Without Prejuduce

To, 01.07.2020

1. The New India Assurance Co. Ltd

Mumbai LCBO- II (990000) New Delhi Centre,Ground Floor,17

Mumbai-400039

2. Axis Bank Ltd

Axis House, C-2, Wadai International Centre

Mumbai-400025

Subject –Legal Notice

Dear Sir,

With Due Adoration,it is stipulated that our client Smt Anita Seghal W/o Mr.Om Prakash Segal
resident of G-1, G-Block New Police Line,Kings Way Camp,Delhi(herinafter referred to as
“Client”).

We served notice upon you, Noticee 1, The New India Assurance Co. Ltd,Mumbai LCBO-II
(990000) New Delhi Centre, Ground Floor, and 17 Mumbai-400039

We served notice upon you, Noticee 2, Axis Bank Ltd at Axis House, C-2, Wadai International
Centre, Mumbai-400025

That without prejudice to rights and contentions of our client an upon instruction of our client,
we hererby serve this present notice notice upon you and further instructed to state as follows:

1. That our client is a house wife and simple woman.

2. At outset our client’s husband has insured with general insurance since ……………. . Her
Husband was holder of Personal Accidental Insurance Policy since……… till and was paying
an annual premium of Rs…………….

3. It is imperative to mention that said policy carried a cover of Approx…………….... -

(Rupees …………………………).

4. It is immense sorrow to our client when her husband was dead due to accident by train and as
per investigation by police which had declared that death had caused due to damage of cranio
cerebral damage consequent upon blunt force impact alongwith multiple injuries.
5. That death of my client’s husband was occurred on D.N Railway line No.3
ShavanPark,AshokVihar,Delhi.

6. That death of deceased had identified by his son, wife, and his father in law. And there had no
eye-witnesses to identify him.

7. That deceased was sole bread earner of my client family. The whole family had dependent on
him. My client is not able to sustain with current income of her family.

8. It was shock to the family of our client when claim was rejected by noticee 1 because of
deceased run over by running train and as per Railway Act crossing of railway track is prohibited
and offence.

9. That noticees had relied on inquest report made by magistrate which is questionable and can
be challenge in trial court. So, noticees cannot not rely on inquest report till the court wil
announced the order.

10. That you also ignored the contents of police report made under section 174 of CrPC which
had specifically said that there are no grounds of “FOUL PLAY” hence in absence of this it is
clear case of accidental death but you ignored this and rejected our claim application.

11. That as deceased is serving in police from last 35 years and it is common assumption “that
everybody is aware that crossing of railway track is an offence and can be dangerous too.”

12. That deceased was focused and honest employee. As far as my client ‘husband concern he
will not to do those things which will be in violation of any rules and guidelines for public safety
laid down by railway.

13. There were many communications with the concerned managers and authorities at New India
Assurance but to no avail. And our Client’s claim was rejected due to crossing the railway track
is an offence.

14. That Noticee 1 and Noticee 2 has not given aid to my client that helps to come out with
financial problems which has faced by my client’s family.

15. That since the incident the Noticee1 and Noticee 2 has stopped attending and responding to
our Client’s messages and calls.

16. That you Noticees entered in this commitment with our client with malafide intentions with a
sole purpose to cheat and defraud our client.

17. That you Noticees have only committed cheating, fraud, Miss apporation but are also
responsible for the financial burden that has now befallen on our client. It is apparent from your
conduct that you all have come out with such policies with the only intent of cheating innocent.
18.In above circumstances we on behalf of our client are constrained to put you to notice and call
upon you to pay them 30,00,000 along with overdue interest of 15%per annum with effect from
the due dates till realization thereof within 7 days of receipt of this notice falling which it shall be
presumed and deemed that you are unable to pay your debts and we have definite instructions
from our client to initiate such civil as well as criminal proceeding& filling of F.I.R for causing
cheating U/s 420 and such other sections that may be applicable at your sole risk and
consequences and cost of all these proceedings shall be borne by you including Rupees 50,000-
as cost of this Legal Notice.