Thursday, May 27, 2010

Legal Notice for Recovery Amount of Salary

Ref No………                                                             Dated __________

Registered A.D./UPC

Legal Notice.

To,
________________

Through its Managing Director _____


Sir,

Under instruction and on behalf of my client ____, Resident House No._____, _____, I do hereby serve you with the following notice:-

1- That my client was appointed by you vide your offer letter dated ____ as ____ and the salary of my client was fixed at Rs. ____ /- per month vide your offer letter dated _____. But my client joined him/her duty on _______ with you

2- That my client did her duty diligently, regularly and with utmost punctuality sincere, and with full devotion by doing manual job with her own hands in accordance with the well-settled provisions of the law. You issued the offer letter in the name of my client and got printed the visiting cards also in the name of my said client.

3- That on ______ when my client went to attend him/her duty then you abruptly refused to allow to my client to attend him/her duty and told that services of my client are no more required by you and thus the services of my client have been terminated by you in a most illegal and unlawful manner without any reasonable rhyme and cause. At the time of termination of the services of my client, you did not pay the salary for the month of ________ and ____ days salary for the month of ________ which comes to Rs. ____/- to my said client.

4- That my client visited your office from ____ to ____ from time to time and spent a huge amount of Rs. ____/- on the charges of traveling /conveyance charges but you refused to pay the outstanding amount of Rs. ____/-. Lastly on ____ you clearly refused to pay the salary amount of Rs. ____/- to my client

5- That you did not provide me statutory benefits i.e. ESI & P.F. etc. You also did not pay the salary of Rs. ____/- and the amount of bonus and other service benefits which totally comes to Rs. ____/-

I, therefore, call upon you through this Notice, to make the payment of the ____/- to my client along with interest up to date, under intimation to me, within the period of 15 days, failing which my client has given clear instructions to me to file criminal as well as civil suit and Suit for Recovery in the competent court of law and in that event you will be fully responsible for all costs, risks, responsibilities, expenses and consequences thereof. Please note well.

A copy of this Notice is kept intact in my office for record and further necessary action and you are also advised to keep the copy of the same as safe as you would be asked to produce in the court.

Thanking you,

____ Advocate ____

Tuesday, May 4, 2010

Application for Legal Notice to hand over the No Dues Certificate and Hypothecation Clearance Certificate

BEFORE THE PRESIDENT DISTRICT CONSUMER DISPUTES REDRESSAL FORUM, _________

___________________

…..Complainant

versus

____________________

……..Respondent


Complaint Under Section 12 of the Consumer Protection Act 1986 Amended up to date


Sir,

The complainant respectfully submits as under: -

1- That the complainant is a consumer of the respondent and the as defined under the relevant provisions of the consumer protection Act.

2- That the complainant purchased a vehicle _________ bearing its Registration No.__________, Model ______, Chassis No. _________, Engine No. __________ from Shri ________ son of Shri __________, resident of ____________, on or about ____________.

3- That at the time of purchasing of the said vehicle it was financed with the respondent and __ installments were due and payable to the respondent by the complainant. The complainant deposited the said __ installments with the respondent without any delay on his part and now nothing is due and payable by the complainant to the respondent. It is pertinent to mention here that some of the installments were got deposited by the complainant in the name of ________ and some of the amount deposit slips were deposited by him in his own name. Some extract amount has been deposited with the respondent.

4- That in the month of ________, _____ the complainant met with the respondent and asked the respondent to hand over the No Dues Certificate and Hypothecation Clearance Certificate of the _______ No. __________ to the complainant but the respondent kept on avoiding the requests of the complainant on one pretext or the other and finally on _______ the respondent demanded an exorbitant, illegal and imaginary amount of Rs. _________/- from the complainant and threatened the complainant until and unless the complainant would not make this illegal and unlawful amount of Rs. __________/- till then the respondent would not issue No Dues Certificate and Hypothecation Clearance Certificate to the complainant. In this way the respondent has committed the criminal wrongs for which the complainant reserves his right to file appropriate proceedings against the respondent in the competent court of law against him.

5- That the complainant sent a legal Notice dated _________ calling upon the respondent to handover the No Dues Certificate and Hypothecation Clearance Certificate of the ________ No._________ and Rs. _______/- as charges of this legal Notice, to the complainant within the period of __ days from the date of receipt of this legal notice. The said legal Notice was accepted by the respondent and sent reply of the same which was quite unsatisfactory. The copies are enclosed.

6- That by not handing over the No Dues Certificate and Hypothecation Clearance Certificate of the _______ No._________ to the complainant the respondent has caused mental agony, mental shock, and harassment to the complainant unnecessarily. There is deficiency in the service on the parts of the respondent therefore the complainant is entitled Rs. ________/- on account of mental tension, agony and harassment suffered by him at the hands of the respondent. The complainant is entitled to receive No Dues Certificate and Hypothecation Clearance Certificate of the _______ No.________ from the respondent.

7- That the complainant is and the respondent reside at _________ and entire cause of action accrued at __________ within the territorial jurisdiction of this Hon’ble Forum, therefore, this Hon’ble Forum has got the jurisdiction to entertain and try the present complaint.

PRAYER:

It is, therefore, prayed that in view of the forgoing facts and circumstances this hon’ble court may kindly be pleased to:

i) Pass an order directing the respondent to hand over the No Dues Certificate and Hypothecation Clearance Certificate of the ________ No._________ immediately .

ii) Pass an order directing the respondents to pay Rs. _______/- to the complainant on account of deficient service of the respondents and for the mental tension, agony and harassment suffered by the complainant at the hands of the respondents.

iii) Costs of this petition may kindly be awarded in favour of the complainant and against the respondents.

iv) Any other relief, which this Hon’ble Forum may deem fit and proper, be passed in favour of the complainant and against the respondents.

Dated______
COMPLAINANT

________ son of Shri _________

resident of ___________,

_____________

Through counsel:

__________, Advocate, ____________.

Monday, May 3, 2010

Legal Notice for Dues Recovery or Application for Recovery of Dues

Ref. No…………….    Dated ____, __________




REGD.A.D.

LEGAL NOTICE

To,

_____________

Dear Sir,

Pursuant to the instructions from and on behalf of my client ___________________, through its _____________, I do hereby serve you with the following Legal Notice: -

1- That my client is a ___________ firm under the name and style of M/s ______________________.

2- That my client is engaged in the business of __________ of the ___ etc.

3- That against your valid and confirmed order my client did your job work from time to time on credit basis as you have running credit account in the account books of my client operated in due course of business.

4- That my client-raised bills of each and every work performed for payment, although you have acknowledged the receipt of such bills raised by my client.

5- That inspite of acknowledging the liability of payment of principal balance of Rs. _________/- you have been miserably failed to make payment of the said amount due to my client from you deliberately with malafide intent, hence you are liable to pay the said principal balance amount of Rs. __________/- alongwith interest @ __% p.a. from the date of due till actual realization of the said sum as is generally and customarily prevailing in the trade usages, which comes to Rs. __________/-

6- That thus you are liable to pay the total amount of Rs. ________/- to my above named client and my above named client is entitled to recover the same from you.

7- That my client requested you several times through telephonic message and by sending personal messenger to your office for release of the said outstanding payment, but you have always been dilly delaying the same on one pretext or the other and so far have not paid even a single paisa out of the said outstanding undisputed amount.

I, therefore, through this Notice finally call upon you to pay to my client Rs. __________/-. along with future interest @ __ % p.a. from the date of notice till actual realization of the said amount, together with notice fee of Rs. ____/- to my client either in cash or by demand draft or Cheque which ever mode suits you better, within clear 15 days from the date of receipt of this notice, failing which my client has given me clear instructions to file civil, criminal., suit for recovery and other Misc. proceedings against you in the competent court of law and in that event you shall be fully responsible for the same.

A coy of this Notice has been preserved in my office for record and future course of action.


(____________)

ADVOCATE

Application for Legal Notice Purchaser

Contact/Mobile: ____
___________, District & Sessions Courts, _________

I, therefore, through this legal Notice call upon you to execute and register the sale deed in respect of the above mentioned ____ in favour of my said client after receiving the balance sale consideration of Rs. ____/- within the period of __ days from the date of receipt of this Notice, failing which my client has given me clear instructions to file civil, criminal and suit for specific performance of the contract and other Misc. proceedings against you in the competent court of law and in that event you shall be fully responsible and pay the charges of this Legal notice i.e. Rs. ____/- to my said client.


Copy kept in my office for record.

_____________, ______

For Grant of Anticipatory Bail in Case under Section of Electricity Act Police Station

IN THE COURT OF HON’BLE SESSIONS JUDGE, ___________




Application No.________ of _______



______ son of _________

R/o ____________,

________, __________

…Applicant/Petitioner.

Vs.

State of __________



………….…Respondent.



1st Application Under Section ___ ___ For Grant of Anticipatory Bail in Case FIR No.___ dated ____ Under Section ___ of Electricity Act Police Station ________.



Sir,



The applicant/petitioner most respectfully submit as under: -

1- That the applicant/accused has been falsely implicated in the above noted case by the S.D.O., _____, _________ and on the instance of the SDO, the said police registered the said case against the applicant/accused. The applicant/accused is an innocent person and has no concern with the alleged offence as alleged by the said police.

2- That the said SDO ______, imposed the penalty of Rs. _______/- on dated __________ vide Memo No. _______ dated _________.

3- That the applicant has deposited the penalty amount of Rs. ______/- on dated ________ in the office of S.D.O. , __________. The photocopy of the receipt is enclosed herewith.

4- That the applicant/petitioner is entitled for bail on the following grounds :-

Grounds of Bail:

(a) That the applicant/petitioner has already deposited all the amount of penalty before the office of __________. The photocopy of the same are enclosed herewith.

(b) That now the police of P.S. _______, _________ and is visiting the house of the applicant and is unnecessarily harassing the applicant.

(c) That the applicant/petitioner undertakes to join the investigation as and when required by the police of police Station ________, ___________.

(d) That there is no apprehension for absconding or evading of taking trial.

(e) That the applicant/petitioner undertakes not to temper with the evidence or witnesses.

(f) That the applicant/petitioner undertakes for not to leave India without the prior permission and consent of the Hon’ble court.

(g) That the applicant/petitioner undertakes to abide by all the terms and conditions as imposed by the Hon’ble court in the event of bail.

(h) That in such type of false cases the bail is rule and refusal of the bail will not serve any purpose.

It is, therefore prayed that the applicant/petitioner may kindly be released/granted anticipatory bail and the SHO concerned/ I.O. of concerned police station _______, _________ may kindly be directed to release the applicant/petitioner on bail in the event of his arrest



Dated :_____ Applicant/Petitioner


______ son of Shri _______ R/o
 ________, _____________



Through counsel:

____________, Advocate, _________