not
against any liability and my client was induced to issue such a cheque.
4. That the contents of para 3 of the subject notice are wrong and incorrect, therefore, are
emphatically denied. The presentation of this cheque by your client for encashment is denied
for want of knowledge. However, your client was clearly asked by our client to not present and
return that cheque before presentation for encashment. It is reiterated that these cheque were
presented without any liability or without any authority.
5. In reply to para no. 4 of said notice, my client has not committed any offence in the eyes of law
and the said cheque was presented to harass my client.
6. In reply to para no.5 of said notice as there was no liability to pay an amount as the client has
already denied it and there is no question of intention of fraud or cheating and there was no
such transaction.
It is further stated that any legal or other action initiated against our client by your client shall
entirely be at your client’s risk, cost and consequences and our client reserves every right to initiate
legal action for damages or other remedies from your client before appropriate Forum/s, which
kindly note.
Therefore, you are requested to call upon your client to withdraw the above legal notice against our
client henceforth, falling which our client will be constrained to initiate the appropriate legal
proceeding and also defend if need arises at the cost and consequences of your client.
Date: 05/04/2019
Place. Jalandhar
Through Counsel
SAA & Partners
(Adil Ahmed)