and also made his best to convince and warn you both the parties for nm

indulging into such sort of criminal activities, and if despite all

theseefforts on the part of my client, you were not to pay any heed to
the same and are still sincere to continue to behave impudently and
thereby trying to prove yourself to be procourante in all such respects,
then it will be totally deleterious and lead to you your own destruction,
destiny anddecadent.
14. That in the circumstances, my client does hereby call upon you not
to indulge into such criminal and illegal activities and particularly
the Nos. 4 to 6 of you should abstain, desist and refrain yourself from
committing such a criminal offence, failing which my client will be
constrained, against his own wish and will, to take against you both the
parties (except No. 3, his loving old mother, who is everything and all
for him) appropriate legal actions including lodging criminal complaints
as well as filing civil suits and writ petitions in the Hon'ble High
Court of Judicature, and in that event, the total responsibility as to
the costs and consequences of such actions shall be that of yours, which
please very seriously note.
15. That it is a fervent request hereby made by my client to the Nos. 3
to 6 of you in particular and the Nos. 1 and 2 in general not to smother
and swamp my client and his legitimate, bonafide and fundamental legal
rights, lest there shall be perturbing aftermath, and then, you shall
have no moral right to blame my client for the wiles and all the illegal
acts, deeds and things indulged into by somebody from you, which please
note.
16. That you should never arrive at a hallucinating stage to the effect
that individual shares in the ancestral property can be sold partially
with illegal terms and conditions, and such a totally wrong conception
may trigger off the very purpose, which please note very carefully.
17. That you are also hereby advised to note, in your own interest only,
thatin that event, you will have to consider, think and give, at least,
a second thought to your ideas that you shall have to thank none but
yourself for your own illegal acts, deeds and things and all the faults
and follies on your part, which please further note.

could still be challenged by my client either in an appropriate civil

court of law or directly in the Hon'ble High Court of Judicature at
Mumbai, for the very reason that since the said properties have not yet
been divided and distributed in metes and bounds, there could be no valid
transaction which could be entered into by any of the members of such
an undivided and joint family as that of my client's.
8. That my client says that if the fear in his mind were to be true,
it would
have very bad repercussions on the family as a whole, and my client shall
unnecessarily be unhappy on that count for no fault of his.
9. That my client is afraid to express that if any sale-deed were to
be executed
by any or all of you, it would amount to deception being played by you
on my client by entering into a bogus transaction and also by executing
totally false and illegal sale-deed, if any.
10. That my client does hereby reiterate that if any sale-deed were to
be executed by the Nos. 3 to 6 of you in favour of the Nos. 1 and 2 of
you, it will be totally illegal and void oh initio, and the same shall
not have any legality, and the family consisting of my client and the
Nos. 3 to 6, as a whole, shall be subjected to ruin and destruction,
which please note.
11. That in spite this very clear and legal position that when there
is no absolute or exclusive legal right in existence which could be
exercised by the Nos. 3 to 6 of you, it appears that you are trying to
play, with common intention, a great mischief with the Government
authorities by executing a bogus and illegal sale-deed, and hence, as
per the provisions and interpretation of Criminal Law, you will all be
liable for committing a criminal offence, which you should please note.
12. That my client has recently learnt that the Nos. 4 to 6 of you
[keeping the No. 3 in complete dark and ignorance - she being in her
decrepitude] have been making attempts to illegally sell and dispose of
the said properties to the Nos. 1 and 2 of you and thereby committing
the offence of fraud and deceit, which will be a cognizable criminal
offence on the part of the Nos. 1, 2, and 4 to 6 of you, which please
note.
13. That my client has, thus, already brought to your notice all these
illegalities

Sirs,
Instructions front and on behalf of my Shri 14- resident of ----
------------------
I have to address you this notice as
client is a son 01' the No, 3 of you, while the real brother of the

Nos, 'I, :► and o of you, That the properties bearing Survey No, 300
and City Survey No, ancestral properties presently owned and possessed
by my client and the Nos, 3 to ft of you,
1, That the said properties are owned ii J I pc)ssessed by the Nos. 3
to 6 of yon
and my client jointly, and they have never been divided and distributed
among all 11, concerned,
That iny client says that he is blessed and really very prowl to claim
that the relationship among all his brothers, sisters and all the kith
and kin has always had been very cordial and highly affection:lie, and
he further says that he is so fortunate to accommodate himself with all
such healthy atmosphere and domestic climate.
5. Thal in spite of this situation and the very beau ideal in the mind
and
heart of my client, he was shocked to learn very recently that the Nos.
3 to ft have proposed to sell and dispose of the said ancestral properties
in favour of the Nos, 1 and 2, and my client was actually broken into
pieces on that account for the very reason that the said properties have
been owned and possessed 1101 only the Nos. 3 to 6 of you but also along
with them by my client and two of his sisters, too, and as per the
provisions of the relevant rules of law, no sale-deed could be executed
or conveyance made unless and until all the necessary and interested
parties arc joined.
6. That you are also aware that the said properties have not yet been
divided, and they are jointly owned by the Hindu Undivided Family
consisting of the Nos, 3 to 6 and my client, as aforesaid.
That my client wants to make it explicit that if the Nos. 3 to 6 were
to execute a sale-deed in respect of the said properties or convey their
undivided shares in favour of the Nos, 1 and 2, it would he bad in law
and