REGD. POST / EMAIL
To,Dt. Date of reply
Advocate's name
Advocate
Advocate's address line 1
Advocate's address line 2
Advocate's city,
Pincode.
Email: Advocate's email address
Ref: Reply to your legal notice dated Date of legal notice being replied to issued on behalf of your client Landlord's name against my client.
Dear Sir,
With 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 thereto as under:
At the very outset, I wish to inform you that your notice is based on wrong, false and incorrect information, and it appears that your client has not supplied you with true and complete information. As such, the contents of your notice are false, frivolous and baseless, except where the same are specifically admitted by my aforesaid client. Had you been aware of the actual ground situation, you would yourself have appreciated the true position and would have endeavoured to persuade your client so that good sense prevailed. However, I wish to clarify and reply to your legal notice in the following paragraphs.
The notice under reply is based on false and frivolous facts and is, as such, liable to be withdrawn by your client outright.
1.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 specifically admitted in the following paragraphs.
2.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 three (3) years, at the agreed monthly rent of Rs. Monthly rent (₹)/-, and the said rent deed was signed by your client. The rate of rent was to be enhanced as per the provisions of the DRC Act.
3.That 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 be clear that the amount deposited with your client exceeds the alleged arrears.
4.That nowhere in the entire notice has your client explained any bonafide reason for the termination of my client's tenancy; hence, the termination is illegal and unreasonable. My client is not in a position to vacate the subject premises with immediate effect, as the premises are being used for commercial purposes and a large quantity of goods is lying therein for work to be carried out in advance. The termination of tenancy at this stage is therefore 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 demonstrates the malafide 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.
5.That my client has always paid rent on time, which is evident from the bank statements of my client. My client is surprised to receive such a vague notice and to see such fabricated liability as alleged by your client. All these activities of your client demonstrate malafide intention and a sole intent to harass my client, which is evident from the fabricated contents of the notice.
6.That, by these activities of your client, it is clearly evident that your client has furnished you with false and unreliable information which has no ground reality. My client shall therefore take strict action against your client for such malafide conduct, and without any doubt, your client shall be liable for the same.
7.That my client is in shock and surprise as to how your client has cooked up such fake and false stories which have no ground reality whatsoever. My client has accordingly instructed me to initiate strict legal action against your client if your client does not withdraw this notice, and my client is not liable to pay any damages.
8.That the grounds and contents raised in your notice are false, unknown, shocking and frivolous. The contents of the notice under reply are wrong and are denied as stated.
9.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 and interests. Please note that our client is also entitled to claim compensation for any losses suffered as a result of the false and frivolous claim of your client.
10.Please note that, in case your client initiates any legal proceedings against my client, your client shall do so at its own costs, risks and consequences thereof. Any threatened action which your client chooses to take shall also be at its own costs, risks and consequences thereof.
11.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 shall initiate appropriate proceedings.
12.This reply has no legal force; nevertheless, if your client proposes to take any legal action against my client, your client shall do so at its own costs, risks and consequences thereof, which you may kindly advise your client.
Copy retained for record.
Advocate's signature name
Advocate