Legal Notice - Draft
To,
Mr. M R Shahid
Butt
S/O A R Butt,
House No: R-89,
Poineer Fountain, Sector
16-B, Scheme – 33,
Karachi.
LEGAL NOTICE
Sir,
Under
instructions & on behalf of my clients (1) Mrs. Na Gull W/O M Ta Gull & M Ta Gull S/O Me Gull. Muslim, Adult,
Presently Resident of House No: 1730/766, Habibabad, Rasheedabad, Baldia Town,
Karachi, I have to address / notice you as under:
1. That
Pursuant to the provisions of Sindh
rented premises ordinance, you are
hereby given an eviction notice and notice to vacate, on or before 15/01/2017, the premises i.e House No: R-89,
Poineer Fountain, Sector 16-B, Scheme – 33, Karachi, owned by my clients. The reasons for this eviction notice are:
A) Your failure to pay rent due
and in arrears when demanded. A demand to pay rent was served upon you by
my clients orally on 2nd
week of December 2016, and you have refused and neglected to pay same.
B) The landlords
require the premises in good faith for their own occupation or use or for the
occupation of their mother and children.
C) You without the
written consent of the landlords have handed-over the possession of the
premises / sub let the portion of ground and 2nd floor to some other
person.
D) You are a accused
of theft of electricity and making fake rent agreement. On account of the
utility bill of electricity, which is more than Rs:181906/= (One Lac Eighty One
thousand nine hundred & six rupees) is left to payable. Further you have
tried to sale out the premises by cheating & fraud through state agents of locality.
Thereafter to pressurize & blackmail, you have moved false complaint at
Police Station Sachal, against landlords. Such acts also as are likely to impair
the material value or utility of the premises.
2. Further in
contravention of above factual position you are committing irresponsible &
offensive acts, for which my clients have also suffered a loss of time &
money, mental torture, loss to personal reputation, which cannot be measured in
terms of money but for the purpose of recovery these amounts through the court
of law, they assess it to the tune of Rs. 250,00,000/= [20.5 million]. To
recover these compensatory costs from your personal assets / properties, my
clients have got finalized the pre-litigation process. No doubt, further delay
at your part in accepting the rights of my client is in addition to basis for
which you will be liable to account for the costs and consequences of
litigation also.
At
the same time I want to caution you that in above said factual situation keep
yourself in right direction and accept the right of my clients i.e (1) hand
over vacant peaceful possession of premises to my clients (2) Pay compensatory
costs - Rs. 250,00,000/= [20.5 million], with in date & time specified
above. Because my clients will not succumb to any pressure tactics instituted
by you and I have definite instructions to proceed against you, entirely at
your sole risk as to cost and consequences, in the court of law Civil/ Criminal,
for which please note.
Yours
Sincerely,
Farhan Khaliq Anwer,
Advocate.
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