NOTICE REPLY ON BEHALF OF THE TENANT

TO THE ADVOCATE OF THE LANDLORD

SUDHAKAR E. AVHAD,                                    16/1 Siddharth Chambers,
B. Sc. (Hons); LL. M.,                                            Erandwana, Karve Road,
ADVOCATE.                                                       PUNE 411 004
     Phones: 5431424, 5431434
     Dated............

NOTICE-REPLY (REGISTERED A.D.)

To
     Shri R. S. Metawade,
     Advocate,
     C-4/10, Shantiban Society,
     S. . No. 52/1, Kothrud,
     PUNE 411 038.

Dear Sir,
Your notice, dated........given by you on behalf of Shri LND, 250 Shivajinagar, Pune, and addressed to my client, Shri TNT, 250 Shivajinagar, Pune, has been placed in my hands with instructions to reply thereto as follows :
1. That the contents of para 1 of your notice are true and correct, and hence need no comments.
2. That the contents of para 2 of your notice are likewise true and correct, and hence call for no comments.
3. That the contents of para 3 of your notice are also true and correct, and hence admitted by my client.
4. That   the contents of para 4 of your notice are partially true and partially misleading, and my client makes it clear that the said amount of rent is inclusive of all other taxes and charges.
5. That   the contents of para 5 of your notice are totally false and frivolous, and while denying the same, my client states that as your client refused to accept the monthly rent, my client has always had been sending the amounts towards the same by money orders, and hence, my client has never become a defaulter within the meaning, interpretation and provisions of law.
6. That the contents of para 6 of your notice to the effect that my client has erected any permanent structure in the premises are totally false and hence denied by my client in to.
7. That the contents of para 7 of your notice to the effect that my client has purchased any flat in the so-called society amount to a sheer piece of fabrication on the part of your client, and my client makes it very clear that it is your client alone, and not mine, who has constructed a big bungalow at Kothrud, and for the last three and a half years of so, your client has also shifted his own residence there, and as such, the boot is on the other leg.
8. That the contents of para 8 of your notice to the effect that my client has sublet the said premises are imaginary and false, and hence denied by my client categorically.
9. That the contents of para 9 of your notice regarding the so-called annoyance and nuisance are false, and since they are the inventions of your client, my client does hereby deny the same.
10. That my client furthermore adds that since your client has himself constructed a new bungalow and already shifted his residence there, he does not require any premises for his personal bonafide occupation, much the less the premises in possession of my client.
11. That in the circumstances, you are hereby requested to appraise your client of the fact that he has no right or authority to terminate the tenancy of my client and that my client is not liable to vacate the premises, and also that he has no cause to take any legal action against my client, and if, despite all these facts, your client were to choose to do so, he shall be doing so at his own responsibility as to the costs and consequences, and in that event, your client shall have to thank none but himself for his own illegal action, which please ask your client further to note.
12. That my client is not liable to pay any costs of the said notice, which please ask your client also to note.
13. That as the said illegal and unwarranted notice has necessitated this notice-reply, your client is hereby charged with its costs, i.e. Rs. 1,000/-, which please ask your client lastly to note.
          Yours faithfully, 
(SUDHAKAR E. AVHAD)
             ADVOCATE.