Saurabh M.
Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
LEGAL NOTICE THROUGH EMAIL/RPAD
To,
Vijendra Singh Morya
Archidea Solution
431, Orbit Mall, Vijay Nagar,
Indore,M.P.-452010
Email:[email protected]
Sub: A Legal Notice for NOT PROVIDING BILL
OF Around RS.92,72,909 AND ACCURATE
AND PROPER SERVICE OF RS.15,00,000
Under instruction of my client M.s BANANA SMART
PLEX, firm duly incorporated and having registered office at B-414
MARADIA PLAZA,B/h LAW COLLECE,NR. ASSOCIATE PETROL
PUMP,C.G.ROAD, AHMEDABAD-380006, through its authorized
person MR. ZENIL SHAH (herein after referred and called as 'my
client' in this NOTICE) and on being authorized by them, I, SAURABH
M.VORA - Advocate, hereby gives this Legal Notice, which is as
Follow:
1. That My client is in the business of entertainment and also
providing good services in striem of various business and he
have very good name in his field and they have started the mini
plex at TIMES SQUARE GRAND, THALTEJ, AHMEDABAD.
Page 1 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
2. You are working in service provider and providing the services of
architect as well as material and service for building the mini
plex and also provide co related services of it and you are
running the business in the name of “Archidea Solution” at 431,
Orbit Mall, Vijay Nagar, Indore,M.P.-452010.
3. You and my client was enter in to the Agreement/MOU as on
Date:04.07.2022 at Ahmedabad for architect work and other co
related work for mini plex at SHOP No.312-A,314,315 on 3 rd
FLOOR, TIMES SQUARE GREAND, SINDHUBHAVAN ROAD,
AHMEDABAD,GUAJRAT. (Hereafter call as “The Said
Agreement”). You and my client has duly executed the said
agreement and decided the scope of work and other terms and
conditions.
4. As per the said agreement you have to finished your work as
stated in the agreement up to Date:06.09.2022 and my client
will make the payment as work finished. You have stated that
you will provide all the necessary layout plans, bills as well as
warranty cards of the materials and goods purchased by you to
my client as and when you purchased and stage was finished.
My client put all the trust on you and your words.
5. After you have started work and draw the lay out at SHOP
No.312-A,314,315 on 3rd FLOOR, TIMES SQUARE GREAND,
SINDHUBHAVAN ROAD, AHMEDABAD,GUAJRAT and show to
my client, my client has stated certain changes but you have not
Page 2 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
do it and you informed to my client that it is accurate and
proper by which my client has trusted on your words. My Client
has made the payment as and when you demanded but you
have not provide any bills of material purchased by you as well
as not provide the appropriate explanation regarding it to my
client as well as not provide and hand over any warranty cards
to my client.
6. My client has make the payment in the account stated by you as
and when you demanded but whenever asked the bills and
warranty cards to you, you always told to my client that there
was very short period of time I will hand over all the bills,
warranty cards and layout plans after completion of work and
my client put blind trust on you.
7. Even After the due date of finishing the work i.e.06.09.2022 you
have not completed the all work and still it was pending hence
you demanded the some time for finishing the work to my client,
my client has consider your request and by putting the believes
and trust in your words grant one month time to you.
8. After completion of your work my client asked you the bills,
warranty cards and layout plans of the said premises but at that
time you informed to my client that you are at outside for certain
work and it will handed over you up to i.e.15.12.2022.
9. During the time my client come to know that you have used and
install the goods and materials of the company as decided in the
Page 3 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
said agreement but of the other company and you have also not
do proper certain plumbing and electricity work which may
result into very big cause of fire or may damage the property of
my client and when for that my client called to you, you are not
provide any satisfactory reply and after words ignoring the
receiving the call of my client.
10. As the work done by you is not proper and it may cause injury
to any person as well as the property of my client, My client have
to immediately required to change of it and make repair of it
which cause the cost of Rs.15,00,000/- Rupees Fifteen lacs to
my client.
After that, My client send you various messages, mails
and call for providing the bills, warranty cards and layout plans
for making payment of GST but you are not provide appropriate
reply to my client as well as when the authorized person of my
client has came to your office as on Date.01.03.2023 for this
regard you have not provide any appropriate answer to them on
call and also not meet him.
11. Then after, As on Date16.08.2023 when you came to the
Ahmedabad for certain work you have visited the my client office
and demanded the remaining money with my client. At that time
my client has show you his books of account and the additional
work done by him due to the negligence and unavoidable work
done by you. At that time you told to my client that you will
provide all the bills and also hand over the necessary layout
Page 4 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
plans within a week and also my client and you have mutually
agreed on it and my client has ready to waive certain additional
expenditure occurred by him due to negligence and deficit
services of your only if you provide your BILLS AND LAY OUT
PLAN and WARRANTY CARD with in a week.
12. After passing of the considerable time you are not provide the
bills of Rs. 92,72,909 /- due to which my client was unable to
pay the GST in the Government as well as you have also not
handed over the layout plans and warranty card which is
belonging to my client and intentionally not provide to my client
as well as due to negligence and deficit in your service cause
additional expenditure of Rs.15,00,000/- Rupees Fifteen lacs to
my client.
13. By looking to the above facts it is crystal clear that you have
intentionally not supplied the Bills, Warranty Cards and Lay
out plans as per the said agreement to my client worth
Rs.92,72,909/- Rupees NINETY TOW LACS SEVENTY TWO
THOUSAND NINE HUNDRED NINE as well as due to you
unavoidable negligence and work cause additional expenditure
of Rs.15,00,000/- Rupees Fifteen Lacs Only to my client which
result into the unaccountable business loss as well as
reputation of my client and you have always made falls
representation regarding the work done and goods and materials
used in the said premises of my client and not providing the
Page 5 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
Bills, Warranty Cards, Layout Plans as well as other necessary
documents of the work done by you to my clients.
14.Under the facts and circumstances as above, I on behalf of
my client called up on you either to PROVIDE ALL THE
BILLS WORTH RS. Rs.92,72,909/- Rupees NINETY TOW
LACS SEVENTY TWO THOUSAND NINE HUNDRED NINE,
ALSO PROVIDE WARRANTY CARDS OF GOOS AND
SERVICES USED BY YOU FOR MY CLIENT IN THE SAID
PREMISES, LAY OUT PLANS AND OTHER DOCUMENTS
REARGING IT TO MY CLIENT ALONG WITH MAKE
PAYMENT OF Rs.15,00,000/- (Rupees FIFTEEN LACS
ONLY) TOWARDS THE ADDITIONAL EXPENDITURE
REQUIRED TO MAD BY MY CLIENT DUE TO NEGLIGIENCE
AND DEFICITE SERVICE PROVIDED BY YOU TO MY
CLIENT WITHIN 30 DAYS FROM THE DATE OF RECEIPT
OF THIS NOTICE, FAILING WHICH MY CLIENT SHALL BE
CONSTRAINED TO INITIATE CRIMINAL AND OR CIVIL
LEGAL ACTIONS AGAINST YOU AS WELL AS FILED A
COMPLAINT U/W 420, 405, 120(B), AT YOUR RISK,
COST AND CONSEQUENCES, WHICH PLEASE NOTE.
15.As this Notice is required to be given to you in the account of
returned of said cheque as above, YOU ARE LIABLE TO PAY TO
MY CLIENT, OF Rs.15,000/-TOWERDS THIS NOTICE CHARGES
which please note
Date:
Page 6 of 7
Saurabh M.Vora
M.C.VORA & M/92/1100,Parasnagar-1,
ASSOCIATES Nr. AEC Over Bridge,Mr. Saurabh M. Vora
132 Feet Ring Road, Naranpura.
ADVOCATES
Advocate(Gujarat High court)
(LEGAL ADVISER & Ahmedabad-380063
CONSULTANT PRACTICE)
M : 9510692003
Email:[email protected]
Date:
Place:Ahmedabad _________________
Saurabh M.Vora
Advocate
AS PER INSTRUCTION OF MY
________________________________
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