Reply to legal notice disputing termination of tenancy
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REGD. POST / EMAIL
To,Dt.Date of reply
Recipient advocate's name
Advocate
M/s. Law firm name & Co.
Chamber Chamber number, Civil Wing,
Law firm address line,
Law firm address line (city).
Recipient's address
Ref: Reply to your legal notice dated Date of legal notice issued on behalf of your client, Mr. Landlord's name, to my client.
Dear Sir,
In reference to your legal notice dated Date of legal notice addressed to my client, Tenant's name, W/o Tenant's husband's name (hereinafter referred to as "my client"), I have been instructed to reply to the same as under:-
1.At the very outset, I would like to inform you that your notice is based on wrong, false and incorrect information. It appears that your client has not supplied you with the true and complete information, and as such, the contents of your notice are false, frivolous and baseless, except wherever the same are specifically admitted by my aforesaid client. Had you known the ground situation prevailing, you would yourself have understood the whole scenario and would have endeavoured to persuade your client so that good sense could prevail upon him. In any event, I wish to clarify and reply to your legal notice in the following paragraphs.
2.The notice under reply is based on false and frivolous facts, and as such, the same is liable to be withdrawn by your client outright.
3.That my client received the aforesaid legal notice on Date of receipt of legal notice, and the contents of your notice are not admitted and are denied, except to the extent of the contents which are admitted in the following paragraphs.
4.That my client is a tenant of the subject premises on the strength of a duly executed rent agreement dated Date of rent agreement for a period of Tenancy period (years) years, at the agreed monthly rent of Rs. Monthly rent amount (₹)/-, and the rent deed was signed by your client, and the rate of rent was to be enhanced as per the provisions of the DRC Act.
5.Since then, my client has been paying the rent through cheque/cash in the name of your client without any default, and if the calculations are properly made, it would become clear that the amount deposited with your client was more than the arrears.
6.In the entire notice, your client has not explained any bona fide reason for the termination of the tenancy of my client. Hence, the termination is illegal and unreasonable, and my client is not in a position to vacate the subject premises with immediate effect. My client is using the same for commercial purposes, and a large quantity of goods is lying in the subject premises for an advance period of work. Hence, the termination of the tenancy at this stage is illegal and unreasonable. On account thereof, my client will suffer a huge loss of money and reputation, which cannot be compensated in terms of money. This illegal termination is not tenable or acceptable in any manner, and it demonstrates the mala fide intention of your client to defame the goodwill and reputation of my client. This has caused significant harassment to my client, and such behaviour is not tolerable in any manner. Hence, your client has sent the notice under reply based on false and frivolous information.
7.That my client has always paid rent on time, as is evident from the bank statement of my client, and my client is surprised to see such a vague notice and the fabricated liability shown by your client. Therefore, all these activities of your client demonstrate a mala fide intention and a sole intent to harass my client, which is very much evident from the fabricated contents of the notice.
8.Therefore, by all these activities of your client, it is clear and evident that your client is supplying false and unreliable information to you, which has no ground reality. Therefore, my client will certainly take strict action against your client for such mala fide conduct, and without any doubt, your client shall be liable for the same.
9.As such, my client is in shock and surprise as to from where your client has cooked up these fake/false stories, which do not even have any ground reality. Therefore, my client has instructed me to take strict legal action against your client if your client does not withdraw this notice, and my client is not liable to pay any damages.
10.As such, the grounds/contents raised in your notice are false, unknown, shocking and frivolous. The contents of your notice under reply are wrong and are denied as stated.
11.In light of the above, my client requests you to withdraw your notice immediately. If you do not withdraw your notice, my client will have no choice but to take legal action to protect his rights/interests. Please note that our client is also entitled to claim compensation for any losses that may have been suffered as a result of the false and frivolous claims of your client.
12.Please note that in case your client takes any legal proceedings against my client, your client shall be doing so at his own costs, risks and consequences thereof. Any threatened action, if your client chooses to take it, shall be at his own costs, risks and consequences thereof.
13.I trust, however, that by timely action, you will obviate the necessity of any unpleasant steps being taken against your client. It will be in your client's own interest to withdraw the notice, otherwise my client will initiate appropriate proceedings against your client.
14.This notice has no legal force, and yet, if your client proposes to take any legal action against my client, your client shall be doing so at his own costs, risks and consequences thereof, which you may please advise your client.
Copy kept.
(Advocate's name)
Advocate