BY SPEED POST
/ COURIER / EMAIL
Date: 12th
day of August’ 2026
To
The Authorised Officer,
Punjab National Bank
ARMB, Murshidabad
Circle
Office Murshidabad
3rd Floor, BSNL Telephone Exchange Building,
Cantonment Road, P.O. & P.S. Berhampore,
District Murshidabad, West Bengal – 742101.
Email:
chmurshidabad@pnb.bank.in
Re: O.A. No. 15 of 2024
Punjab National Bank
Versus
M/s. H. M. Enterprise & Ors.
Before the Learned Debts Recovery Tribunal, Siliguri
Subject: Service of a copy of the Written Notes of
Arguments filed/submitted on behalf of the Defendants in O.A. No. 15 of 2024.
Sir/Madam,
Under
instructions from and on behalf of my clients, the Defendants in the
above-mentioned O.A. No. 15 of 2024,
I hereby forward and serve upon you a copy of the Written Notes of Arguments on behalf of the Defendants, prepared
for being relied upon and submitted before the Learned Debts Recovery Tribunal,
Siliguri in the aforesaid proceeding.
The
said Written Notes of Arguments contain the submissions of my clients on the
basis of the pleadings, documents and materials already forming part of the
record of the said O.A., including the Original
Application filed by the Bank, the Written Statements filed on behalf of the
Defendants and the Rejoinder filed by the Applicant Bank, together with
the issues arising therefrom.
The
Written Notes specifically deal with, inter alia, the maintainability and sustainability of the claim of the Applicant Bank,
the disputed account-wise liability, the alleged outstanding amount, the
earlier SARFAESI proceedings, the effect of the Judgment and Order dated
29.07.2024 passed by the Learned DRT, Siliguri in S.A. Nos. 26 of 2022 and 27
of 2022, the earlier Demand Notice under Section 13(2) of the SARFAESI Act, the
subsequent position taken by the Bank regarding the said notice, and the other
factual and legal issues arising from the pleadings and documents on record.
A
copy of the said Written Notes of Arguments is accordingly being served upon
the Applicant Bank/its Authorised Representative for information, record and necessary action, and the same may
kindly be treated as duly served.
It
is made clear that the service of the present communication and the
accompanying Written Notes of Arguments is without prejudice to all rights, contentions, objections and submissions
of my clients in the aforesaid O.A. and in any other proceeding
connected therewith. Nothing contained in this communication shall be construed
as an admission of any liability, claim, amount or contention of the Applicant
Bank.
You
are requested to kindly acknowledge receipt of the present communication along
with the enclosed copy of the Written Notes of Arguments.
Thanking you,
Yours’ faithfully,
Ashok Kumar Singh
Advocate
High Court Calcutta
Encl.:
- Copy
of Written Notes of Arguments on behalf of the Defendants in O.A. No. 15
of 2024.
Copy to:
The
Learned Advocate/Authorised Representative appearing for the Applicant Bank,
for information and necessary record.
Sri
Prabir Kumar Sikdar
Advocate
“MATRIBHUMI”
20,
Panchanan Sarani,
Ashrampara,
Siliguri,
P.O.
& P.S. Siliguri,
District
Darjeeling
Pin
– 734001
Mobile
: 9832506418
No comments:
Post a Comment