Humanity Law Associates

Jury Consultants

CELL # 03009729448
E-Mail: minhas.sandhu.114@gmail.com
ADDRESS: Offc # 310, St # 03, Hamdani Block, F8-Markaz, District Courts Islamabad.

Muhammad Asghar
S/O Mukhtar Ahmad
R/O House # R-1076, Block 16, F.B area, Karachi.

Dear Sir, Dated: 28-07-2020

Ref. No.: LN/ISL-001-KRH

We are writing to you on the instructions of our client(s) Mr. Irfan Munaf and Mr.
Khurram Munaf son(s) of Malik Abdul Munaf R/O House # A-846, Block-12 Gulburg,
F.B area, Karachi who has received a legal notice sent by you dated 10th July 2020.
In your notice you have inter alia averred that our client(s) has violated the rights
of possession and obligations of ownership of your client Mr.Muhammad Asghar.

We deny this contention and bring your attention to the following facts and claim.

1. That our clients are law abiding, honest, sophisticated and well reputed
citizens of the State of Pakistan.

2. That the present claim of our clients is rightly maintainable with some facts
which were misrepresented and deliberately your client has concealed its
misdeeds and wrong-done against our clients thus averments made against
our clients are wrong, frivolous and misconceived hence they are denied.
3. That the contents of Para No. 1, 2 and 3 are a matter of record and hence,
merit no reply.

Denial Facts on merit.

4. That according to the sale agreement remaining amount of the subject

matter property has to be cleared till the end of the 2015 which was
neglected and terms of the agreement were disregarded.

5. That neither your client fulfills the required terms of the agreement nor he
paid our remaining amount in these 5 years and always became a reason of
discomfort for us.

6. That in between these 5 years from 2015 to till now, your client made no
efforts to return the remaining amount of our clients of the subject matter
property without considering decrease in the value of rupee and
corresponding increase in the prices of the land would be rather unjust.

7. That it is mandatory for the party who seeks enforcement of the agreement
under Specific Relief Act 1877, to deposit the balance amount at time which
is completely disobedience at the end of your client.

8. That the claim of 2 million rupee made by our clients which is an addition in
remaining amount is rightly maintainable on the ground of decrease in the
value of rupee and corresponding increase in the prices of land hence we do
not see any infirmity much less illegal.

9. That numerous promise were made by your client to clear the remaining
amount of the subject matter property but no fruitful efforts came into
existence and instead of clearing the debts, dragging the subject matter is
causing wastage of our precious time.
10. That mere intentions of your client is not more than defaming our property
as a disputed property and spoiling our reputation which is irreparable loss
and an act criminal defamation.

Therefore, you are requested to call upon your client to withdraw the legal
notice sent against our clients, rather than accepting the legal and moral
responsibilities your client attempt to use a ‘cease and desist notice’ to
intimidate and silence our clients.

Our clients reserves the right of initiative criminal and civil proceedings
against your client.

ADVOCATES:

Waqas Sandhu. Barrister Syed M. Ali.

(Adv. High Court) (Adv. High Court)

Ikram Haider Jaffery. Minhas Sandhu.

(Adv. High Court) (Advocate)