M. S.

Ahluwalia
Advocate
J-9l48-B,(Ist Floor)
Rajouri Garden,
Flerr Beki-^l1$027
Mob.9811040827
E-mail: msah luwalia2003@yahoo.co.in
Dated : 29.7 .2013
SPEED POST
To
Shri S.P. Srivastava
Advocate,
335, Lawyers' Chambers
3'd Floor, Delhi High Court
New Delhi-110003.
SUB: Reply to your legal notice dated 1g.7.2013.
Sir,
under instruction
and on behalf of my aforesaid
client Delhi
Institute
of Technology
& Management,
Gannaur,
Distt. Sonepat,
Haryana,
through its chairman
Dr. Sanjay Nijhawan,
who have
handed over to me your aforesaid
notice, I do hereby give
short reply
to your
aforesaid notice as under :
_
At the outset my client would like to state that the aforesaid
notice is all vague and frivolous
as your
client has given you untrue
picture
which has resulted into present
notice. The notice is denied in
tctc' excepi the facis are atrmitteci
irerein. Due to the faise facm given
by your client, your goodself
has send this notice,
my crient is giving
a short reply to the same.
It is pertinent
to state that when your client was sent a notice
dated 15.4.2013, your client readily accepted
the said notice along
with one month salary and he never raised any objection
and fuither
he was given
excellent fairwell party
along with whole of faculty
M. S. Ahluwalia
Advocate
J-9l48-B'(lst Floor)
'
Raj';uri Cardcn.
i\e\r' Delfii-i l+iil-l
Md.b.9811040827
E-mail:'rnsahluwalia2003fi)vahoo'co'in
participated and he never raised ary objection. But it seems that your
client has become
greedy and after aocepting all the terminal benefits,
he has sent the present false and frivolous notice
just
to illegally
extort..money
from my client. In fact there is no norm of AICTE that
there is retirement age is 65 for the Director. In fact AICTE norrn
states that no person shall be appointed as a Director whose age is
about 65 years. It seems that your client is trying to distort the said
norn
just
to take unfair advantage.
1. Contents of para 1 of your notice to the extent matter of record
are not denied and rest of the contents are wrong and denied.
Contents of para 2 of your notice are wrong and denied'
Contents
pf para 3 of your notice are wrong and denied.
Contents of pala 4 of your notice are wrong and denied. It is
denied that your client was shocked that he was relieving from
duties without completing his age of superannuation.
It is
denied that services of your client has been'illegally terminated
by
-y
client under the guise of retirement.
'It
is denied that
your client has been given a force retirement. It is denied that
no laws have been followed. It is pertinent to state that when
yiliir ciien'i; was sfr & nci'iice tieLcfi |5.4.2Ai3, your ciiei'rt
feadily
accepted the said notice along with one month salary
and he never raised any objection and further he was given
excellent fairwell par:q along with whole of faculty participated
and he never raised any objection. But it seems that your client
has become
greedy and after accepting the termination and all
the terminal benefits, he has sent the present false and frivolous
2.
a
J.
4.
t\W
M. S. Ahluwalia
Advocate
5.
J-9l48-B'(Ist Floor)
Rajouri ClrJen.
Ne'rv l-ielhi-.i i0027
Mob.9811040827
'
E-mail: msahluwalia20036)vahoo.co'in
notice
just
to illegally extort money from my client. In fact
there is no norm of AICTE that there is retirement age is 65 for
the Director. In fact AICTE norm states that no person shalt be
appointed as a Director whose age is above 65 years. It seems
that your client is trying to distort the said norm
just
to take
unfair advantage.
Contents of para 5 of the notice are wrong and denied. It is
denied that my client with oblique motive and malafide design
has acted in utter disregard of the said principles, norms and
rules etc., has terminated the services of your client without any
justification. In fact my client has acted in accordance with the
said principles, but now it seems that under the garb of the
present notice, your client is trying to illegally extort money
from my client. The said fact c.learly demonstrates from the
.fact that your client clearly has sent this false and frivolous
notice after a span of more than three months. It is denied that
when your client himself received the one month salary from
my client, as such there is no occasion for.your client to raise
this false and frivolous issue and to harass my client. That after
'-
receiving one month salary as per terms and conditions of
appcintmont letter, y'cur client i:as ';cluniarily accrlpieci
'iire
notice and termination letter.
Contents of para 6 of the notice are wrong and denied except to
the fact that the notice was issued on 15.4.2013 and letter of
relieving dated 13.5.2013. It is denied that the said letters are
nonest being wholly illegal and void. It is denied that your
client has any right to continue with the service. He has
6.
M
M. S. Ahluwalia
'' Advoqate
J-9l48-B,(Ist
Floor)
Prajouri Garden'
ii*.; Delhi'it0ii27
Mob.9811040827
E-mail: msahluwalia2003@vahoo'co'hr
happily
accepted
the termination
notice along.with
one month
Salary.
It is denied
that your client,s tensure of service
was to
be completed
on 20.12'2013'
In fact your client
got the
appointment
with the institute only at the age of 60 years and
there is no condition
that he is to retire at the age of 65 years'
It is denied
that
your client has any right to demand back
'salaries/
dues from the date of termination
of his services'
It is
denied
that termination
of service is illegal. It is further denied
that my client is liable to pay salary and
perks :upto 20'12'2013'
it is denied
that
your client is entitied. for compensation,
damages
for termination
of his services.
It is denied that my
clienthascausedanyharassment,mentalagonytoyourclient'
Pleaseadviseyourclienttowithdrawthesaidnotice
forthwith.
In case he proceeds with his illegal designs, the
same shall be defended
at your client's costs'
risks and
.ponsequences.
A copy' of the present reply is kept in my office for
future reflerence.
ryt*
(M"njit Singh
luu,eliar\
Advocate
C.C. to
Dr. P.S. Vishnoi,
Son of Late Sh. R.K. Shastri,
R/o C-520, Sarita Vihar
New Delhi-110076.