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ARKJ/LN489-F/01

Jan 03, 2018


Without Prejudice

Mr. Shahid Pervez,


Whole Sale Merchant,
Ashraf Road, Peshawar.

Subject: Legal Notice (Under Registered Postal Cover, Acknowledgement


Due)

Sir,

I have been instructed and duly authorized by Mr. Amjad Siddique son of Muhammad
Pervez, resident of Shami Road, Peshawar (hereinafter referred to as “ My client” to serve
upon you a legal notice, as follows:

1. That My client is a renowned businessman of Peshawar and is appraised for his


integrity and honesty amongst his contemporaries and business circle.

2. That My Client is involved in business of sale and supply of different Food Items
such as Rice, Pulses and Wheat etc.

3. That you entered into a deal of purchase of pulses with my Client and My client
supplied the required items to you on 01/12/2017, for the payment whereof you
provided my Client a Bank Cheque No. 22 99958549 dated 02/12/2017 amounting
to Rs. 3 Millions drawn from Allied Bank Chowk Yadgar Branch Peshawar having
Account title in your name bearing No. PK 54ABPA0010005808440019 .

4. That when my Client presented the Cheque in his Bank i.e. MCB Chowk Yadgar
Branch, Peshawar City for its onward clearance, the same was dishonored and
returned to My Client vide Return Memo dated 02/01/2018 for the reason of
Insufficient Funds in Your Account. (Copy attached)

5. That when My client contacted you and enquired from you for the reasons of not
arranging amount for clearance of his Cheque and why the Cheque was
dishonored, you started making lame excuses and asked my Client to contact you
after few days so that arrangement could be made on your part for fulfillment of
obligation on your part.
6. That since than My Client has numerously contacted you for clearance of his
amount and fulfillment of obligation on your part, but due to your insistent and
stalwart attitude of not arranging amount for onward clearance of the Cheque so
handed over to my Client, My Client has strong reasons to believe that you have no
intention to clear the outstanding amount due against you and are now trying to
deceive and defraud my Client and usurp the amount so outstanding against You.

7. That inaction and non payment of amount due against you explicitly and clearly
postulates that you dishonestly issued the Cheques in name of My Client and after
receiving the items/ goods, you intentionally not arranged for the amount in your
Bank for its onward provision and clearance of issued Cheque in favor of My
Client which act on your part is an offense under the law and you are liable to be
prosecuted for an offence under Section 489-F PPC read with Section 406,419/420
PPC.

You are therefore urged and called upon in your own interest to clear the outstanding
amount of Rs. 3 Millions and honor your obligation within seven days from the receipt of
this Notice. In case of defiance, I have been specifically been directed to hold you
personally responsible and accordingly file a recovery Suit in the Court of Competent
Jurisdiction at your sole risk and costs besides lodging an FIR against on you own risk
and costs. Meanwhile I remain
Sincerely yours,

Abdul Rahim Khan Jadoon,


Attorneys at law,
Peshawar.

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