Under the authority and instructions on behalf of my client, Pradeep Khandelwal, presently resident of AM-141, Shalimar Bag Delhi-110088, hereinafter referred to as my client, I issue you the following legal notice the circumstances necessitating are as under-
1. That my client was inducted as tenant in respect of the IInd Floor “barsati” premises in property bearing no. D-102, Defence Colony, New Delhi. The said premise was let out by your father to my client in December 2006. That my client since then till February 2012 had been living in the said premises as tenant and was regularly paying the agreed rent and other charges for the said premises regularly to the landlord and till his demise and thereafter to his widow Shrimati Pushpa Devi.
2. That after the demise of Shrimati Pushpa Devi, your mother, the above addressee, you were collecting the rent and other charges of the said premises while there were the property disputes with regard to its inheritance between you and your brother who is presently living in the USA.
3. That you used to call my client to the second Floor for consulting your family problems and when my client provided all sorts of such assistances at times of need. You always insisted my client to stay on ground floor during most of the day time. That my client use to spent entire day time available with him in the ground floor and going to the tenanted premises in the ‘Barsati’ Floor only during nights while continuing to use the same for his residence and other use to suit his own convenience.
4. That with the passage of time, certain differences started simmering up between you and my client which had led to the filing of false reports by you with the police against my client. That on 23.02.2012 you made a false complaint against my client in which you alleged serious allegation on my client such as physical assault, criminal intimidation destruction of physical property, etc. That in pursuance that complaint Kalandara proceeding was initiated against my client under section U/s 107 and 131 of Cr.P.C in which my client was discharged of the allegation made by you.
5. That you the above addressee to fulfil your personal grudge and revenge against my client, you made a false and fabricated complaint of stealing of virtual identity against my client before before Cyber Crime Cell the same was referred for the Kalndara Proceedings before the court of S.E.M/ South. in which my client has been discharged of the offences.
6. That the court of S.E.M/ South after conducting the proceedings found no evidence against my client and discharged my client from all the allegations levelled against him.
7. It is submitted that you the above addressee filed the baseless, vexatious and concocted complaint against my client only to harass and tarnish the image of my client in the society and locality. It is pertinent to mention here that you the above addressee wants to take advantage of your own wrong and filed the false and fabricated complaint against my client only to pressurize him.
8. That your allegations were absolutely defamatory and derogatory in nature and has caused grave mental torture, pain, agony and sufferings to my client who is man of reputation and goodwill and is having the good base in the society and working place but you the above addressee fraudantly and maliciously and out of ill will and personal grudge have levelled the aforesaid defamatory and derogatory allegations against my client with sole malafide intention to malign the reputation, dignity, honour of my client in his own eyes as well as in the eyes of common friends, colleagues and other staffs at working place.
9. That you the above addressee have ruined the reputation, dignity, honour and self respect of my client and have made my client a scornful object among society members and the people at the place of work and my client has received grave mental depression and set back and the injury suffered by my client can only be experienced but can not be explained in words. I therefore, call upon you the above addressee through this legal notice to tender unconditional apology for levelling the defamatory allegations against my client by filing a false, fabricate and vexatious complaint of identity theft before Cyber Crime Cell, in writing within one week from the date of service of this legal notice upon you and if you fail to comply with the demand of this legal notice than my client claims a sum of Rs.20.000,00(Rs. Twenty Lac) from you the above addressee on account of loss of reputation, dignity and honour and you the above addressee being the author of defamatory allegations are legally liable to pay the damages and compensation to my client and take notice that my client has strictly instructed me to institute the civil and the criminal proceedings for defamation against you the above addressee at your risks and costs. You are further liable to pay a sum of Rs……../- to my client being the cost of this legal notice.