Saturday, December 28, 2024

Reply on Legal Notice of Bank

 

 

                                                          Date : 24th day of October’ 2024

To,

Sri Onkar Ganguly,

Advocate

High Court Calcutta

Residence :

Canal Side Road,

(Opposite Bagan Bari),

Kolkata – 700084

Mobile : 9830074191

 

Chamber:

10, K.S. Roy Road (2nd Floor),

Kolkata – 700001.

Ref. : (1) Loan Account Number 0145766000027 & Others, with Canara Bank, Chowringhee Branch, 7, Kyd Street, Kolkata – 700016.

 

(2) Your Letter dated 07/10/2024;

 

Your Client : Canara Bank, Chowringhee Branch, 7, Kyd Street, Kolkata – 700016.

 

My Client : Sri Jayanta Chowdhury, Proprietor of M/s. Global Aqua, Mouza – Nawpala, under Sarat Chandra Gram Panchayat, P.S. Bagnan, District – Howrah, Pin – 711303, and also at Holding No. 61, Purba Bagnan Colony, 2nd Floor, Premises No. 44/1A, Shyamnagar Road, South Dumdum, Bangur Avenue, Jessor Road, Kolkata – 700055, District North 24 Parganas, and also at 3rd Floor, Premises No. DC-9/15, Deshbandhu Nagar, P.O. Deshbandhu Nagar, P.S. Baguihati, Kolkata – 700059, District South 24 Parganas.

 

Subject : Demand Notice asking for Payment of unpaid Loan.

Dear Sir,

 

Under instructions of my Client Sri Jayanta Chowdhury, Proprietor of M/s. Global Aqua, Mouza – Nawpala, under Sarat Chandra Gram Panchayat, P.S. Bagnan, District – Howrah, Pin – 711303, and also at Holding No. 61, Purba Bagnan Colony, 2nd Floor, Premises No. 44/1A, Shyamnagar Road, South Dumdum, Bangur Avenue, Jessor Road, Kolkata – 700055, District North 24 Parganas, and also at 3rd Floor, Premises No. DC-9/15, Deshbandhu Nagar, P.O. Deshbandhu Nagar, P.S. Baguihati, Kolkata – 700059, District South 24 Parganas, I write to you as follows;

 

1.    Pursuant to your Demand Notice dated 7th day of October’ 2024 and subsequent your Corrigendum dated 19th day of October’ 2024, I would like to remind you of your presence on 25th day of September’ 2024 before the Hon’ble Debt Recovery Tribunal Kolkata 3 in SA/627/2024, when you appeared for the Respondent Bank i.e. Canara Bank, wherein the recall for notice dated 28/03/2023, has been challenged against the Loan Account Number 0145766000027 & Others under reference.

 

2.    That it is surprising that even after your participation in the said case being SA/627/2024, before the Hon’ble Debt Recovery Tribunal Kolkata 3, you have once again agitated the same issues of unpaid Loan in respect of the aforestated Loan Account Number 0145766000027 & Others. As such your said Notice dated 7th day of October’ 2024 and subsequent your Corrigendum dated 19th day of October’ 2024, amount to a Statutory Notice under Section 13 (2) of The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (54 of 2002). But the Creditor under the Law is required to send notice which is misleading in the present incident.

 

 

 

 

3.    That by sending your said notice dated 7th day of October’ 2024 and subsequent your Corrigendum dated 19th day of October’ 2024, you have tried to reopen a fresh case against same Loan Account Number 0145766000027 & Others.

 

4.    That your such action is not trust worthy specially when you submitted before the Hon’ble Debt Recovery Tribunal Kolkata 3, on 25th day of September’ 2024, in SA/627/2024, that the earlier notice dated 28/03/2023 as annexed in the application being SA/627/2024 is not correct and the Hon’ble Tribunal has been pleased to believe the document presented by you in respect of the date of notice, which according to both the Hon’ble Tribunal and you should be 28/03/2024. But inspite of request, you have not given me a copy of your said notice dated 28/03/2024, as mentioned in the said Order dated 25th day of September’ 2024.

 

5.    That your present conduct suggests two things;

 

(i)           Either you misled the Hon’ble Debt Recovery Tribunal kolkata 3, on 25th day of September’ 2024;

 

Or

 

(ii)          You are denying your earlier proceeding under The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (54 of 2002);

 

In the circumstances, I request you to clear your stand as to whether you are denying your earlier steps under The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (54 of 2002), which in fact has been challenged by your own notice dated 7th day of October’ 2024 and subsequent your Corrigendum dated 19th day of October’ 2024, and whether you deliberately submitted or misled the Hon’ble Debt Recovery Tribunal Kolkata 3, on 25th day of September’ 2024, in SA/627/2024, by producing a Document dated 28/03/2024, allegedly had been issued under Section 13 (2) of The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (54 of 2002). Your early reply in the matter is solicited.

 

Thanking you,

 

Yours’ faithfully,

 

 

Ashok Kumar Singh,

Advocate

High Court Calcutta

 

Copy to : Canara Bank, Chowringhee Branch, 7, Kyd Street, Kolkata – 700016.

               {for your kind information}

 

 

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