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Advocate

BY RPAD / EMAIL

03.10.2023

To

Ms. Shabnam Banu

Advocate

Flat No. (32, Ground Floor,

No. 7, Prithivi Apartments

2^nd Street, Seetha Nagar

Off Sterling Road

Nungambakkam,

Chennai 600 034

Madam,

Your notice dated 03.10.2023 sent on behalf of your clients ASICON

2018 CHENNAI, Association of Surgeons of India, 78^th Annual National

Conference, Organizing Committee, represented by its Relationship Manager Mr. Abdul Rasheed has been placed in my hands by my client Mr. A.R.Rahman, having office at No.5, 4^th Street, Dr. Subbarayan Nagar, Kodambakkam,

Chennai 600 024 with instructions to send the following reply

1. My client denies all the allegations contained in your notice under reply except those that are specifically admitted herein and put your clients to strict proof of the same.
2. My client denies the allegations contained in para 2, 3 and 4 of your notice under reply and states that my client has developed a stellar reputation as a world renowned singer, winning several awards and accolades for his musical talent. Our Client is a well-respected musician and an upstanding member of

No. 88/30 AA Block, 1st Street, Anna Nagar, Chennai – 600 040.

Tel : 91 (44) 2622 0452 E-mail : narmadhasampath@gmail.com

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the society, who has always been held in high regard in the public eye. My Client has contributed extensively to society through his philanthropic efforts and support for social causes. My Client has worked hard to develop his reputation over the years, and considering that the nature of my Client’s work requires that he remain in the public eye, it is immeasurably damaging for his career if my Client is subjected to any false and frivolous allegations which are defmnatory in nature.

3. My client further states that the entire notice reeks of malafides and oblique motives. My client further states that he has absolutely no connection whatsoever with your client ASICON. My client never entered into any contractual obligation with your client, but still for the sake of cheap publicity, your clients with a collateral motive are trying to sully my client’s image in the entire process. A bare perusal of the notice sent by your clients does not in any way show that my client had any privity of contract with your clients. My client further states that the amount mentioned in your notice under reply was not paid to my client which was paid to some third parties. It is strange that your clients are trying to involve the name of my client for a transaction with third parties. My client further states that in para 7 of your notice under reply, it has been stated that “at this juncture, it is crucial to note that without the express approval of the first of you, such a refund could not havé been possibly agreed upon”. It is clear that your clients had presumed such a thing and had the audacity to issue the legal notice based on mere surmises and conjectures. The entire allegations are made against one Mr. Senthilvelan and Group Company of Senthilvelan. Your client knowing fully well that my client is no way connected with the any of the monetary transactions, has chosen to drag my client into the instant controversy fer the reasons best known to your clients.

(N$ampm///

Advocate

4. My client filflher states that in para I l of your notice under reply, unverified facts have been Inade that the company is backed by my client which is far from truth. My client states that you have chosen to associate the name of my client only with a malafide intention to defame the good reputation of my client. It is also important to note that in the last five years, this was the first time my client is being made aware of these alleged transactions. My client states that your clients are making vain attempts to defame the reputation enjoyed by my client. It is farcical to state that my client is vicariously liable and also state that my client is morally responsible.
5. My client states that he has never entered into any transaction with your client at any point of time and also denies the allegation that your client had booked him for a show and paid an advance of to him. In order to gain media attention from the fame enjoyed by our client and in orderto harass our client you have also chosen to name him in the complaint given to the Commissioner of Police Chennai. It is crystal clear with a malafide intention to cause disrepute and to lower the esteem, knowing fully well that such imputations are baseless and vexatious. The magnitude of your assault on the reputation, esteem and the honour of my client is irreversible among the minds of general public. Your attempt to allege any transaction to which my client has not been a party to is done only with an intention to lower the esteem of my client. Knowing fully well that my client has not received a single penny paid by your client the criminal complaint was lodged and it was widely publicized in various newspapers both English and vernacular languages and also in social media has caused substantial damage to the impeccable reputation enjoyed by my client among the general public. The police complaint and the instant notice all are aimed with a single agenda just to defame the good reputation built by’ my client over a period of time.

No. 88/30 AA Block, 1st Street, Anna Nagar, Chennai – 600 040.

Tel : 91 (44) 2622 0452 E-mail : narmadhasampath@gmail.com

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In the above said circumstances your clients are hereby called upon to recall the notice dated 03.10.2023 within 3 days from today. An email is also sent to the email id provided by you in the notice, You are also hereby called upon to issue a public apology immediately, prominently publicized for defaming my client. My client also demands a sum ofRs. 10,00,00,000 (Rupees Ten Crores only) within a period of 15 days from today, as damages for the defaming the good reputation of my client, failing which please take notice that my client will be constrained to initiate legal action against your client both civil and criminal holding your client liable for all costs and consequences incidental thereto. If in spite of this reply notice, if your clients take any hasty action, the same will be defended appropriately at the cost of your clients’ costs.

Yours

(Narmadha Sampath)