Ref: JD/101/2015 16th September

2015

By Registered Post A.D. / Speed PostWithout Prejudice

To, Soni Jaysukhlal Shantilal Near Mama’s Chhipar, Palitana, Taluko: PalitanaDistrict: Bhavnagar

Dear Sir,

Subject: Legal Notice Reference:

1. The ‘Satakhat’ – An Agreement to sell of the Land (Non-agricultural) dated 14th of August 2014

I, the undersigned, under the instructions of my client, Shree Jagjivanbhai Lakshmanbhai Umaralia, aged 82 years, Hindu, Indian, Occupation: Retired; having its registered residential address at Bungalow No. 35, Jaldhara I - Bungalows, Near Pushpak Bungalows, Opposite: Bopal Gram Panchayat, Bopal, Ahmedabad , Gujarat; India, I am addressing this legal notice to you, among other things, for your wilful failure and deliberate action of breaching the terms and conditions of the agreement resulting into breach of trust and fraud towards my client.

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1. That the details of the Land in dispute is enumerated herein below:

1.1. Non- Agricultural land with the vicinity of Bhavnagar District situated at Palitana Gam, Taluka, Palitana bearing Revenue Survey No. 297 admeasuring 9713.42 Sq. Ft. known as ‘Gunoday Puram’; out of which from Plot. No. 5 to Plot. No. 13 admeasuring in total 1049.42 Yards.

2. That you along with Soni Suryaben Jaysukhlal, Soni Jigneshbhai Jaysukhlal, Soni Hardikbhai Jaysukhlal, Soni Bhavinbhai Jaysukhlal have entered into an agreement to sell the land mentioned above with my client by way of an agreement to sell (‘Satakhat’) dated 14th of August 2014.

3. That under the terms and conditions of the same, a valid due consideration in monetary form having huge worth is been paid to you all, in presence of you all with an honest intention to purchase the said Land.

4. That it was also mutually agreed between the parties that the documentations and other formalities including registration would be executed in due course of time.

5. That, however, even though it’s been more than a year today from the date of an agreement, even after various attempts by my client to pursue you to execute the final Sale Deed in

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favour of my client and implement the agreement dated 14.08.2014, you, all have kept on delaying the same by making frivolous trivial excuses.

6. That the wilful inaction on your part has given birth to the reasons into the mind of my client and upon the investigation, my client has come to know that, you have along with the parties to the agreement have committed fraud with my client specially by breaching the terms and conditions of the agreement. Upon the investigation by his resources my client has come to know that you all have hidden the very fact that earlier to the agreement dated 14.08.2014, you all (the same parties) have entered into the same kind of ‘Satakhat’ with another person named Navinchandra Khimaji Nagda for Plot No. 5 to 11 for the same property on 04.04.2014.

7. That at the time of agreement with my client, my client was kept completely into dark and has never been disclosed the information as to the same parties have entered into an agreement to sell for the said property bearing Plot No. 5 to 11 and have also taken a valid consideration to that effect. My client is shocked to know that even after a satakhat which existed earlier, the agreement was entered including the said property which was already promised to sell by way of an agreement dated 04.04.2014. The height was reached because the valid consideration was also taken from Mr. Nagda.

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8. That upon realisation of the same, my client personally visited the said land and to the at most shock and surprise, my client came to know that upon the said land i.e. from Plot No. 5 to Plot No. 11, the construction is already on the verge of finishing. My client has all the reason to believe from the investigation that, the said land is sold to some third party which was never a part or person interested at the time of ‘Satakhats’ in question. The step-by-step process undertaken by you all clearly depicts the criminal intention of you all and is in facto sufficient.

9. That under the circumstances, I, therefore, call upon you through this legal notice to explain immediately within a period of 15 days from the date of receipt of this legal notice, explaining the reasons as to why civil and criminal actions shall not be initiated against you, failing which my client shall constrained to file appropriate proceedings against you in the court of law and in that event you shall be responsible for all costs, risks and responsibilities which you please note well. Kindly note that time is the essence and has to be complied with in strict sense.

10. That my client reserves all the rights and liberty to mention the facts and truth on record as and when required along with the documentary evidence of them. Please note that, this is a notice with a view to reconcile the talk on papers so that, the amicable settlement can be worked out. Hence,

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my client reserves liberty to bring them on record in case needed.

11. A copy of this legal notice is retained in my office for record and further necessary action.

12. Further, any other kind of harassment or silence or inaction from you towards my client and/ or the parties to this notice or any endeavour would be taken as mental harassment of my client resulting into litigation in the appropriate court of law.

Kind regards,

Jagruti Dekavadiya, AdvocateManaging Partner

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