By Regd Post with Ack-due

Kadapa,
21-05-2018.
From:-
Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District
To:-
Sri.A.Suneel Kumar M.A., L.L.B
Advocate
Door No: 47-351,
Ravindra Nagar,
Kadapa city,
Pin code: 516003.
Sir,
Sub:- Reply notice for your legal notice dated 16-05-2018 issued on
behalf of your client Smt. V.Sailaja W/o Rami Reddy – Rg.
Under the instructions and on behalf of my client Sri. Pappireddy
Pavan Kumar Reddy son of Pappireddy Reddenna residing at flat No:404
in Sreenivasam Apartment, Chemmiyapet, Kadapa city, I herely issue this
reply notice to you with the following facts.
1. Your client executed an agreement of sale on 17-07-2015 in
favour of my client by agreeing to sell the schedule property to my client
for Rs. 6,00,000/- and that your client received an advance amount of Rs.
5,90,000/- from my client and that your client should execute regular
sale deed in favour of my client on or before 31-01-2016 after receiving
the balance sale price of Rs. 10,000/- by settling all the disputes if any,
clearing Bank loans, mortgages, surveying, giving E.C and bank clearance
certificate to my client on or before 31-01-2016. My client has been
ready and willing to perform his part of agreement from the very
beginning up to now. Whereas your client is not ready and willing to
perform her part of contract up to now. My client paid the balance sale
price of Rs. 10,000/- to your client on 20-01-2016 itself.
2. Your client made an endorsement on the back of that sale
agreement on 20-01-2016 by stating that your client received the balance
sale price of Rs. 10,000/- from my client on 20-01-2016 and that your
client could not clear off that Bank loans, mortgages, surveying,
delivering E.C and clearance certificate to my client and that your client
required some time for completion of those works (acts) and that your
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client will inform to my client to execute regular sale deed either in
favour of my client or in the name of the person as required by my client
as and when my client demands your client to execute regular sale deed
to that effect and that the sale agreement is not barred by limitation as
per endorsement made by your client.
3. Your client did not give E.C, Clearance certificate etc to my
client up to now as per endorsement made by your client on 20-01-2016
on the back of the agreement of sale dated 17-07-2015. My client is
waiting since long time for the call of your client for getting that
registered sale deed from your client. But, your client is keeping quiet
without calling my client to take registered sale deed from your client.
My client paid the entire sale consideration to your client as per the
terms of agreement of sale by performing his part of contract but your
client is lagging behind from performing her part of contract up to now.
4. Hence my client issued legal notice to your client on 17-05-
2018 by calling upon your client to come to sub registrar office Rural
Kadapa on 31-05-2018 for executing regular sale deed in favour of my
client for the schedule property. So your client has to execute registered
regular sale deed in favor of my client on 31-05-2018 for the schedule
property as demanded by my client in his legal notice dated 17-05-2018.
5. You issued a legal notice dated 16-05-2018 to my client by
stating that your client received Rs. 5,90,000/- from my client and
granted time upto 31-01-2016 for payment and accordingly your client
paid that amount to my client and that my client cancelled that sale
agreement are all totally false and concocted by your client for escaping
from the responsibility of executing registered sale deed in favour of my
client on 31-05-2018. The truth is that your client executed agreement of
sale in favour of my client as stated in para No: 1 of this reply notice. Your
client did not pay Rs. 5,90,000/- to my client 31-01-2016. Your client is
falsely thinking that an agreement of sale executed by your client is a
promissory note and not an agreement of sale. The agreement of sale
executed on 17-07-2015 is not nominal agreement of sale but it is true
and correct agreement of sale executed by your client for selling the
schedule property to my client. How can your client pay Rs. 5,90,000/- to
my client when my client paid the balance sale price Rs. 10,000/- on
20-01-2016 to your client and that my client is ready and willing to take
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registered sale deed on 31-05-2018 as demanded by my client in his legal
notice dated 17-05-2018. Your client should know that agreement of sale
dated 17-07-2015 is not promissory note at all. Your client did not pay Rs.
5,90,000/- to my client as alleged in your legal notice. The agreement of
sale dated 17-07-2015 is not cancelled and that my client has to enforce
that agreement of sale by filing suit against your client in the court of law
if your client fails to execute registered sale deed in favour of my client
on 31-05-2018. Your client fully received the sale consideration of
Rs. 6,00,000/- form my client.
6. Therefore please take this reply notice and that your client
should come to sub-Registrar office Kadapa Rural, Kadapa city on 31-05-
2018 for execution of regular sale deed in favour of my client. Otherwise,
my client is forced to file civil suit against your client in the court of law
for those reliefs by holding your client liable for costs and consequences.
Schedule:-
Property situated in Chemmumiya peta village fields, within the
limits Kadapa Municipal Corporation, Kadapa Rural, Sub District, Kadapa
District.
Circar punjai D No: 573/1-B Extent 0.02 cents or 735 links.
Bondaries:-
East : Road
West : Property Ponnolu Pali Reddy
North : House bearing Door No. 1/142-3 (44/142-3) Belonging to Battana
Subbanna.
South : Site of Mudireddy Nagi Reddy
East to west on the northern side 49 ½ feet north to Southern side
53 feet.
North to South Eastern side 24 ½ feet on the western side 22 feet
with all easementary rights thereof.
Copy to the party for information and to execute registered sale deed in
favour my client on 31-05-2018:
Smt. Vadltala Sylaja
S/o Rami Reddy
Door No: 44/157-1
Chemmumiya peta,
R.V Nagar Post,
Kadapa city.

Advocate