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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