MAAN SINGH KAKRAN
ADVOCATE
PUNJAB & HARYANA HIGH COURT CHANDIG
Office Cum-Resi. 5407/4, Cross Road no. 3, Punjabi Mohalla, Ambala Cantt
___________________________________________________________________
Regd.A.D. /Speed Post. / Courier. / or
through Email ID or Whatsapp messenger.
Dt: 11.07.2022
To:
1. Sonia W/o Sunny Gachan d/o Fakir Chand R/O
H.NO 102 Near DRM Office Sunder Nagar
Ambala Cantt Haryana
2. Fakir Chand
3. Guddi w/o Fakir Chand
4. Ajay S/o Fakir Chand
5. Varsha w/o Ajay
All other Resident of House No-1843 Sadar
Bazar Darabi Line, Karnal Haryana.
Subject-
Under the instructions and authorization of my
client Sh. Sunny Gachan, aged about 35 years,
S/O Late Lal Chand, R/O HNO 102 Near DRM Office
Sunder Nagar Ambala Cantt Haryana I hereby serve
upon you with the following legal notice:-
1) That you the above said addressee no. 1 is
the wife of my client, addressee no. 2 is
the Father of addressee no. 1, addressee no.
3 is the mother of addressee no. 1,
addressee no. 4 is the brother of addressee
no. 1 and addressee no. 5 is the Bhabhi(wife
of brother) of addressee no. 1 .
2) That my client and the you above said
addressee no. 1 solemnized their marriage on
18/11/2018 according to Hindu Rites at
Ashoka Hotel in Karnal and Twins daughter
namely Divyanka and Divyanshi(DOB-20-01-
2021) is born out from the said wedlock.
3) That it is also pertinent to mention here
that the above said marriage was solemnized
between the parties as an arrange marriage
and you the addressee no 1 posted an
advertisement of marriage in newspaper and
thereafter my client contact you through
telephonically and your parents then after
due verified the status of my client offered
to perform the marriage with my client and
thereafter the marriage was performed at
karnal and all the religious ceremonies were
done as per rituals and that as my client
are very simple and down to earth, a simple
and minimalistic wedding was arranged.
4) That after the marriage my client gave all
comforts and even luxurious facilities to
the addressee no. 1 beyond his financial
capacity and my client even took the you the
addressee no 1 to Kerala, Portblair, Sikkim,
Darjeeling, Bangalore, Mumbai, Jaipur,
Kolkata, Shimla, Kasuali, Dalhousie, Mysore,
Goa, Mcleodganj, Amritsar, manikaran,
vaishno Devi, Shirdi, Chikmanglor and many
other places also as per demand/ desire and
my client had made every sincere effort but
it also went all in vain.
5) It is also pertinent to mention that my
client was very much interested and
enthusiastic and had planned a new born baby
but you the addressee no. 1 had always
denied the same and not ready to plan a baby
for next 5 years atleast and you gave
reasons like, giving birth to a baby will
upset and hamper with your body-figure and
you can’t afford to look bad just for a
child and that for the period of your
pregnancy, you the addressee no.1 will not
be able to enjoy any kind of intoxication
like alcohol and that even giving birth to a
baby will cost your growth in your career
and that you the said addressee no. 1 had
always kept her growth as an excuse,
whenever my client used to ask you for
having a baby and that you will think of
having a baby only after minimum time of 5
years and that my client had requested you
that he is already 34 and in 5 years he will
turn around 39 years and that this will be
very late for the better future of the baby
and that it is pertinent to mention that
later this came into the knowledge of my
client that you the addressee no. 1 was even
consuming birth control drug or medicine in
order to escape pregnancy but after the
interference of some relatives she is ready
for new born baby and above said 2 twin
daughters born out from their wedlock.
6) That after some days of marriage you the
addressee no. 1 clearly told that she is a
very open minded and used to wear short
clothes like miniskirts, shorts, crop top,
and other exposing clothes in the
matrimonial house which was not suitable as
per the status of my client and even you
wear the same before my relatives,
neighbours and friends and you didn’t make
any food or had never done any domestic work
and my client had adjusted with a hope that
good sense will prevail in you and you will
start to understand and adjust at least in-
front of my parents or friends or relatives
but you didn’t listen any of my clients good
suggestions and that you the addressee no. 1
used to reply that you are not such type of
girl and you will not adjust in such type of
atmosphere and you also threaten that you
will not change yourself and it is the duty
of the husband and his family to change
themselves to adjust in the matrimonial
life.
7) That many times you addressee no 1 had ran
from the home without any intimation to my
client and he got surprised when he came to
know about your absence from the home as you
left your two minor daughters home alone
just to torture my client and my client and
other persons caught you many times and
brought you back to the home.
8) That you insisted to upon my client to live
separately from the parents of my client and
my client refuse to do same you got annoyed
on this core and made a scene on each and
every petty matter and also threaten my
client to commit suicide and falsely
implicate in a case without any reason an
cause and life of my client got hell by you
and my client tried to understand to you the
addressee no 1 but you had no listen
anything and my client told this fact to a
addressee no 2 to 5 in this regard but my
client was very surprised when you the
addressee no 1 had spotted the version of
addressee no 1 and told to my client it is a
good step to live separately from the
parents and such type of steps was taken by
you addressee no 1 soon before marriage and
also told to my client that in their custom
every couple is living separately and after
completing the all the social obligation
mother father are living separately and they
have no consent with the boy and my client
requested before you as his father namely
Lal chand was already expire on 5-4-2011 and
there is no other person to look after his
old mother sukhesh and his brother in law
(Jija) also expired and his real sister who
is a widow is resided with the mother of my
client along with a minor child and there is
no person to look after them and he cannot
take the step to live separately in that
situation and his duty is to maintain or
care his widow mother and sister but in such
type of situation you all the above said
addressee melt there heart and at last my
client was agreed to live separately from
those persons and he started his matrimonial
life at Sunder Nagar ambala cantt with you
the addressee no 1 in a rented accommodation
but in spite of that devotion you the
addressee no 1 change your cruel act and
conduct towards my client and you the
addressee no 2 to 5 regularly interfere into
the life of my client through telephonically
and as well as one or two person from the
you the above said addressee was resided at
that rented accommodation and used to live
minimum 15-20 days and you the above said
addressees had not spent the valuable time
with my client and ignored him and due to
your interference the physical relation
could not done as there is one rented room
which is in very small size and such type of
your act and conduct gave physical and
mental torcher to my client.
9) That on your act and conduct at last my
client made a complaint to the PS Parao in a
nakshal manner in which you all the
addressees’ apologize for their act and
conduct and on believing your assurance the
matter was compromised in police station.
10) That after some day you the addressees
made a revenge on made a complaint against
them to the police and you all of them
comments upon my client without any reason
and cause not to allowed see and care of his
daughters and later on my client came to
know that you all the addresses of them
hatched a criminal conspiracy with each
other and after due consultation of your
relative who is a advocate and practicing in
court threaten my client without any reason
an cause.
11) That it is also pertinent to mention that
my client and his family members are very
religious and very social people and the
usually worshiped in the temple by reading
holy books and chanting mantras and that you
the addressee no. 1 was advised to please
be obey all the religious rituals and
sacrifices but you the addressee no. 1
clearly stated that you don’t believe in
Hinduism or Murti-Puja and you the addressee
no. 1 never entered the premises of the
temple and that you instead used to demand
my client and his family to leave Hinduism
religion and instead get converted or
baptised into Christianity and start to pray
and preach the greatness of Jesus. You the
addressee no. 1 always used to go to
churches and used to force my client to come
and pray along with you. That you the
addressee no. 1 in-front of his family on
many occasions used ill words towards Hindu
God and used to question and insult the
Hindu religious beliefs and always
deliberately used to hurt my client and his
families religious sentiments. That on one
occasion you even picked up the stone figure
of the Hindu deity established at the home
temple in-front of the parents of my client
and forcing that you will further establish
the Symbol or figure of Jesus in the temple
and that forced my client to convert into
Christianity and further to preach or pray
only to Jesus in the home premises and that
it is pertinent to mention that you the said
addressee used to openly drink wine in the
house in front of my clients relatives and
neighbours and when my client and his
parents objected the same, you the said
addressee used to shout and create a scene
and that you even stated in front of my
client’s parents that “Christianity ka toh
yeh parshad hai, tum sab logo ko bhi peeni
chahiye, aap logo ke Charna-mat se toh
bahoot aacha hota hai”.
12) That my client and his family is very
religious and the parents of my client did
not used to entertain any non veg or egg
articles in the house premises and that you
the addressee no. 1 often used to cook
chicken or eggs in the matrimonial kitchen
and that you never respected my clients way
of living and you the said addressee used to
do such things to hurt my clients religious
sentiments and that you the said addressee
often used to force my client to consume non
veg or egg along with her and that caused
great mental pain to my client.
13) You the above said addressee no. 1-5
hatched a criminal conspiracy with intention
to grab the money out of my client and you
all the above said addressee made pressure
upon my client to exploit unfair money out
of his pocket and it came in the knowledge
of my client that you all the said addressee
had hatched a conspiracy and the addressee
no. 1 had filed a false and frivolous
complaint against my client to PS Parao and
his parents and has alleged false
allegations and has disturbed the peace of
mind of my client and has made my client
life a living hell and had totally disrupted
his mental peace of mind.
14) That my client or his family member were
called the police and thereafter they reach
there and narrated all the fact before them
and they advise to the you the addressee no
1 to join the life with my client but at the
time you had consult and discuss with your
advocate who is relative as motioned above
and thereafter you had told there that you
are not ready to join the matrimonial life
at that time with my client and she would
come back after 28-11-2021 from you parental
home if my client would take her back from
there and at the time you had taken all the
costly and valuable gold and silver
ornaments of my client and my client believe
your assurance and gave 10000 rupees at that
time and a writing proceeding was conducted
in PS Parao in this regard and you the above
said addressee no 1 living separately since
from 18-11-2021.
15) That thereafter my client made many
telephonically call to you the addressee no 1
and you intentionally no picking up a single
call and later on you blocked my client and
these facts was also told by my client to you
all the addresses no 2 to 5 but you all
ignored him and not listen anything of my
client and thereafter my client visited at
karnal but you all the addresses were not
allowed to enter my client in your house even
you all the addresses threaten my client by
saying that csVk vackyk Fkkus esa tku cw> dj
fy[kok;k Fkk fd 28 rkjh[k rd ;fn ugh ysus vk;k
rks rsjs f[kykQ djuky esa eqdnek ntZ djok,axs
tcfd lPpkbZ esa yMdh dks rks Hkstuk ugh rsjs
dks rsjs ifjokj dks tsy dh pDdh pyok,axs vksj
rsjs ?kj ds crZu rd fcdok nsaxsA
16) That thereafter my client requested to
addressee no 2 to 5 to send addressee no 1
with him along with his 2 minor daughters but
you all the addressee refuse and threaten him
if he would demand the custody of minor
daughters they will see him and the addressee
no 1 said he cannot come with him and he
wants only divorce from my client and the
said marriage was not as per her status she
is much educated other then my client.
17) That then my client requested to return
the article of my client which were taken by
you on 18-11-2021 and my client was also
offered you take your gifts which is lying in
the custody of my client but had not listen
anything and my client had returned back with
empty hands and not picked up his phone
intentionally.
18) That thereafter receiving the notice of
my client the all above said addressee.
19) That you made a false complaint to PS
Parao on 18/11/2021 with intention to
humiliate or just to make a pressure on my
client with false and concocted facts with
the legal help against my client or his
family members in which my client or his
family members were called by the police and
my client was ready to settle the matter but
your intention was not good at that time and
you made a statement to PS Parao and you made
a request to forward the said complaint to
Karnal with intention to harass or threaten
my client and thereafter you gave the reply
to your counsel dated 28.11.2021 on wrong
and concocted facts and it is pertinent to
mention here that the said reply was given by
you by engaging counsel at Ambala but you
had not settle anything by Ambala police and
my client was called by women cell on
02.12.2021 in which you and all the above
said addressee insulted or defamed or
humiliated by client in public in large and
my client tolerated everything as his
intention was very clear as he don’t want to
spoil his matrimonial life or the both twins
girls and he had a very love and affection
for all of them and my client narrated
everything before the police that he is
already dishonour by his widow mother and as
per the instigation by the all above said
addressee , my client started his life with
you the above said addressee in separate
accommodation in spite of that you have not
stopped your act and cruelties towards my
client and his mother namely Sukesh Devi who
is aged about 70 years who is a widow lady,
she is suffering from many ailments and could
not walk alone without the help of any person
and has no source of income and also
dependant on my client fully and the
applicant also told that he is not in
position to bear such kind of extra expenses
to live in separate accommodation and to
maintain her old mother and in this regard it
was decided and you the above said addressee
no 1 told that you will live along with
mother in law and with both minor daughters
and you also assured that you will not repeat
your acts and conduct with your mother in law
and with my client which is mentioned with my
client and my client had taken you from women
cell Karnal on 02.12.2021.
20) That my client started a new life with
you addressee no. 1 with hope for a better
fruitful life but all in vain you acted with
same cruelties, tortures towards my client
and towards your mother in law, my client
many times understands you but all in vain
you clearly told my client that you will not
live with your mother in law at any scope and
my client requested to stick with your
assurance which was given by you at Karnal
and on this core you made a scene
unnecessarily in daily routine and gave
threatening to commit suicide along with
minor daughter by falling jump in river or by
hanging and implicated my client or his all
family members in same false case. Amy client
is apprehention that you will commit wrong
act and if you will do , my client and his
family member is not responsible for that as
you are very short tempered lady .
21) That my client narrated all the above
said facts to the above said addressee no 2
to 5 but all in vain as all of you the
addressee no 2 to 5 supported the version of
addressee 1 and clearly told that if my
client will not live separately without his
old widow mother and such type of acts will
continue in such a manner or clearly told
that “tere ko aur tere gharvalo ko chaki
pisvayenge karnal jail mein.”
22) That you also shown the photograph along
with Bhupendar Singh Hudda EX CM and also
shown photograph of Ex MLA Reenu Balla Gupta
and told that addressee no 2 as” muh bola
bhai” of those person and you have a high
link with such officials and those person
have a regular visited terms in Karnal and
also blackmailing and tortouring my client
unnecessarily and my client is not in
position to bear everything as he is also a
human being.
It is therefore advised to you by way of
this legal notice to change your nature and
start living with my client and with minor
daughters and stop blackmailing or
threatening my client to commit suicide and
if you do so, my client and his family
members will not be responsible for that and
if you are not in position to change your
nature my client is ready to take a legal
action against you and against all above
said addressee.
A copy of this legal notice is being retained at
my office for further necessary action, if
required.
Signature of my Client
Sunny Gachan
THROUGH COUNSEL
Maan Singh Kakran(Adv)
