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THROUGH REGISTERED POST/ A.

To, 26/11/2020
DIMAPUR
THE EXEXUTIVE ENGINEER (CAWD)
COMMISSIONER’S OFFICE
KOHIMA: NAGALAND

SUB: - NOTICE WITH REFERENCE WORK ORDER REGD. NO.


NPW/CL-1/619, KOHIMA

OUR CLIENT: - MRS. T. KAMJILA YIMCHUNGER


Through her legal counsel,
HUKAVI ZHIMOMI
Having its Office at: -
Opp. Dist. & Sessions Court
Dimapur, Nagaland
-797112

Sir,

UNDER THE INSTRUCTIONS OF MY CLIENT, Mrs. T. KAMJILA


YIMCHUNGER, R/o, Diphupar- B, house No.852, Dimapur, Nagaland. I
issue the notice to you as under;

1. That in reference to the work order Regd. No. NPW/Cl-1/619, Kohima


you the Noticee is requested to kindly release the funds to my client
since the work order has been assigned to Mr. T. Akhumba Yim as he is
a minor, and by doing so you are invalidating the contract and going
against the terms and conditions of the workorder.

2. That since you have transferred hand written funds to Mr. Tshanso who
has sublet the contract from Mr. T. Akhumba Yim it does not only
invalidate the contract but goes against the terms and conditions
enshrined in the work order.
3. That as per the divorce agreement dated 29/10/2016 signed between Mr.
Tshanso Yimchunger and my client, all the rights and responsibilities
and power to take care of all the expenses for the purpose of the work
order was divested to my client.

4. That it is to bring to your notice that my client is the one who has been
implicated by Mr. Tshanso Yimchunger as the said amount of Rs.
57,50,000/-(Rupees Fifty Seven Lakhs and Fifty Thousand Only) has
been withdrawn by the latter and now my client bears the headache of all
the payments/dues which she was supposed to pay out of the said
workorder, as promised in the aforementioned divorce agreement.

5. That the above act of conniving with Mr. T. Akhumba Yim and Mr.
Tshanso Yimchungher has affected my client indirectly and thus has
amounted to an act of illegality on part of you the Noticee and your
department officials.

6. That your department has committed the workorder to a minor and the
minor has further sublet the workorder to Mr. Tshanso Yimchunger thus
the aforesaid illegal act is prima facie entirely goes against the terms and
conditions enshrined in the workorder.

7. That due to your illegal acts of conniving with the abovementioned


persons, our client suffered mental agony, mistrust and also suffered
financial loss which are solely attributable to you the Noticee.

8. That our client is entitled to special damages on account of mental


torture, agony, financial loss and costs due to your malicious conduct
and actions of conniving with the abovementioned persons.

9. Therefore, through this instant legal notice you the Noticee is requested
to reimburse an amount of Rs. 57,50,000/-(Rupees Fifty Seven Lakhs
and Fifty Thousand Only) to my clients account so that my client can
make all payments and fulfil the workorder and further you the Noticee
is also requested to disallow the department to reimburse/ transfer any
further payments to the account of Mr. Tshanso Yimchunger in relation
to the abovementioned workorder.

10. That through this instant legal notice in order to avoid any legal
repercussions or facing any civil/criminal charges you the Noticee is
requested to reimburse an amount of Rs 57,50,000/-(Rupees Fifty Seven
Lakhs, Fifty Thousand Only) owed to our client along with damages
amounting to Rs. 10,00000/-(Rupees Ten Lakhs Only) and cost of this
notice amounting to Rs.10,000/- (Rupees Ten Thousand Only) within 7
days from the date of receipt of this instant legal notice failing which, our
client has positively instructed to sue you (by making you and your
department officials a party to this suit) in the Court of Law at your cost
and has also given clear instructions to file civil as well as criminal
proceedings against you and your department officials in the competent
courts of law for your above illegal conduct and in that event you shall be
fully responsible for the same. This is also without prejudice to pursuing
actions against you that are unbecoming of a Government official.

11. A copy of the present Notice is duly retained by our office, for records
and future action.

With Regards,

[HUKAVI ZHIMOMI]

(ADVOCATE)

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