ADVOCATE RAHUL SHARMA

Email- advrahul7@[Link]
M. +91-9999325814

Date: 03.02.2025

To,

Mr. Ajay Kumar S/o Late Mohar Singh

LEGAL NOTICE FOR CRIMINAL DEFAMATION

Sir,
That I have been instructed by my client namely Mr. Sanjeev Kumar, son of Sh. Kripya Ram R/o of
House no. 137 Hasanpur Mussoorie Post Khkera dist. Baghpat uttar Pradesh-250101 to serve upon
you legal notice for defamation under Section 356 of the Bharatiya Nyaya Sanhita (BNS), in
response to your defamatory actions and baseless allegations made against him.

1. That my client, Mr. Sanjeev Kumar, is a law-abiding citizen and a respected member of society. He has
held several official positions, including:
 Former Director of District Cooperative Bank
 Former Member of Block Development Council of Khekra
 Former District President of Samajwadi Party
 Former Vice President of Uttar Pradesh Petroleum Association
Additionally, my client has successfully run several educational institutions, including Delhi Public
School, Baghpat.

2. That It has come to our attention that you have lodged a complaint with the Superintendent of
Police, Zila Baghpat, making baseless, false, and defamatory allegations against my client. These
allegations are not only atrocious but have also caused significant harm to my client’s reputation in
society. Your claims are entirely false, malicious, and without any evidence. My client has no
involvement whatsoever in the matter you have raised, as he is neither the seller nor the buyer of the
property in question, nor is he a witness to any such sale deed transaction. Your allegations are
entirely fabricated and are an attempt to tarnish my client’s hard-earned reputation.

3. That, This is not the first time you have made such baseless allegations. In the past, you have filed
similar complaints, which were thoroughly investigated by the concerned authorities, and my client
was proven innocent. Your repeated attempts to defame my client are clearly motivated by personal
vendetta and an attempt to remain relevant in local politics.

4. That my client is a respectable citizen of this country. He is enjoying a very good reputation,
command, and great respect amongst the family, friends, colleagues, and locality as well as the
community. My client is having great respect, dignity, and prestige in the area and also having a blot-
less career throughout his life.

5. That Your actions amount to criminal defamation under Section 356 of the Bharatiya Nyaya
Sanhita (BNS), which defines defamation as any act or attempt to harm the reputation of a person by
making false and malicious statements. The punishment for defamation under Section 356 of the
BNS includes imprisonment for up to two years, or a fine, or both.

6. That you have leveled serious allegations against my client. Due to the said allegations against my
client without any basis and purely engineered on malice, client suffered mental agonies, torture.
Furthermore, my client is facing continuous mental torture, harassment, and fear.

7. That due to the said averments which you made in the said report communicated to Superintendent
of Police, Zila Baghpat , which is now a public document, the reputation of my client, as well as his
family, has been damaged in such that there could not be repaired. The credibility built by my client
during the span of time is shattered due to writing the false, frivolous, fictitious, and baseless
allegations against my client.

8. That the defamatory statement/ averments which you made in the report, which is submitted
before the Superintendent of Police, Zila Baghpat, is having a tendency to injure the reputation of my
client i.e. to lower him in the estimation of others and to bring him in in obliquity contempt and
ridicule. Which my client also reserves the right to file for defamation and damages.

9. That my client is demanding special damages on account of mental torture, agony, financial loss,
and injury inflicted to his reputation, honour due to the statement/averments, which you have made
before the Superintendent of Police, Zila Baghpat, Delhi as well the detail of the same are mentioned
as under:

General Damages
That In light of the above, my client demands the following:
1. Issue a public apology for the defamatory statements made by you.
2. Publish a "mafinama" ( written apology) in a national newspaper of wide circulation in the
prescribed size, clearly stating that your allegations were baseless and false.
3. A written undertaking that you will cease and desist from making any further false allegations
or complaints against my client.
4. Payment of Rs. 1,00,00,000/- (One Crore Rupees) as compensation for the damage caused
to my client’s reputation.
5. Payment of Rs. 50,000/- (Fifty Thousand Rupees) as legal fees incurred in this matter.

That through the instant legal notice for defamation, You are hereby given 15 days from the receipt of
this notice to comply with the aforementioned demands. Failure to do so will compel my client to initiate
appropriate legal proceedings against you, including but not limited to filing a criminal complaint for
defamation under Section 356 of the Bharatiya Nyaya Sanhita (BNS) and a civil suit for damages.
Please treat this notice with the utmost seriousness it deserves.

A copy of the instant legal notice for defamation is retained in my office for further necessary action.

Thanks & Regard

RAHUL SHARMA
ADVOCATE