Notice Reply

THROUGH REGD.
AD POST/ COURIER
Dated: 21st may 2017
To,
Mr. XYZ
D-1 2nd Floor,
Kalindi Colony, Delhi -110065
Ref: Your Legal Notice dated 14.05.2017 issued on behalf of your client Mr.
XYZ.
Sub: REPLY TO YOUR LEGAL NOTICE DATED 14.05.2017.
Dear Sir,
We have been handed over your legal notice dated 14th of May 2017, which was
issued from your good office to our client namely SONY INDIA PVT. LTD office
at A-31, Mohan Co-operative Industrial Estate, Mathura Road, New Delhi-110044.
PRELIMINARY OBJECTIONS:
1. That the present claim at the onset is not maintainable as the Noticer did not
approach any of the answering opposite parties regarding any alleged
defect in the Sony Xperia M2 Dual bearing IMEI No. 353953065369855
(hereinafter referred to as the “subject handset”). It is submitted that the
subject handset was returned to the Noticer in normal working condition and
that the same handset is working perfectly well as the Noticer has not
approached the answering opposite parties with the same.
2. At the outset, we have instructions to state that your client has not apprised
you the correct facts and has also concealed the above stated notice dated
23.02.2013 by our client, which resulted into issuance of this frivolous
notice. It appears that your client has misrepresented the true facts
deliberately and has concealed its misdeeds and wrongs done against our
client. It is further stated that averments made against our client in the
subject notice are wrong, frivolous and misconceived, hence they are denied.
3. That the true facts pertaining to the present matter may be noted.
REPLY TO MERITS
2. That the contents of Para 1and Para 2 are a matter of record and hence, merit
no reply.
3. That the contents of to Para 3 of the notice are wrong and hence, denied. It
is denied that the subject handset was malfunctioning right from the date of
purchase. It is submitted that the Complainant had used the subject handset
to the full of its potential for more than five months before approaching the
O.P. No. 2 with a Complaint on 09.07.2015. It is submitted that due to the
inability of the Complainant in using the phone properly and not due to any
malfunction in the subject handset, the Complainant had to contact
customer care for help/assistance.
4. That the contents of Para 4 of the notice is a matter of record and merits no
reply.
5. That the contents of Para 5 are wrong and hence, denied. That I say that the
subject handset was working perfectly from the date of purchase. However,
when the notice approached the answering opposite parties after few
months, the requisite parts were not available due to fast changing
technology. The Noticer was duly informed about the same and hence he
took the handset back from the Noticee No.2.
6. That the contents of Para 6 are wrong and denied to the extent that the
answering opposite parties are customer oriented company and has always
worked towards its satisfaction. Hence informed the Noticer about the
unavailability of the spare parts and also made an offer to the same
regarding the change of the subject handset to a new handset.
7. That the contents of the para 7 are wrong and denied and the Notice to be
put to strict proof of the same.
8. That the contents of para 8 are wrong and denied and as the answering
opposite parties have always worked towards the satisfaction of its
customers and hence are not liable to pay any amount for the alleged
allegations.
In reply to unnumbered para of the notice, it is stated that our client has no
liability to pay any amount and the subject notice and claim made therein
against our client is fictitious and frivolous. It is further stated that any legal
or other action initiated against our client by your client shall entirely at
your client’s risk, cost and consequences and our client reserves every right
to initiate legal action for damages or other remedies from your client before
appropriate Forum/s, which kindly note.
Therefore, you are requested to call upon your client to withdraw the above
legal notice against our client henceforth, falling which our client will be
constrained to initiate the appropriate legal proceeding and also defend if
need arises at the cost and consequences of your client.
Copy of this reply has been retained in our office for future action and references.
ADM and associates
(Advocate)

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THROUGH REGD.

Dated: 21st may 2017

D-1 2nd Floor,

Kalindi Colony, Delhi -110065

Sub: REPLY TO YOUR LEGAL NOTICE DATED 14.05.2017.

at A-31, Mohan Co-operative Industrial Estate, Mathura Road, New Delhi-110044.

approach any of the answering opposite parties regarding any alleged

defect in the Sony Xperia M2 Dual bearing IMEI No. 353953065369855

(hereinafter referred to as the “subject handset”). It is submitted that the

approached the answering opposite parties with the same.

23.02.2013 by our client, which resulted into issuance of this frivolous

O.P. No. 2 with a Complaint on 09.07.2015. It is submitted that due to the

malfunction in the subject handset, the Complainant had to contact

customer care for help/assistance.

took the handset back from the Noticee No.2.

regarding the change of the subject handset to a new handset.

put to strict proof of the same.

opposite parties have always worked towards the satisfaction of its

appropriate Forum/s, which kindly note.

constrained to initiate the appropriate legal proceeding and also defend if

need arises at the cost and consequences of your client.

ADM and associates

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