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Under instructions and on behalf of my client, (Your Name), residing at (Your Address), contactable at (Your Contact), I hereby issue this Legal Notice to you as under:
1. That my client entered into a Rent Agreement dated (Agreement Date) with you, whereby my client took on rent your property situated at (Property Address), on a monthly rent basis. The tenancy commenced on (Start Date) and concluded on (End Date).
2. That at the time of entering into the said Rent Agreement, my client paid you a refundable security deposit of Rs.(Amount) on (Date) by way of (Payment Mode), which was duly received and acknowledged by you. The said deposit was paid as security against any genuine damages and was to be refunded in full upon vacation of the premises.
3. That my client vacated the said premises on (Vacating Date) and handed over peaceful possession of the property to you in good condition, subject to normal wear and tear. All dues towards rent and utilities were cleared by my client prior to vacation.
4. That despite the vacation of the premises on (Vacating Date), you have failed and neglected to refund the security deposit of Rs.(Amount) to my client till date, notwithstanding the fact that the deposit was to be refunded by (Due Date). You have made no deductions whatsoever and have provided no valid legal justification for withholding the said amount.
5. That my client sent multiple oral and written reminders to you requesting the refund of the security deposit, the last such communication being on (Date). Despite the same, you have chosen to wilfully ignore my client's legitimate demands and continue to wrongfully withhold the said amount, causing my client undue financial loss.
6. That your aforesaid conduct amounts to a clear and wilful breach of the terms of the Rent Agreement. The wrongful retention of the security deposit after fulfilment of all tenancy obligations by my client constitutes unjust enrichment and breach of contractual obligations at the expense of my client. Such conduct may also entitle my client to pursue appropriate remedies before consumer forums, wherever maintainable in law.
7. That my client possesses documentary evidence including the Rent Agreement, proof of payment of the security deposit, communication records and proof of handing over possession of the premises, all of which are available and shall be produced as and when required.
DEMAND: I, on behalf of my client, hereby call upon you to pay the following amounts to my client within 15 (fifteen) days of receipt of this notice:
a) Principal security deposit: Rs.(Amount)
b) Interest at 18% per annum from the date of default
c) Legal notice charges and costs
Total: Rs.(Amount) plus applicable interest and costs
Payment to be made via bank transfer to the account details provided by the Noticee.
8. That in the event you fail to comply with the above demand within the stipulated period, my client shall be constrained — without any further notice — to initiate the following legal proceedings against you, entirely at your risk, cost and consequence:
a) A civil suit for recovery of the said amount along with interest and costs before the competent court having jurisdiction;
b) Appropriate remedies before consumer forums under the Consumer Protection Act, 2019, wherever maintainable in law;
c) Appropriate civil recovery proceedings before a competent court as may be advised;
d) Any other legal remedy available under law, including criminal proceedings where applicable.
Nothing contained herein shall be construed as a waiver of any rights or remedies available to my client under law.
This notice is being served upon you by Registered Post Acknowledgement Due (RPAD) and shall serve as conclusive proof of your knowledge of these proceedings.
This is your last opportunity to settle this matter amicably. Please govern yourself accordingly.