By RPAD

To, Date: 15.08.2023

1. M/s. R.J.Rishikaran Projects Pvt. Ltd,

Represented by its Managing Director.

Having corporate office at

LEGAL NOTICE
Dear Sir

Under the instruction of our clients Smt.Radha.N.P W/o Santhosh Kumar.T, aged about 36
years, residing at No: E-20, Brigade Goden Triangle, Huskur Village, Near Kattamnalur Gate,
Virgonagar Post, Bangalore East_560049, we are causing this notice as under:

1. Our client instructed us to state that, Mr.Rathnakar Shetty managing Director of M/s
R.J. Rishikaran Projects Pvt. Ltd, Represented during the year 2018 that, M/S Mysore
Metal Industries, is the absolute owner of the Immovable Property being the converted
land measuring about 1,15,315 Sq. ft., in Survey No.40/1, Municipal No.272/219,
situated of Bhattarahalli Village, Bidarahalli Hobli, Bangalore East Taluk, presently
under the Bruhat Bangalore Mahanagara Palike and assessed to taxes as,
Bhattarahalli, K.R. Puram Ward, Bangalore, more particularly mentioned and described
in the schedule 'A' to the construction Agreement dated 26.06.2018".

2. Our client instructed us to state that, you have further represented that, M/s R.J.
Rishikaran Projects Pvt. Ltd, has entered into a Joint Development Agreement dated

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 26.05.2013 for the development/sale of the Schedule 'A' Property with the M/S Mysore
Metal Industries, which is registered as No.4040/2013-14 in Book-l, stored in C.D.
No.INRD74 and also executed a Power of Attorney dated 26.05.2013 same is
Registered as No. 455/2013-14in Book IV, stored in C. D. No. INRD 74 which are
registered in the office of the Sub-Registrar, Indiranagar, Bangalore in the Office of the
Sub-Registrar, Indiranagar, Bangalore for the development of the Schedule 'A' Property
to the construction Agreement dated 26.06.2018".

3. Our client instructed us to state that, you have formed a scheme for the development of
the Schedule 'A' Property into two Residential Blocks consisting of Apartments and
prepared the necessary plans and submitted to the Bruhat Bangalore Mahanagara
Palike for its Sanction. Wherein the Bruhat Bangalore Mahanagara Palike has
sanctioned the Plan vide L.P. No. ADDL.DIR/JD NORTH/LP/0055/13-14 dated 4/7/2013
issued by the Joint Director (Town Planning - North), Bruhat Bangalore Mahanagara
Palike, for the development of the Schedule 'A' Property to the construction Agreement
dated 26.06.2018".

4. Our client instructed us to state that, further you have represented that as per the said
scheme you will construct a Multistoried Residential Tower to be known as "R.J. LAKE
GARDENIA" comprising of two Residential Blocks consisting of two Basements, Ground
and Upper 27 Floors with common entrance, staircases, lift, passage, along with
common amenities and facilities and by virtue of the Joint Development Agreement you
are entitled to nominate purchasers to the extent of 63% of Undivided share in the
Schedule 'A' Property and receive consideration for the sale of the undivided share in
the land directly from the prospective purchasers as per the terms of the Joint
Development Agreement.

5. Our client instructed us to state that, further you have represented that, M/S Mysore
Metal Industries and M/s R.J. Rishikaran Projects Pvt. Ltd have mutually agreed and
identified the Apartments falling to your respective shares in the said building to be
constructed on the Schedule 'A' Property as per the Sharing Agreement dated
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 25.09.2013.

6. Our client instructed us to state that, you have agreed for the sale of proportionate
undivided share, right, title and interest in the land comprised in the Schedule 'A'
Property to the construction Agreement dated 26.06.2018", which share is more
particularly mentioned and described in Schedule 'B' to the construction Agreement
dated 26.06.2018, based on your assurance and undertaking, our client has entered an
Construction agreement and Agreement of sale of Undivided share on 26.06.2018 and
as per the said scheme you have agreed to get constructed an Apartment bearing No
B-203 on 2nd Floor in 'B' Block, having a super built up area of 2150.29 Sq. ft., along
with Two car parking spaces in the Multistoried Residential Tower known as "RJ LAKE
GARDENIA" which is more particularly mentioned and described in the Schedule 'C' to
the construction Agreement dated 26.06.2018.

7. Our client instructed us to state that, as per the Construction agreement dated
26.06.2018, the total consideration Rs:1,15,30,456/- which includes undivided share,
Maintenance charges, construction cost and other charges as mentioned in Annexure
to the constriction Agreement dated 26.06.2018 accordingly entered in to above said
Construction agreement and Agreement of sale of Undivided share on 26.06.2018, out
of total consideration of Rs:1,15,30,456/- (Rupees One Core Fifteen Lakhs Thirty
Thousand Four Hundred Fifty Six Only), and our client has paid an amount of Rs:
40,00,000/- (Rupees Forty Lakhs Only), our clients has to pay balance amount as per
the schedule mention in Annexure-1 (a) (c) and Annexure-1 (b) (c) to the said
construction Agreement.

8. Our client further instructs us to state that, upon entering into the Construction
agreement and Agreement of sale of Undivided share dated 26.06.2018, our client has
paid an amount of Rs:3,00,000/- by way of cheque bearing No: 972289, dated
26.06.2018 drawn on SBI, Battarahalli Branch as advance and subsequently our client
has availed the loan from Bank of India for the tune of Rs:75,00,000/- (Rupees Seventy
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 Five lakhs) and paid an amount of Rs:40,00,000/- to you directly from his loan account
you have accepts and acknowledges the receipt of the said sum of Rs: 40,00,000/-
(Rupees Forty Lakhs Only) on various dated as pert the terms of the said Construction
Agreement.

9. Our clients further instructs us to state that, even though our client has made the
payments promptly as per the Construction Agreement, you have not completed the
construction as agreed under the Construction agreement dated 26.06.2018, within time
stipulated i.e. within 31st July 2019 with a grace period of 6 months.

10. Our client further instructs us to state that, subsequent to execution of Construction
agreement dated 26.06.2018 in favour of our client, you had promised to complete the
entire construction by 31st July 2019 and no such commitment was fulfilled by you,
whenever our clients have been contacted you on personal visits, you have “Kept On
Making Promises Only”. In fact our client has tried her best to convince you in an
honorable manner about difficulties faced by our client but it is unfortunate that you
have come up with false, unwarranted and undignified promises.

11. Our clients further instructs us to state that, our client was monthly interest a sum of
Rs:32,000/- approximately from the date of availing loan towards the purchase of the
schedule Flat,. Our clients instructed us to state that you have collected monies from
our client and have failed to complete the work and handover the possession of the
Flat/Apartment as mentioned in the Construction agreement dated 26.06.2018, though
you have collected the substantial consideration, you have not bothered to complete the
work only with malafide intentions of cheat our client of her hard-earned monies.

12. Our Clients instructs us to state that, when our clients have approached you in a good
faith, you will rectify all your mistakes and complete the work. However, to her
disappointment, and she has put to such a misery and hardship due to the negligence
on the part of you. The erroneous and negligent act by you, our client inflicting hardship
and mental agony is nothing but your deficiency of service.
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13. Our client instructs us to state that, subsequently due to the delay on your part our client
decided to annul the Construction agreement and Agreement of sale of Undivided share
dated 26.06.2018 and in spite of several requests and demands by our client you have
agreed to cancel the said Construction agreement and Agreement of sale of Undivided
share dated 26.06.2018 and agreed to pay interest on the amount paid by our client,
accordingly our client has handed over the all original documents to you vide letter
dated 02.04.2019 and request you to repay amount paid by our client.

14. Our client further instructs us to state that, in view of the cancellation of the Construction
agreement and Agreement of sale of Undivided share dated 26.06.2018 you are liable
to pay an amount of Rs:40,00,000/- along with interest and damages to our client as
you were not kept up your promises and made our client to pay interest from
07.09.2018 till 30.12.2020 on amount of Rs:75,00,000/- availed loan for the purpose of
purchasing the above said Flat, due to your acts our client has suffered huge monetary
loses and caused mental agony and humiliation in the society.

15. Our client further instructs us to state that, when the matter stood thus, you have taken
signatures on certain blank papers and without paying any interest or damages to our
client, you have repaid only principal amount of Rs:40,00,000/- on 30.12.2020 which is
nothing but unfair trade practice on you part, the said repayment without interest and
damages paid to our client is unjustifiable even after enriching from the hard earn
money of our client and our client has paid interest approximately Rs:_____ towards the
loan taken from Bank of India; Hence you are liable to pay interest and damages.

16. Our Clients instruct us that, as you promised during the promotional meeting and
negotiations to complete the constriction work within agreed time i.e. before 31 st July
2019, you were not kept up your promises and obligations and such your acts amounts
to unfair trade practice, which has caused mental agony to our Clients and financial
losses due to your incomplete works, and they are also entitled take necessary legal
action against you.
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 17. Our clients instructed to state that, due to the non-adherence of the promises and
obligations from your end is causing great hardship and financial loss to our clients as
such you are liable to pay interest on the sale consideration @ 24% P.A from the date
of payment made by our client till repayment on 30.12.2020 and in addition to this you
are also liable to pay for the tune of Rs: 10,00,000/-, towards mental agony,
harassment and damages suffered by my client.

Wherefore, In view of the above mentioned facts and circumstances, you are hereby
called upon to pay interest on the sale consideration @ 24% P.A from the date of
payment made by our client till repayment i.e. on 30.12. 2020 on amount of
Rs:40,00,000/- and to pay an amount of Rs: 10,00,000/- (Rupees Ten Lakhs only)
towards the costs and damages for the mental harassment and suffered by our client,
within fifteen (15) days of the receipt of this legal notice, failing which our Client shall be
constrained to take appropriate legal action both civil and criminal against you at your
cost for which only you will be held responsible.

The charges of this notice is Rs.20,000/- is payable by you to our client.

Thanking you
R.Narayanaswamy
Advocate

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