Home

Correspondence Address:-
27, Western India Building, 3rd floor, P. M. Road, Fort, Mumbai- 400 001
Ref No. 01/PHS/10
18th December 2010

To,
Ashok Kumar Singh
Advocate for Surjeet Kaur Singh
302, Gundecha Chambers,
Nagindas Master Road, Fountain,
Mumbai- 400 023

REF: Your letter dated 7th December 2010

Under the instruction and on behalf of my clients (1) Shri. Paramjeet Harbhajan Singh Deogun and (2) Smt. Rajendar Kaur Paramjeet Singh residing at Room No. 10, Krishna Cottage, Coldongri, Lane No. 3, Sahar Road, Andheri (East), Mumbai- 400 069 who have placed captioned notice in my hands and in reply to the captioned notice I herby state as under:-

  1. It seems that the captioned notice has been addressed by you without the proper facts and material of the case. It seems that your client has not given you proper instructions before the issuing the captioned notice.

  2. The captioned notice issued by you is bad in law and it seems that you client has suppressed the material facts from you and same is issued by your client on instigation of third person who is interested in the premises of your client.

  3. With reference to paragraph no. 1 the same is a matter of record hence same do not require any comment.

  4. With reference to paragraph no. 2 my clients states that right from the year 1981 my client is staying in Bahrain due to his employment. After his marriage my client settled down Bahrain in along with his spouse i.e. addressee no. 2 as he was already having good job in Bahrain. During vacation time of his kids, my clients use to come down to his home town i.e. Mumbai and on that occasion for a limited period of time i.e. vacation period, he use to stay in the same premises with your client being he is the only son with whom your client have good relations as compare to other sons. My clients state that even for couple of years your client has accompanied my client in his Bahrain house. The content of rest of paragraph is...