Abhinav Srivastava Legal Notice

7/28/2019 Abhinav Srivastava Legal Notice

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To

1. Abhinav SrivastavaManager HRLupin Ltd.B/4 Laxmi TowersBandra Kurla ComplexBandra (E)Mumbai 400 051IndiaPhone: +91 22 6640 2222Fax: +91 22 6640 2130

Also at:

Flat no-402, Amansprings Aptt (near Laljipada)

Kandivli(West)

2. Anil Kumar,

3. Mrs Kusum Lata Srivastava

Both at:

Basera D2/501, Sector-F Jankipuram

Lucknow (ph: 0522-2754008 mob: 9439075210(father)

LEGAL NOTICEWITHOUT PREJUDICE

BE YOU FOREWARNED

That under instructions from my client, Ms Neha Srivastava, d/o ShriAnil Kumar Srivastava, resident of Delhi, address being presentlywithheld for security reasons, (hereinafter Client), I give you noticeas under:

1. That my Client met Noticee No 1 (hereinafter Abhinav) in the

summer of 2004 through her cousin, who insisted on meeting him ashe thought they might like each other because of the common


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interests my Client and Abhinav shared.

2. The my Client and Abhinav started dating right from the month ofJune, 2004.

3. That my Client and Abhinav started working together in Gurgaon inAugust 2005 and that is when the parties started living together as myClient was promised that a marriage would be in the offing.

4. That initially my Clients parents were not very elated at the prospectsof this relationship as they feared that my Client and Abhinav camefrom different backgrounds and Abhinav was not well established inlife. However, my Client was able to prevail upon her parents and thecouple got engaged in the month of October 2006.

5. That the engagement expenses were shared by the parents of bothparties. My Client was happy as she assumed that if this spirit was tocontinue throughout the marriage, her family would not be burdened.However, Abhinavs mother, called my Client home after theengagement under the pretext of buying jewelry and clothes of mychoice. While purchasing the gift items, my Clients mother-in-lawindirectly suggested as to what kind of jeweler should her parentsshould buy and what gifts should be given in the marriage. My Clientwas told that there was something called "saas ka baksa", which

should apparently have expensive sarees, jewelry, bed sheets,sandals, cosmetics etc...(which she eventually got but wasdisappointed by what my Clients family had given her because it wasway below her expectations).

6. That my Clients mother-in-law therefore demeaned her in front ofothers guests assembled during the wedding. This humiliationcontinued even thereafter and my Client had to tolerate the taunts tillone year after marriage. My Clients parents-in law insisted that themarriage which cost my Clients parents more than Rupees 15 Lakhs

(apart from all the travelling they did for almost 3 months for arrangingthings in Lucknow as the in-laws extended no help to them despitethe fact that they were in Lucknow and it was they who had insistedthat the marriage should be held in Lucknow) was not satisfactory.

7. That as my Clients was not an arranged marriage in the traditionalsense, when she brought all this to the notice of her husband, he wasnever bothered about what was happening, all he did was to pretendand say that these are necessary traditions and that the couple mustnot get involved.

8. That my Client felt very betrayed and cheated as when the couple


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had decided to marry, her husband had never told her about these socalled 'traditions in his family'. Lies were told right from the beginning.Abhinav had said that his father was an 'officer' in SBI, who turnedout to be a senior clerk and Union Leader (not that it mattered to myClient or her family). My Client did every bit to please Abhinavsfamily, and so did her parents.

9. That at the time of the marriage, Abhinav had held out to my Clientsparents that he would take her to Switzerland for the honeymoon. Hehad also demanded that they contribute half the amount to buy aSedan before the marriage.

10. That in fact, my Client was taken to Ajanta Ellora for a honeymoonand that too because it was just 100 km away from where Abhinavworked (i.e Aurangabad).

11. That my Client was pursuing MBA from a college in Gurgaon,because Abhinav had promised never to move out of NCR, but thensoon after the couple married she had to leave Gurgaon and move toAurangabad. Though my Client never realised it back then, but nowas she introspects, it is apparent that he was always into his work andhad his own priorities. For first couple of years my Client thought thatthis was the time to stand right besides him to help him grow and hedid. That my Client never doubted his capabilities. However she was

greatly distressed when he would support his mother's action oftaunting her. That my Client's mother in law would keep taunting hersaying that the marriage reception was the talk of the town but theMarriage ceremony was so mediocre. That she wanted it to be hostedat the Taj Hotel knowing fully well that for a service-class familyarranging such a reception for almost 500 people in Taj Hotel (a starhotel) would be backbreaking.

12. That my Client resumed her MBA course again in 2008. She used tostudy and make sure that she never lacked in the duties as a wife.

She made all efforts to enhance her husband's career by maintaininggood relations with office staff. She got involved in his office kittywhere she used to interact with his office colleagues and bosses.

13. That for every vacation or leisure trips undertaken by the couple, myClient was required to plan the same and such vacation had to besponsored by my Client's parents. Thus it was not only monetary butthere was a lack of interest and initiative of any kind to keep thismarriage alive on the part of Abhinav.

14. The trouble started in the month of May 2010, when because of hisindifference, my Client let herself be persuaded by her husband to


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come to Delhi for a job. That Abhinav had stated that till the time myClient was unoccupied, she would expect time from him which hesimply could not give. He also promised to follow my Client as soonas he found a better opportunity, within couple of months. That myClient was somehow convinced. She came to Delhi and startedlooking out for jobs. He would not call my Client for days at a stretchand the only excuse he gave was his work. One day, she received acall from one of his colleague's wife stating that she should comeback home because..."Abhinav is behaving little strange thesedays...". That my Client was shocked because she knew what shewas trying to imply. She rushed back to Aurangabad, to find Abhinavlittle disappointed by her arrival. That when she had to handle hismobile on one occasion, she found a couple of pictures of someunknown females. That when she asked him who they were he saidthat he went out with them to Paithan Dam which is around 60kmsdrive from Aurangabad. There was no regret or contrition. Heignored and slept as if nothing happened. However, after that incidentwhen my Client accidentally saw the mobile pictures, he startedlocking his phone, his PC, etc. That my Client still found few chatsand emails written to this one particular lady.

15. That Abhinav used to go to Lonavala and Mumbai, often for officialtours, my Client often asked him to take her along because stayingalone for 5-6 days at a stretch was very boring. However, he would

always give some or the other reason to avoid taking my Client onone pretext or the other, the most cruel of them was..." What wouldmy office people think..it would hamper my reputation!"...so my Clientstopped asking.

16. By this stage the pattern of behaviour witnessed changes. Abhinavwould always carry his phone to the bathroom, would find out ways tojust get away from my Client and make calls. That my Client foundparking tickets of PVR when she was not with him...all in all hestarted lying about everything and my Client started getting

suspicious. When my Client would bring up the issue, Abhinav woulddeftly deflect the issue to give the impression that he was kind ofashamed of my Client. He once even asked my Client to joinTalwarkar's so that his mother would be happy and would stopcomparing her with all those so called pretty women around her. Thatduring this period Abhinav consciously started excluding my Clientfrom his conjugal company on one pretext or the other.

17. That in October 2010 the couple moved to Goa where he joined LupinLtd. He went for a 15 days training to Lonavala and left my Client with

his parents. On 2.10.2010 when my Client shared her concerns withthem they started blaming her.Abhinavs mother (Noticee No 3) said


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unpleasant things about my Clients parents and they both did noteven let my Client talk to either Abhinav nor her parents. She had asevere Asthmatic attack that night and that is when his father(Noticee No 2) finally tried to reconcile. That what made mattersworse was that my Client called up Abhinav and begged him to comeand make things all right but he never came, inspite of the fact that itwas a weekend and he could have managed easily.

18. On subsequent occasions, my Client has been ticked off by Abhinavfor not going to Lucknow often, but he has forgotten that even after allthat happened my Client did go to Lucknow by choice not just oncebut, number of times as she knew that it will take time for them tounderstand and accept her, specially when Abhinav was not trying tohelp.

19. That while the couple were staying in Goa, there was increasingindifference on the part of Abhinav which caused grave mentaldistress to my Client.

20. That in August 2011, he asked my Client to go to Delhi. My Client,being deeply in love with him again believed his story that he wasserious about quitting his job and moving towards North.

21. That my Client came to Delhi and started looking out for jobs againhoping that Abhinav would follow in December, but then he said hehad a promotion due so will come once that happened.

22. That my Client would keep asking him to come and meet her onweekends but he never came for months on end.

23. That after some time, Abhinav started convincing my Client intoleaving my job and coming to Mumbai. My Client did so in April 2011.

24. That in Mumbai, Abhinav started behaving even more distantly. Hewas receiving late night calls and was spending quiet a while insidethe bathroom with his phone. Suddenly he had to go to Goa for fivedays on an official tour. After a long time, my Client asked him totake her along. He did not pay any heed to her request. So my Clienttold him that she would leave for Delhi, get over with an upcomingtrekking trip she had planned months ago and come back, by thattime he would be relatively free to help her find a job and spend somequality time after 8 months of separation.

25. That when my Client went back after 10 days, he was all changed, he


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told her that he has to go to office even on a Sunday. Just out ofsheer exasperation my Client said Leave me back at the airport halfjokingly. To her horror, he grabbed at the opportunity and straightdropped her back to the airport. My Client on her own came homeagain from the airport as she could not leave like this. She was tooshaken by such insensitive behavior.

26. That when my Client was tidying up the house she found a pack ofused condoms in his travel bag. Instinctively, my Client checked themanufacturing date, it was August 2011 (bought during the period myClient was not with him). My Client waited for him to come home, triedto ask him but all he had to say was, "tum pagal ho gae ho...". Nextmorning he did not even bother to talk to my Client and got ready toleave for the office. So, in utter humiliation, my Client had no optionbut to return to Delhi.

27. That after being consoled by her parents and determined to fight tosave her marriage, my Client returned to Mumbai on 15.05.2012.When my Client reached home, the premises were locked and myClient had no keys so she called Abhinav up. He said he has toleave for Goa the following morning so has gone to stay in his officeguest house which is close to the airport. However, when my Client

asked the security guard, he said that Abhinav left just 15 minutesbefore her arrival in hurry with a suitcase, and told him that he wasgoing to a friend's place to stay. While my Client was on the flight,Abhinav's father called my Clients parents asking about herwhereabouts and when he was told she had left for Mumbai, he wasangry and reprimanded them for letting her go without seeking his(Abhinav's father's) permission.

28. Incidentally, Abhinavs Chacha who stayed close by in Mumbai camealong with his family to visit my Client. Abhinav came at around 12

PM, almost after 1 and a half hour after my Client had called him upand his phone was constantly busy, while my Client tried calling himup.

29. When he reached home, he was furious at her for making himcancel his Goa trip...(which was a falsehood as my Client hasreliably learnt that there was no such trip planned officially.)

30. That the moment his chacha left, he closed the door and went off tosleep simply ignoring my presence. My Client went to him asking for

an explanation about his behavior (including his extramarital affair, afact which is not being emphasized at this stage and the evidence


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shall be pressed at the appropriate stage should the occasion soarise). He simply told my Client that he did not feel any love oraffection towards my Client. That my Client has faced a lot of crueltyat the hands of the Noticees. Once Noticee No 3 asked if my Clienthad some medical problem, because she was not conceiving. MyClient felt so hurt as it was he who was not ready for the child.

31. That night (15.05.2012) my Client asked him that things would befine, may be staying apart had taken away the charm, but somehowhe was not ready to listen to anything and asked her to leave and waitfor him to come if ever he planned to change his mind. My Client wasvery hurt, she could not believe anything that was happening, all shewanted was a hug and his affection but all he did was to ask her tostay away and sleep. My Client was so emotionally disturbed thatwhen she went to the bathroom, she felt dizzy and she mistook abottle with liquid for water and consumed the same and her throatstarted burning. It was some other substance. My Client startedcoughing badly and only then Abhinav came running asking what shehad done and all my Client could think of was ...please hug me for awhile. He simply called called up his father and started shouting athim saying things my Client cannot exactly recall on account of herstate. All my Client heard was "ye pagal ho gae hai...". His chachachacha came and rushed my Client to hospital. The Doctor keptasking my Client what happened, did her husband do anything, etc.

All my Client remembers saying is that it was not his fault.

32. That my Clients uncle and parents came in the next morning.

33. That at the hospital also my Client was ready to forgive and forget allfor the sake of saving her marriage and held him tightly and askedhim to take her home but all he said was..."tum jao".

34. That the stress and strain of the marriage and the incident of the 15thnight had taken a severe toll on the mental and physical health of my

Client.

35. That soon my Client received calls from Abhinavs office about himgoing around with some office colleague.

36. That my Client again visited Mumbai for one last time despite allhumiliation and pain. This time her parents also came with her forsupport and comfort as she was mentally and physically exhaustedby the cruelty meted out by the Noticees. My Client called Abhinav tosee her at Inorbit Mall, to which he said that he will not come and that

he will send his Chacha to pick her up. When my Client said shewanted a direct meeting and would go back, then he came to see her


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for 30 minutes. In-between he kept receiving calls from his parentsinstructing him to go home and not to talk to my Client. The partiesspoke and my Client thought there is still hope left but suddenly heasked her to leave and go back to the hotel she was staying and thathe cannot take her home.

37. Abhinav left my Client at the lift of the hotel and went back to hisChacha's place without even meeting her parents. That the next dayafter lot of begging from my Clients parents and her, they came tosee her and his Chacha shouted at my Client and blamed her foreverything.

38. That till date no efforts have been made by the Noticees to inquiry asto the mental and physical health and well being of my Client.

39. That my Client is now residing in Delhi and she and her parents havemade several efforts to contact the Noticees to work out a resolutionof the issues and secure the entitlement of my Client and return ofstridhan which had been entrusted to the Noticees. Unfortunately,there has been no encouraging response from the side of theNoticees.

40. That no monetary help or financial assistance has been forthcomingfrom the Noticees. My Client has been compelled to take monetary

help from her parents for a long time now. That during her marital life,her husband never gave my Client his credit card or debit card.Though the couple have an combined account in SBI, my clientopened byAbhinavs father 4 years ago, my Client has no access totill date.

41. That my Client again calls upon you to forthwith return in Delhi the followingitems: (two Gold Jewelry sets)

41.1. 1 long necklace,41.2. 1 short necklace,41.3. 2 pairs of earring, and41.4. 2 bangles

42. That my Client calls upon you to immediately make payment ofexpenditure undertaken in the wedding of parties by her parents (i.e.Rs 20 lakhs) as she is in urgent need of funds having expended herfamily resources on her Mumbai travels, treatment and legal andmedical costs.

43. That my Client also calls upon the Noticee No 1 to pay monthly

maintenance of Rs 20,000/- for her upkeep and maintenance.


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44. That my Client also calls upon the Noticees to provide an 2BHK Flatin Delhi for the residence of my Client.

That the demand hereinabove are made in assertion of rights of myClient under extant laws and in no way amount to a condonation ormitigation or waiver of the right of my Client to initiate criminalprosecution against the Noticees for the offences committed by themagainst her.

Yours sincerely

Sanjoy Ghose

Documents

Abhinav Srivastava Legal Notice