04/02/2016.

SUBJECT:-

LEGAL NOTICE U/S 80 CPC from Ravi Bhateja S/O Baldev Raj dated 04/02/2016
28/45 Punjabi Bagh New Delhi-26

& H-10,Kirti Nagar , Delhi-

110015.

Resident of

&

co-owner

ravibhateja<ravibhateja1978@gmail.com>

: to Bhagwan Dass Bhateja

Kindly find the copy of the main application page no. 2 to 11,which should be construed as a legal notice u/s 80 CPC


Arising out of the intentional acts of Advocate Pramod Ahuja & Associates
401 Lawyers Chambers
Delhi High Court
Bar Council No.D185/1974.
New Delhi-110003.

&
his client

Sh. Bhagwan Dass Bhateja

S/O Kesho Dass
H-10 , Kirti Nagar
New Delhi-110015.

from

copy to : Advocate Pramod Ahuja

Bhagwan Dass Bhateja or D-1 )

CS / OS : 1114/2008

Advocate Geeta Dhingra

All Parties to suit no CS / OS : 1114/2008.

Delhi Bar Association

Bar Council of India.

Ravi Bhateja
s/o Baldev Raj Bhateja

04/02/2016
Notice under section 80 CPC from Ravi Bhateja S/O Baldev Raj (relevant docs enclosed)

Be informed that I ravi bhateja s/o baldev raj r/o 28/45 punjabi bagh
west new delhi -26 , hereby by the virtue of self motion undertaken
through self consciousness and realization , serve you with this
plaint which should be construed

as a legal notice under section 80

cpc claiming damages for psychological distress

and

moral turpitude

and injury caused deliberately by you and your client .

1) That

yourself

I.e

advocate

pramod

ahuja

have

deliberately

violated the provisions of MODEL code of conduct as recommended

under Advocate act during the cross examination proceedings for
I.A:7251/2014

recording of evidence under order no ......and the same which

happened

on

.k.sisodia)
applicant

03/09/2015
at

is

Delhi
party

in

high
to

the
court

the

court

of

reference

aforesaid

JOINT
to

suit

registrar (a

CS(OS):1114/2008.

civil
&

along

suit

with

The
his

father is arranged as defendant no 12 & 11.All the parties to

the suit are related to each other by birth & blood , being born
out of common father (kesho dass ) and

mother .

2) That sh kesho dass(deceased) is the grandfather of the applicant

and father of the applicant's father .
matter of the suit

As such the subject

happens to be a dispute regarding the

partitioning, possession and rendition of the accounts of the

HUF property at H-10 , kirti nagar, Delhi which is in illegal
possession

of

thy

client

sh

bhagwan

dass

bhateja

or

the

respondent no 1 , as he has managed to fabricate a forged will

of his father(kesho dass ) in connivance with some of his like
minded brothers for grabbing the whole HUF property .
3) That your client has got a fabricated forged will out of nowhere
and used the same to get the whole of the HUF property mutated
an escape

in the name of his wife Vimal by making through false pleas of

love and affection allegedly shared between his father and his
wife .That as such a presumption is unsustainable being contrary

Page 1 of 10

to the actual reality as they used to fight among themselves and

were not in the good terms. That's why thy client had filed a
suit u/s 10 HMA forjudicial separation againsthis wife/beneficiary

4) That

testimony

03/09/2015

in

was

the

given

court

by

of

the

applicant's

joint registrar

father

on

sh.A k sisodia

regarding the authenticity of the decree awarded in 1974 by the

court

of

sub judge

sh

ravi

kumar

securing H-10

as

an

HUF

property . That on 03/09/2015 the attesting witness who is also

the

father of

the applicant

, was

cross

examined by

many

learned counsels of the parties to the suit including you

5) That it is pertinent to mention here that during the course of
cross

examination

you

had

shown

the

attesting

witness

the

original copy of that very fabricated will which was allegedly

made by his father sh kesho dass & upon the basis of

which your

client has clandestinely managed to get the mutation done in his

wife's name only .

6) That during the cross examination proceedings on 03/09/2015

,the attesting witness, upon being asked by you regarding his
comments about the will , whether the signatures of sh kesho
dass on the will are authentic/genuine ,the respondent no 11
replied in negative.Further that the witness insisted especially
on this point and has repeatedly made the same answer to
all

such

queries

regarding

the

authenticity of

thesignatures

of his father or sh kesho dass on the will which is at

on

the

record.

As

such

all

the

your

individuals

present

who happened

to be present in the courtroom at that time including joint

registrar sh.A.k sisodia along with the many learned counsels
are a witness to such deposition by applicant's father and in
noway such can be
the

will

are

disputed.

That

the

signatures

present

on

not that of his father or that he identified

and proved that the signatures present on the will are forged .
Page 2 of 10

7) That after this you suggested him that his

father (kesho dass )

the owner of the property personally accompanied his brother or

your client that is sh bhagwan dass

&

his wife

registrar office the day when the will allegedly

. To such a suggestion the witness

vimal to the
got registered

again replied in negative as

his father had expired around 5 months prior to the date on

which

registration

was

done

dead

person

accompanying

beneficiary to the sub-registrar's office is hilarious & out of

this world.

8) That ever since the suit matter got invoked in 2007 , which
still awaits final adjudication ,

your client(bhagwan dass) has

changed a number of ld counsels for representing him in the suit

as such no learned counsel was capable of helping him win a lost
battle or the present suit . That the names of them are not
produced herewith for the sake of brevity . But it is quiet
evident that during the courseof proceedings till date ,the
situation has become very clear in everyone's mind including
your client that he shall be burned with criminal liability
instead of winning an award in the legal battle .The notion of
his defeat got affirmed by the order of sh v.k.jain dated in
which the honorable court was pleased to place an injuction over
the subject suit property and restrained your client bhagwan
dass

from

raising

understandably

any

your

third

client

party
is

interest

infuriated

.
by

Hence

quiet

the

said

deceleration .

9) That

it

realized

is

pertinent

that

to

whatever

mention

the

frauds

that
that

your
he

client
has

now

managed

has
to

perpetrate throughout his entire life time, are now showing

signs of exhaustion and

they are no longer aiding him in

achieving his ulterior motives. Your client foresees his decline

Page 3 of 10

where he stands to loose the economic edge that he has managed

to gain and retain by advocating and practicing divide and rule
policy within the precincts of his joint family. Also it is
pertinent

to

mention

that

your

client

harnesses

sense

of

acrimony and hatred towards his younger brother ( applicant's

father or defendant no 11) right from the day when he got
married to a working girl from a family of higher stature than
that of his own & hence he was unable to digest his progress
.That's why he specifically mentioned about the same in
correspondences

with

his

other

brothers

which

his

is on court

record in suit regarding HUF house at punjabi bagh and as such

the same document is on the court record

10)

That the

already.

cause of action arouse on 03/09/2015, when during

the cross examination , you specifically made the allegations of

incompetence
or disentitlement
and
took
upon
deliberate
obfuscation and/or used prohibited ambush defenses by mentioning
many

narcissist

appears
and

the

to be
same

proceedings

comments

and

suggestions

that

prime

facei

fabricated by you at the instance of your client

was

.In

irrelevant

other

words

to

the

during

existing

adjudication

proceedings

when

you

happened to cross examine mr baldev raj you violated the very

soul of the judiciary upon which the temple of justice stands .
Allow

me

to

quote

those

disgusting

objectionable

imputations/remarks , distasteful comments/ suggestions which

were made by you in front of the entire court including the
applicant, his mother who is also the wife of the attesting
witness along with

astt registrar sh a k sisodia who was

presiding over the proceedings at that instance .

11)

That the verbal sentences made by you at that point of

time are

reproduced herein and are as follows:-

Counsel /advocate/yourself :" AAPKO KYA LAGTA KI HARISH KO PROPERTY KA SHARE MILNA
Page 4 of 10

CHAHIYE, JAB TAK KI USKA BAAP ZINDA HAI " Reply of the
witness :-Blank or no reply.
That the witness remained silent and he avoided giving any
reply in relation to the first inquiry or the imputation made
by you.
12). Then you repeated the same sentence but with a little rearranged
words

but

bearing

the

same

imputation

for

the

purpose

of

prodding the witness to answer to you or for the purpose of

provoking

him and making him angry .Therefore you repeated the

same gesture again and again and asked the same sentence in a
little

different

way

by

rearranging

the

words

along

with

intimidating facial expressions. Thereafter

You :" AAP YEH BATAYEIN KI KYA HARISH KO KUCH PROPERTY KA SHARE
MILEGA kya JAB TAK KI USKA BAAP ZINDA HAY "?
13. As such both the lines convey more or less the same meaning
therefore as those sentences along with gestures one after the
another

continuously

justification,can

be

being

repeated

adjudged

as

by

you

deliberate

without
attempt

a
to

distraught the witness so as to drop him in a feeling of sheer

helplessness .No wonder we all witnessed that very proceedings
including yourself and your client in which the witness looked
as if he has been insulted and pained but since as he was bound
by his oath , he nodded in affirmative .This reaction from him
is already present in

the record of the court and is Exibit

No..as a certified copy of the deposition by respondent no 11.

14).Thereafter you dropped the last atom bomb on nagasaki by

Page 5 of 10

looking in the eyes of the witness and saying the following

lines: HARISH KO ZAIYDAD KA HISSA TAB TAK NAHI MILEGA JAB TAK KI

USKA BAAP ZINDA HAI AUR USKE BAAP KE MARNE KE BAAD HI

HARISH KO USKA HISSA MILEGA "
15) Respected sir we all are aware of the fact that all the
materialistic

possessions

of

this

world

illusion or a mirage . Every mortal being

are

sort

of

an

comes and goes all

alone from this world . That's why in HINDUS, for centuries some
lines are spoken in particular" RAM NAM SAT HAI during the
funeral procession when the mortal remains of a departed soul
are bound for pyre" .No offense that I am sure that the same
tradition shall be complied with by your own son in future if he
believes

in

Hinduism

faith

.But

doesn't

matter,

even

if

he

practices faith of any other religion,then also you are bound to

be disposed off in a similar manner . Also we are aware of the
fact that from which place of the body a lady

gives birth to

her child and by this process of reproduction ,you and we all

have come to an existence on this planet which is known as the
earth. Even the dead soil is regarded by intelligentsia either
as motherland

or as fatherland .And you no doubt are one of

them.

16).But the very big question is how come it be justified that

Page 6 of 10

we the so called learned officers of the honorable court of law

under an express oath blazingly at the top of our voice make
imputations like the ones involving blood relations or involving
that for which I have just given an example . How can we justify
the same in the color of executing the

proceedings of the court

or under the pretenses of fulfilling our duty and discharging

our functions .That the cross-examination which got conducted by
you of his father was no doubt at some instance offensive and
without clear purpose or

significance and same sentences were

repeated many times without any logical justification by you

.Hence ,such remarks during the cross examination were prolix,
extensive , offending and uncalled for and as such they violate
the model code of conduct for the advocates u/s 35 Of advocate's
act.
17.

That

as

such

those

tactics

have

been

advanced(it

is

speculation) to try and get the witness discharged by invoking a

sense of hopeless inside the the individual who unfortunately
happened to be pitted against the members of his own clan and
that includes those

who are elderly and deserve unconditional

respect. Mahabharta is a classic example of such a scenario when

Lord Krishna enlightened the helpless Arjuna. That you used your
closing speech to imply bias on the part of the living members
of the applicant and his family and the same can be said to have
invoked a sense of deliberate insult and ridicule .
18.The

applicant

hoped

that

you

as

gentleman

upon

being

informed , may admit mistakes which in reality was more than

just that and further extend tender an apology . Therefore the
applicant made an E- mail to you on

date 17/12/2015. But as

such

and

nothing

bombardment

of
of

that

sort

happened

vexatious

notices

and

instead

you

started

suits Page No.14

Therefore again the applicant made an E- mail to you on date

Page 7 of 10

on 29/12/2015. Thereafter he wished you a very happy new year

on

date

01/01/2016 PAGE NO.

That

you

chose

not

to reply

appropriately or directly within the four walls of the Delhi

high

court

dialog as

which

per

the

you

are

aware

universal

of

accepted

the

need

norms

of

of

mutual

nobility

and

civility.But instead on the date when next hearing of the case

was

scheduled

to

be

held

you

approached

the

chamber

of

advocate Geeta Dhingra (at Delhi High Court) , who is also the
learned counsel to the applicant and his father .There in her
chamber you verbally dropped names at a loud pitch of your voice
,inquired

about

consequences

the

thereby

applicant

and

threatened

an

emergency

invoking

her

with

alarm

dire

type

of

distress in her mind .Again after committing the abhorrent act

of insult against the applicant's father ,the same was committed
deliberately

by

you

as

you

know

that

she

is

also

close

relative of the applicant .Then the applicant got to know what

that transpired at his back.
19.

That it is very respectfully submitted that your such acts

are completely against the principles of natural justice and

further are fatal to it's administration . Such acts are meant
by you and your client to cause prejudice to their opponents and
unjust advantage to your own client who are arranged as parties
to the suit .It is pertinent to mention that your client gets
the same respect as that of his own father by the applicant and
they are arranged to be contesting for a common cause in a
second suit which is concerned with the partition of another HUF
property at Punjabi Bagh west, Delhi-26 .Unfortunately
an

not even

iota of good faith OR a notion of privileged communication

can be derived from the very conduct of rendering imputations by

you during judicial proceedings. Hence, your such
been

cause

of

severe

mental

agony

and

actions had

anguish

to

the

applicant who is respondent no D 11 & his father who is D12 in

suit CS(OS)1114/2008.
Page 8 of 10

thereby leading to their reduction in health ,weight and well

being .As such the liability for compensating such loss of their
health lies upon your shoulders . Hence a written unconditional
apology is the need of the hour and is being demanded at an
earliest from you , along with a monetary compensation of Rs 25
Lakhs in Indian currency, failing which the applicant shall be
at

his

liberty

to

approach

the

competent

court

of

law

for

invoking appropriate criminal or civic legal proceedings under

or law prevailing at time of adjudication

the law of torts against you or your client or both entirely at

your cost and risk without causing any prejudice to anyone.
AFTER ALL THY MUST REAP WHAT THAT YOU SOW.
20.

That the period of this notice starts from today dated

03/02/2016 or THE THIRD OF FEBURARY TWO THOUSAND AND SIXTEEN of

the english calander and shall be

for a period of 31 days &

destined to expire on 07/03/2016 as 6th OF march being a sunday.

Therefore it is requested to comply with the terms of this
notice at the earliest .If in case no response is received from
you with reference to this subject matter , it shall be regarded
as

denial

eligibility

thereby

rendering

for proceeding

the

applicant

the

required

further.
Deponent
Ravi Bhateja
28/45 , Punjabi Bagh west
New Delhi-26.
E-mail :ravibhateja1978@gmail.com

Enclosure: 1. True copy of the judgement by his lordship on

06/07/2011
2. Certified copy of the cross examination of Defendant no 11
dated 03/09/2016
3. True copy of the e-mail dated 17/12/2015
4. True copy of the E-mail dated 27/12/2015

5.

True copy of the E-MAIL dated . 01/01/2016.

Page 9 of 10

THE HIGH COURT OF DELHI AT NEW DELHI

%
+

Judgment Pronounced on: 06.07.2011

CS(OS) No. 1114/2008

SHRI HARISH KUMAR BHATEJA

..... Plaintiff
Through: Mr. Rajeev Saxena, Adv.
versus
SHRI BHAGWAN DASS & ORS.
..... Defendant
Through: Mr. S.P. Pandey, Adv. for D-1 to
10.
Ms. Gita Dhingra, Adv. for D-11 & 12.
Mr. R.K. Bedi, Adv. for D-13 & 14.
CORAM:HONBLE MR JUSTICE V.K. JAIN
1. Whether Reporters of local papers may
be allowed to see the judgment?

No.

2. To be referred to the Reporter or not?

No.

3. Whether the judgment should be reported

in Digest?

No.

V.K. JAIN, J. (ORAL)

IA 7014/2008 (u/O 39 R 1 & 2 CPC)
1.

This is a suit for partition of property No.H-10,

Kirti Nagar, New Delhi. The case of the plaintiff is that the
aforesaid property was owned by an HUF of which he is a
member, along with his father, brother, uncles and cousins.
The case of the plaintiff is that the sale consideration for the
CS(OS)No.1114/2008

Page 1 of 6

aforesaid property was paid from the funds of the HUF,

though the Title Deed was executed in the sole name of his
grandfather.

The HUF, according to the plaintiff, was

headed by his grandfather late Sh. Kesho Dass.

In the

lifetime of Sh. Kesho Dass, defendant No.11 Baldev Raj filed

a civil suit being 607/1973 seeking a declaration that the
aforesaid property which had been acquired in the name of
late Sh. Kesho Dass was an HUF property. Vide judgment
and decree dated 18th November 1974 Sh. Ravi Kumar, then
Civil Judge, Delhi passed a decree for declaration declaring
the aforesaid property as HUF property. The plaintiff, who
claims to be a member of the aforesaid HUF, is seeking
1/18th share in the aforesaid property. IA 7014/2008 has
been

filed

seeking

injunction

against

sale,

transfer,

assignment and parting with possession of the suit property

during pendency of the suit.
2.
10.

The suit has been contested by defendants No.1 to

Their plea is that the aforesaid property was the self

acquired property of late Sh. Kesho Dass, who had

bequeathed it to his daughter-in-law Smt. Vimal Bhateja,
wife of Sh. Bhagwan Dass and the plaintiff has no right, title
or interest in the aforesaid property. Defendants No.13 and
CS(OS)No.1114/2008

Page 2 of 6

14, on the other hand, are supporting the plaintiff and claim
that the aforesaid property was an HUF property and was
declared as such by the Court of Sh. Ravi Kumar, then Civil
Judge, Delhi.
3.

Defendants No.13 and 14 have placed on record a

certified copy of the judgment dated 18th November 1974

passed by Sh. Ravi Kumar, then Sub-Judge 1st Class, Delhi
declaring therein that property No.10, Block H, Kirti Nagar,
New Delhi was an HUF property and Sh. Kesho Dass, who
was defendant No.1 in the suit, had no exclusive right, title
or interest in that property to alienate it to anyone to the
exclusion of other members of the HUF. A certified copy of
the decree passed by the Court pursuant to the aforesaid
judgment has also been placed on record.
4.

The

contention

of

the

learned

counsel

for

defendants No.1 to 10 is that the documents filed by

defendants No.13 and 14 are forged documents and no such
decree was ever passed by the Court. He also states that
this suit is a counter blast to the suit already filed by his
clients, which is pending before the learned Additional
District Judge, Delhi.
5.

At this stage, there is no material on record on the

CS(OS)No.1114/2008

Page 3 of 6

basis of which it can be said that the documents filed by

defendants No.13 and 14 are forged documents.

It was

contended by the learned counsel for defendants No.1 to 10

that the copies of the judgment and decree sheet filed by the
plaintiff are different from the copies filed by defendants
No.13 and 14. I have compared the photocopies filed by the
plaintiff with the certified copies filed by defendants No.13
and 14 and I have not been able to notice any discrepancy
in the two sets of copies.

Prima facie, these documents

appear to be genuine certified copies of the judgment and

decree dated 18th November 1974, passed by Sh. Ravi
Kumar, then Sub-Judge 1st Class, Delhi.

If the suit

property is an HUF property in terms of the aforesaid

judgment and decree, obviously late Sh. Kesho Dass had no
right to bequeath whole of it to his daughter-in-law and he
could have bequeathed only his share in the aforesaid
property.
6.

Since plaintiff has made out a prima facie case,

showing the suit property to be an HUF property and he

claims to be a member of the HUF having 1/18 th share in
the property, it would only be appropriate that the suit
property is preserved during pendency of the suit and no
CS(OS)No.1114/2008

Page 4 of 6

third party interest is created therein.

It is settled

proposition of law that in a suit for partition, the property

subject matter of the suit needs to be preserved during
pendency of the suit, if a prima facie case is made out in
favour of the plaintiff. If the injunction is not granted and
consequently the contesting defendants are able to sell,
transfer or alienate the suit property either wholly and in
part or part with its possession, that may negate the decree
which may be passed in favour of the plaintiff and it may be
difficult for the plaintiff to execute such a decree in view of
creation of third party interest and delivery of possession to
a third party. The parties to the suit are, therefore, directed
to maintain status quo with respect to title and possession
of the suit property during pendency of the suit.
The application stands disposed of.
IA 7443/2009 (u/S. 151 CPC)
Dismissed as not pressed.
IA 13920/2009 (u/S. 151 CPC)
Heard.

Since certified copy of the judgment and

decree dated 18th November 1974 has already been filed by

defendants No.13 and 14, the purpose of passing the order
dated 30th May 2008 requiring the plaintiff to file the
CS(OS)No.1114/2008

Page 5 of 6

original/certified copy of the order has been fulfilled.

Mr. Pandey states that the record of the suit is not
available in District Court being old record.

The question

whether the record is available or not, has no relevance at

this stage, since the authenticity or otherwise of the certified
copies filed by defendants No.13 and 14 has to be finally
decided only after recording of evidence.
The application stands disposed of.

(V.K. JAIN)
JUDGE
JULY 06, 2011
Ag

CS(OS)No.1114/2008

Page 6 of 6

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ROOM NO. 347, TIS HAZARI COURTS. DELHI

M NO. 01/16
BALDEV RAJ

: 20.01.16
of order
of filing of PF : 25.01.16
: 29.01.16
of Issue
Date of Hearing: 04.02.16AT 2PM

Date
Date
Date
Next

VS.

KESHO DASS (DECEASED)

COURT NOTICE
To.

SH. BALDEV RAJ

S/O LT. SHRI KESHO DASS
28/45, PUNJABI BAGH, (WEST)

NEW DEI,HI
Whereas applicant has moved an application U/o 9 Rule L3 (copy enclosed). You are

required to appear
.l

in

person or through pleader

in this court on the next date of hearing

i.e.

04.02.2016 at zPM to give reply of the said application.

Given under my hand and seal of this court on 29.01.l-6.

|\rli- i UDGP$ENrR,'{I L \
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ravibhateja<ravibhateja1978@gmail.com>

Refertoyourcommunicationonthebehalfofthyclient.
1message
ravibhateja<ravibhateja1978@gmail.com>
To:pramodahuja.adv4@gmail.com

Thu,Dec17,2015at6:59PM

saadarpranamdear,
Firstofalliwouldliketoappreciateyourendeveryoureffortsyourfamily.Afterallapersonearnsmoneyforthesakeofone'sfamily,nomatterhowoneearnsit.Nowonderhumansare
superstitiousbutlawyersarerationalandpractical.Alsoalawyermaynevercommittoanyemotionastheyarenotemotionalfoolsunliketherestofus.Nowonderevenabutchererwouldblamegeneralpublic
asanexcuseforhisownabhorrentcrimescommittedwithsuchanimpunitythataprudentmanisboundtoblamehimselfthatwhydidhequestionedhimintheveryfirstplace.Theveryfirstinstancewheni
sawyouwithinthepremisesofdelhighcourtihadthoughtthatyouhaveanimpeccablequality.ihadneveranticipateditbutnowiregrettosaythatyouhavefailedmetotally.Lookingatyourconductinthe
courtwhenyouwerecrossexaminingmyfather,mynervesgotfilledwithlavawhenyousuggestedandaskedmyfatherthatharishwon'tbegettingasharetillhisfatherisaliveanditisuponhisexpiryblahblah
!!!Iwasboundbylawandtookyourgreyhairsinconsiderationotherwiseyouwouldhavegotanewclienttodefend/prosecuteforsurerightthere.Anywayiknowtheentirebloodlineofyoursandplease
realizethatyourBIGBisnolongeraPresidingofficerandyourarenolongerentitledtoimmunityorprivilages.
youarenotfaithfultoyourbloodlinethatiknowbutitwouldbebetterifyoualsogettoknowthatiamunlikeyou.Idofeelsadandpainedtoseeyousuckingthebloodofmytaulikealeech.andthatAGED
personwhothinkshimselftobemorethanintelligent,isbeingmadeachutiyabyueveninspiteofbeingfullyawarethathestandsnochanceinthislitigation.Howinterestingthatseemedtomewheniread
yournoticejustashortwhileagoandiamstillconfusedwhethertolaughonitorscratchmyhead.Lowerjudiciaryisbeinginvokedtogiveorderstohon'blehighcourtlozzz.Wellitnowappearstomeasifyou
alsoareabrotheroftomari.eExlawminister.
ANYWAYSTHYSHALLREAPASYOUSOW.
Askingforyourblessingsasiknowyouhaven'tgrownyourhairgreybecauseofsunlight,
taukawafadaarmunda
jaimatadi&jaihind

ravibhateja<ravibhateja1978@gmail.com>

InReferencetoyourcommunicationonthebehalfofB.D.Bhateja
1message
ravibhateja<ravibhateja1978@gmail.com>
To:"pramodahuja.adv4@gmail.com"<pramodahuja.adv4@gmail.com>

Tue,Dec29,2015at10:08AM

Dearsir,
Iwouldliketotakeanotheroppertunityoutofyourveryprecioustimetoenlightenyouonthesubjectwhichisatpresentrepresentthecauseofactionofyourclienti.eshb.D.Bhateja.Dishonesty
onlyfruitifiesdishonesty.Andalltheeffortsofeitheryouoryourclientshallseethejudgementdaymuchaheadoftime.Wellithoughtaboutsharingatopicwithyouwhichiamsurewillinvokeyourinterestas
thesubjectmatterisrelatedtotheinterestofthyclient.Kindlyseeandshowtoyourclientalso.Asfarasthesuitisconcernedplztellmrb.d.bhatejathatialoneamsufficienttodealwiththevexatioussuits
thatyouarenowretortingto.Whetherthesuitisbadinlaw,barredbytheprinciplesofresjudicia&estoppelorifitisafraudonthecourtu/s340crpc.Wellrespectedsiriwouldlikeyoutotellhimthatinthis
casealsothebarcontainedu/s195crpcisnotattractedastheforgerywascommittedmuchearliersoyouarealsogoingtogetacasewhereyouclientwillbeimpleadedasafraud/defendant.happyskimming
thecream......
dpa.pdf
2296K

ravibhateja<ravibhateja1978@gmail.com>

HAPPYNEWYEAR
1message
ravibhateja<ravibhateja1978@gmail.com>
To:"pramodahuja.adv4@gmail.com"<pramodahuja.adv4@gmail.com>

respectedsir,
wishingyouandyourfamilyHAPPYNEWYEAR2016.
Your'sown,
RaviBhateja

Fri,Jan1,2016at3:10PM