TAHIR KHALIL MEO

Advocate High Court Cell # 0300-8356444

Office # 80, Block A, Judicial Complex Pattoki, Kasur

Ref: TK/9/21/PTK
21st March, 2023

Subject: - Legal Notice regarding Cancellation of

Aagreement to Sell Dated: 24-05-2022 AND Extension/
Supplementary Agreement to Sell Dated: 20-11-2022

To,

Mr.Qayum Nawaz S/O Qadir Baksh, by Caste Mayo, R/O Devo

Kalan, P.O Kahna Nau, Tehsil Lahore Cantt, District Lahore.

Sir,
Under the instructions from and on behalf of my client Mr. Shahab Deen S/O
Peer Bakhsh, by Caste Mayo, R/O Devo Kalan, P.O. Kahna Nau, Tehsil Lahore
Cantt, District Lahore. (Hereinafter referred to as the “CLIENT”) I do hereby serve
you with the following legal notice: -

1. That my client is absolute owner of the land (Plot) measuring 1 Kanal forming part
of the Khewat/Khata No. 52/54, Khatoni No. 152, Total Pieces of Land/Area i.e.
“Qitaat” 5, Total area of Khata 16K-2M, Share Transferred 15/161 which is
situated in Revenue Estate Raja Bolay, Tehsil Lahore Cantt, District Lahore.

2. That, initially you entered into an Agreement to Sell (“hereinafter referred as

the Agreement to Sell”), vide E-Stamp No. PB-LHR-221810B784E8059B on
dated 24.05.2022, with my said client to purchase the said land (Plot) of my
client area measuring 1 Kanal, which is situated within the revenue estate of Raja
Bolay. You and my client signed “the Agreement to sell” in the presence of
witnesses on the same day.

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 TAHIR KHALIL MEO
Advocate High Court Cell # 0300-8356444
Office # 80, Block A, Judicial Complex Pattoki, Kasur

Ref: TK/9/21/PTK
21st March, 2023

3. That as per the terms and conditions of “the Agreement to sell” the total sale
consideration of the said land was settled at Rs.60,00,000/- (Rupees Sixty Lacs
only), you paid money of Rs.30,00,000/- (Rupees Thirty Lac only) to my client on
the same day of “the Agreement to Sell”.

4. That the date for execution and registration of the sale Deed is to be completed
within four months from the date of the said agreement i.e.,24.09.2022. So, at
stipulated date as per said agreement, my client in good faith with bona fide
intention contacted and meet you personally, and requested you to make
remaining balance of sale consideration i.e., Rs. 30,00,000/- to my client and he
also requested to you that he is ready to and willing to execute and register the
sale deed of the said land (Plot) in the office of Sub Registrar Tehsil Modal Town
in your favour or in favour of any person as you may direct in accordance with the
terms and conditions of the said agreement. but the same was not done for
reasons that you were unable to pay remaining balance of sale consideration and
you made request to my client to extend the stipulated time of “the Agreement to
Sell”, which was accepted graciously and peacefully by my client in good faith
with bona fide intention without any increase in sale consideration or without
getting any profits or benefits in any other shapes from you. After that you and
my client entered into an Extension/Supplementary Agreement to Sell
(“hereinafter referred as Extension/Supplementary Agreement to Sell”) in
respect of said land Vide E-Stamp No. PB-LHR-D3B3AD1A32C697D7 on 20-
11-2022.

5. That you paid only RS.15,00000-/ (only Fifteen Lack Rupees) Out of remaining
balance of sale consideration i.e., RS.30,00000-/to my client on the same day i.e.,
20-11-2022.

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 TAHIR KHALIL MEO
Advocate High Court Cell # 0300-8356444
Office # 80, Block A, Judicial Complex Pattoki, Kasur
Ref: TK/9/21/PTK
21st March, 2023

6. That, as per terms and conditions of Extension/Supplementary Agreement to sell

date for execution and registration of the sale Deed is again fixed for
10-01-2023.

7. That the date and time was essential part of the said Extension/Supplementary
agreement to sell, and according to the clause of the said agreement, the said
transaction is to be completed on 10-01-2023 of the said agreement.

8. That it is pertinent to mention here that my said client had already handed over
the possession of the said land, peacefully to you in good faith with Bona fide
intention without receiving full sale consideration which depicts and shows his
genuineness and readiness to perform his part of Contractual obligations and
liabilities of the said agreements, even though the clauses of the said agreements
clearly state that he was not bound to do so, that without/before receiving full sale
consideration.

That again at the stipulated date for execution and registration of the said sale
Deed, my client in good faith with bona fide intention contacted and meet you
personally, and requested you to make remaining balance of sale consideration
i.e., Rs. 15,00,000/- to my client and requested to you that he is ready to and
willing to execute and register the sale deed of the said land (Plot) in the office of
Sub Registrar Tehsil Modal Town in your favour or in favour of any person as you
may direct in accordance with the terms and conditions of the said agreement. but
the same was not done for reasons of you had become dishonest, and you with
malafide intention, deliberately avoiding to pay the balance sale consideration
and you had completely failed twice to perform your part of the said agreements
as per the terms and conditions of the said agreements.

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 TAHIR KHALIL MEO
Advocate High Court Cell # 0300-8356444
Office # 80, Block A, Judicial Complex Pattoki, Kasur

Ref: TK/9/21/PTK
21st March, 2023

9. That since then my client have been visiting your house and has been continuously
requesting you and demanding from you the balance sale consideration and
requesting you also to execute and register the sale deed of
the above mentioned land in your favour after but you have been avoiding to the
legitimate requests of my client on one pretext or the other.

I, therefore, through this legal Notice intimate you that you had completely
failed to perform your part of the said agreements i.e., “the agreement to
sell” vide E-Stamp No. PB-LHR-221810B784E8059B dated:
24.05.2022 and “Extension /Supplementary of Agreement to sell” Vide
E-Stamp No. PB-LHR-D3B3AD1A32C697D7 dated 20.11.2022,
because you had become dishonest and you intentionally and
deliberately violates the terms and conditions of the said agreements and
both the said agreements stand cancelled, thereafter according to the
terms and conditions of the said agreements to sell, the amounts paid by
you had been forfeited by my said client and You would have no any right
to claim against my said client in respect of the said agreements to sell
and my client is free to sell his above said property to anybody else and
I shall initiate lawful legal proceedings against you at proper law forums
with damages and costs.

Sincerely;

Tahir Khalil Meo,

Advocate High Court,
0300-8356444

Note: A copy of this Notice is kept in my office for record and further necessary Legal
actions.