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To,
K. ALFRED,
S/O S.K. DHARAMRAJ,
NEW NO.: 34/2, OLD NO.: 109/2,
EAST VANNIAR STREET,
K.K. NAGAR-WEST,
CHENNAI-600078
Sir,
Under instructions from and on behalf of my client Mr. RAMESH IYER,
Managing Director, Mahindra & Mahindra Financial Services Ltd., Chennai.
I do hereby serve you with the following Legal Notice:1.
Services Ltd., Chennai. My client is associated with this organization for last
many decades with substantial responsibility.
2.
That you, the Noticee, have intentionally and deliberately made false
3.
That my client was shocked to see that you referred his company as
GOONDAS COMPANY and compared him with Mr. Vijay Mallya who is a
willful defaulter and facing criminal charges in India, by making statements like
kindly keep an eye on Mr. RAMESH GANESH IYER, not to escape from
India like Mr. Vijay Mallya, did in March, 2016in the official application
served to various high government officials.
4.
That the false comments made by you intentionally and deliberately to the
public officers against my client are derogatory and defamatory. That the
disparaging remark made and written by you against my client are false,
concocted, malicious and incorrect. The disparaging remarks made by you
publicly against my client have and will lower the dignity of my client and
damage my clients reputation in the eyes of the public.
5.
That your deliberate actions of making false and malicious remarks against
my client in public clearly reveal your ulterior motive for demeaning and
slandering the image of Mr. Ramesh Iyer and his company i.e. Mahindra &
Mahindra Financial services Ltd.
6. That the letters circulated and conveyed by you, the noticee, is per se
defamatory and scandalous. Baseless conclusions have been drawn on your part.
7. You the noticee deliberately mentioned my clients company as Goonda
Company and compared him with a willful defaulter which will harm is public
reputation and will affect its functioning and popularity in customers which in
turn will result in monetary loss.
8.
Mahindra & Mahindra financial Services Ltd. and the reputation and image of
its Managing Director is vital for any company. However, you the noticee
deliberately and intentionally published the said statements knowing fully well
and having reason to believe that such imputation will harm the reputation of
Mr. Ramesh Iyer and Mahindra & Mahindra finance co. ltd.
9. That wild and concocted remarks mentioned in the aforesaid application by
you the noticee against Mr. Ramesh Iyer and his company is completely
defamatory, scandalous and false.
10.
You are hereby called upon to withdraw your defamatory and malicious