Reply To Legal Notice (Patra Enterprise)

WITHOUT PREJUDICE

SPEED-POST/COURIER/EMAIL

Date: .03.2024

To,
M/S Patra Enterprise
Represented by Mr. Sudhanshu Patra
R/O Unit No. 102, Dhuri IND, EST PH- 5,
Complex No.1, Survey No.74, Hissa No. 1/2 ,
Waliv Pha, Vasai , Palghar, Maharashtra – 401208
Mobile No.- 70571366009, 7276047396
Subject: Reply to the Legal Notice for Settlement or

period extension of Mortgage loan amount of
Rs.6,00,000/- bearing account number PR00959972
Sir/Ma’am,
On the instructions of our Clients, SBFC FINANCE, Neptune

Element, Plot No. F3 & F4 -1, Road Number -22, Krishnagar,
Wagle Industrial Estate, Thane West, Maharashtra – 400604, we
respond to your Legal Notice dated 10/02/2024.
In this regard we reply as under:

1. That at the very outset, we vehemently deny the
contents of aforesaid notice and submit that the said
notice is erroneous as it is not based on true facts.
That it is apparent that you have chosen to conceal
the omissions and failure on your part to adhere to the
terms of the Agreement dated ………….
2. That the Legal Notice is devoid of any substance and

cause, and that the contentions and allegations raised
in the Legal Notice are baseless, misconceived, and
false, and hence, are denied.
3. That no averments, statements, submissions, grounds,

contentions, or allegations made in the Legal Notice
are admitted or deemed to be admitted by our clients,
save and except when expressly admitted.
4. That SBFC FINANCE take exception to the accusatory

tenor of the Legal Notice and strongly deprecate the
ill-founded claim that made therein. Our clients deny
all the contents of your Legal Notice as being baseless
and without any merit. It is entirely malicious to make
the claims by way of the Legal Notice, under
reference, which have been vehemently disputed and
denied in its entirety.
REPLY ON MERIT
1. That SBFC FINANCE has given a mortgage loan amount to

you on 30/10/2021 for purchasing of office property for at
Shree Ganesh Apartment Room No. 306, A wing, Vianayak
Nagar, Moregoan Talav, Nalaspara East, Palghar ,401209.
The loan amount was 6,00,000 /- (Rupees six Lakhs only)
and the monthly EMI of 14,052 /-.
2. That despite the severity of the situation, it appears that

the SBFC FINANCE was not informed immediately after
the occurrence of the fire accident. Such a delay in
reporting this critical event could potentially have had
adverse consequences, not only for the property but also
for the safety and security of all involved parties.
3. That the mortgage loan amount provided by SBFC finance

to you Rs. 6,00,000 /- (Rupees six lakhs only) for which
the agreed tenure was (……..]. As per the terms outlined
in our agreement, my monthly Equated Monthly
Instalment (EMI) is set at INR 14,052. You have hesitantly
made […….] monthly instalment payments, ensuring
timely fulfilment of my financial obligations as per our
agreement.
4. That there is a remaining outstanding amount i.e., …….

with interest @........that must be paid by you.
5. That In light of the situation, you proposed two feasible
options for loan settlement:
A. Option 1: Settle the loan by paying a lump sum amount
of [settlement amount], constituting [percentage] of the
outstanding balance, as a full and final settlement. This
approach not only saves SBFC Finance the hassle of
recovering the loan from a bankrupt borrower but also
alleviates the debt burden for my client.
B. Option 2: Extend the loan repayment period by [number
of months or years], accompanied by a reduced
instalment amount of [new instalment amount], and a
lower interest rate of [new interest rate]. This
adjustment would afford my client the necessary time
to recover from the loss and resume business
operations.
Regrettably, that SBFC Finance has not found consensus
in either option. Consequently, we urge you to reconsider
and visit our office for the furtherance result to the current
situation.
6. That the Legal Notice under reference has been issued

with a malafide and ulterior motive to achieve unjust
enrichment and unlawful financial gains at the costs and
expense of our clients. The claimed, is disputed and as
such contrary to the terms of the Agreement. You are,
therefore, at the outset, advised to withdraw the subject
Legal Notice issued to SBFC FINANCE .

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WITHOUT PREJUDICE

Subject: Reply to the Legal Notice for Settlement or

On the instructions of our Clients, SBFC FINANCE, Neptune

In this regard we reply as under:

2. That the Legal Notice is devoid of any substance and

3. That no averments, statements, submissions, grounds,

4. That SBFC FINANCE take exception to the accusatory

1. That SBFC FINANCE has given a mortgage loan amount to

2. That despite the severity of the situation, it appears that

3. That the mortgage loan amount provided by SBFC finance

4. That there is a remaining outstanding amount i.e., …….

6. That the Legal Notice under reference has been issued

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