Legal Question in Credit and Debt Law in Pakistan

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M/s NIMIR RESIONS Limited and Reduced

(Formally M/s NIMIR RESIONS Limited)

Through its Chief Executive Mr. ___________

_______________________________________

Subject: LEGAL NOTICE

Under the instructions of Muhammad Ashraf Sheikh son of ________________________________resident of _____________________________________(�my client�) to serve upon you the following notice:

1. That my client was appointed in your company namely NIMIR RESIONS Limited (a Private Limited Company) as Senior Marketing Manager vide appointment letter bearing Reference HR/23/0113 dated December 09, 2000.

2. That my client served the said company diligently, efficiently and with full devotion due to which the business of NIMIR RESIONS flourished to a great extent. In February 2004 a Memorandum of Understanding (MOU) was executed between DAWCHEM (a Public Limited Company) and NIMIR RESIONS Limited. By virtue of this MOU, DAWCHEM became the parent body and new management of DAWCHEM took over the charge of all affairs of the NIMIR RESIONS Limited in May, 2004. All the correspondence and reporting of business of NIMIR RESIONS Limited started to the head office of DAWCHEM. It is also pointed out here that after execution of said MOU all the employees of NIMIR RESIONS Limited including my client came under the direct control and management of DAWCHEM, however, name of NIMIR RESIONS Limited is continued to be used with one slight modification �NIMIR RESIONS Limited and Reduced� hereinafter referred to as �Company�.

3. That my client on 29.06.2004 presented his resignation to the Company with the request to settle his dues by 30th September 2004. But the management of the Company extended the time of service of my client till 31.10.2004 for the reason to completely handing over the charge and for re-confirmation of all the sales conducted within the tenure w.e.f. 09.12.2000 to 31.10.2004 after satisfying itself. On 01.11.2004 the management of the Company, vide letter bearing Reference HRD & A/PF-2117, accepted the resignation of my client and charge was completely handed over to the management of the Company.

4. That my client asked for his dues i.e. provident fund etc. the management ignored the matter. It is pertinent to mention here that my client bonafidely remained available even after acceptance of his resignation to the Company and even without any remuneration in respect of clarification of work done within his tenure of service.

5. That my client visited office of the Company many times and requested for the issuance of clearance certificate and realization of his lawful dues but the management delayed the matter with one pretext or the other.

6. That my client not only verbally but through letters dated ___________, again requested the Company for his lawful dues, but the Company instead of doing the needful has started extending threats to my client to curb his demand for dues from the Company to which my client is legally entitled and to which the liability of the Company in this regard is established one. Such acts of the Company are highly objectionable and have caused my client, who is an educated through gentleman and have great respect & honour in the society, great mental torture and agony due to which daily life and working of my client has been badly affected and he is in a state of continuous depression and suffering due to non payment of his dues and threats from your side. Please note that my client reserves his right to sue the Company for damages in that behalf.

7. That my client has repeatedly requested the Company for the payment of his dues after issuance of clearance certificate but the Company has delayed intentionally and deliberately payment of dues of my client and in response to my client�s claim the Company has chosen to snub my client illegally which acts of the Company are not permitted under the law.

Through this notice, you are hereby advised to pay my client�s dues after issuance of clearance certificate within fortnight from the receipt of this notice otherwise, I have full instructions from my client to initiate the legal proceedings against the Company and in that event the Company will be responsible for all expenses, consequences and costs etc. ensuing there from.

A copy of this notice has been retained in my office for further reference.

Yours faithfully,

Gull Hassan Khan Mayo

Advocate High Court

[email protected]