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| Reply to Legal Notice for Specific Performance of Agreement to Sell format |
In the name of ALLAH, the most beneficent, the most
merciful
To,
Raja
Arslan Khan Bhatti
Son
of Farhan Ali Nabeel Khan Gujar
R/o
Pind Nasrala,
Subject: REPLY TO LEGAL NOTICE REFERENCE NO. 20054/21
DATED
I have been
instructed by my client to serve you with reply of legal notice dated
1.
Para No. 1 is admitted.
2.
Para No. 2 is admitted.
3.
Para No. 3 is admitted. The date of payment
of remaining sale consideration of Rs. 1,30,00,000/- (Rupees One Croer Thirty
Lacs only) and transfer of the house No. DK-254544, Street No. 454, Ratta
Amral, Rawalpindi was fixed for 28-10-2021 and in this regard, my client has been
contacting your since 28-10-2021 with the request to pay above the remaining
sale consideration and to get the house in question transferred in your name but
you started delaying the matter and till today you have not made remaining sale
consideration of the house in question. My client is still ready to receive the
remaining sale consideration and to transfer the house in question.
4.
Para No. 4 is admitted to the extent of possession
of the house in question. However, as far as the expenses regarding renovation allegedly
spent by you are concerned, in reply, it is stated that my client never permitted
you to renovate the house in question. So, any expense spent if any, by your on
renovation of the said house is not consent of my client.
5.
Para No. 5 is incorrect, hence denied. The
delay has been caused on your part and not on the part of my client. It is my client, who requested you many times
to pay the remaining sale consideration
and get the house in question transferred in your name but you always shown lack
of interest or unwillingness in this regard. However, my client is still ready transfer
the house in question in your name subject to receiving remaining sale consideration detailed above.
6.
Para No. 6 is incorrect hence denied
vehemently. Detailed has already been given above so same is reiterated here.
7.
In reply to para No. 7, it is stated that
my client is ready to fulfill his part performance i.e ready to transfer of the
house in question in your name after receipt of remaining sale consideration
Rs. 1,30,00,000/- (Rupees One Croer Thirty Lacs only)
Therefore, you are hereby directed to withdraw form the above said legal
notice dated 29-10-2021 bearing reference No. 20054/21 and to pay remaining
sale consideration of Rs. 1,30,00,000/- (Rupees One Croer Thirty Lacs only) and
to get the house in question transferred in your name on or before 10-11-2021, failing which my
client reserves the right to initiate legal proceedings against you in
competent court of law at your own risk and cost
Yours
Counsel name
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