Legal Notice from Adam & Associates To Kamlesh D.Patel

Posted On Friday, February 10, 2017 | 6:33:09 PM

Adam & Associates
Law Firm
Jubair Ahmad Khan,
Advocate
314,C.K.Daphtary Block, Off:-259/A-3, Nayyar Manzil,
New Lawyers Chamber, Noor Nagar, Jamia Nagar,
Supreme Court, New Delhi-1 New Delhi-110025,
Phone No: 23381727, Phone No.26840591
Tel. & Fax 23381727 Mobile- 9891023875
REGISTERED AD/ SPEED POST/COURIER
2nd February, 2017
From the office of:
Jubair Ahmad Khan
Advocate
To,
Shri Kamlesh Desaibhai Patel
c/o Shri Ram Chandra Mission
Babuji Memorial Ashram
Manapakkam Main Rd,
SRCM World Headquarters,
Lalithamba Nagar,
Manapakkam, Chennai,
Tamil Nadu 600125
email: daaji@heartfulness.org

Shri Kamlesh Desaibhai Patel
Shri Ram Chandra Mission Road,
Manapakkam, Chennai,
Tamil Nadu 600125.

Shri Kamlesh Desaibhai Patel
c/o Shri Ram Chandra Mission
Yogashram, Hardoi Road,
Rosa Post,
Shahjahanpur - 242 406.

Shri Kamlesh Desaibhai Patel
c/o Shri Ram Chandra Mission
R C Puram Mandal Office,
Bhel Township,
Ramachandra Puram,
Hyderabad, Telangana 502032

Shri Kamlesh Desaibhai Patel
c/o Shri Ram Chandra Mission
Plot No. 2, Institutional Area
Sector – 4, R.K.Puram,
New Delhi-110022.

LEGAL NOTICE 
Upon the instructions of my clients namely Shri Shubh Chintak Kishore S/o Late Parmatma Kishore Mathur 
R/o A-6/2, Rana Pratap Bagh, Delhi-110007, 
Shri Sharad Chandra S/o Late Prakash Chandra 
R/o Rai Bahadur Buildings, Mohalla Dewan, Jograj, Keruganj, Shahjahanpur U.P - 242001 and
Shri Anand Sarup Khullar S/o Late I.S. Khullar 
R/o B-75, Swami Nagar (North), near Panchsheel Enclave, 
New Delhi-110018 
and on their behalf, I do hereby serve you the following notice:
1. That “RAM CHANDRA MISSION” was founded in 1945 by Mahatma Ram Chandraji Maharaj of Shahjahanpur (U.P), in order to fulfil his sacred mission and serve humanity in an organised way. Mahatma Ram Chandraji Maharaj of Shahjahanpur (U.P), a renowned personality popularly known as “Babu Ji” worldwide, having an
exceptional calibre, blessed and bestowed by “Nature” with exemplary and special honour with title of Special Personality, had introduced a simple system named
“SAHAJ MARG” based on principles of spirituality, for moral and ethical (spiritual) education and for the attainment of social and moral aims of life. The moral and ethical (spiritual) education under the system of “Sahaj Marg” enables an ordinary person to become human being in its true sense, to be able to attain the object of life by leading a happy and balanced life following the “SAHAJ MARG”. 
Mahatma Ram Chandraji Maharaj of Shahjahanpur (U.P) had also got registered the system of “SAHAJ MARG” under the name of “RAM CHANDRA MISSION” under the
provisions of the Societies Registration Act, 1860, in the year 1945. 
The primary aim and object of the mission is to encourage the common man/woman and promulgate amongst them, the easier method practicable to them for the attainment of the social and moral aims of life, based on the principle of
spirituality, translated as “SAHAJ MARG” free of cost .
2. That as per the Constitution and Rules (memorandum of association) of “RAM CHANDRA MISSION”, the members and officer bearers of the said mission are under obligation to discharge their duty sincerely and in true manner by
propagating “SAHAJ MARG” for the purpose of achieving the aims and objects of the mission. The office bearers and members of the said mission cannot fall short of their duty and requirement for propagating “SAHAJ MARG”. 
The constitution and rules of the said mission also cast an obligation upon its office-bearers and members that the funds of the mission shall be wholly utilised for the promotion
and propagating “SAHAJ MARG” and the funds of the mission shall not be utilised for any other purpose and that all possible care or safeguards taken against its improper use. 
The constitution of the said mission further imposes obligation upon its office bearers and members that neither any activity shall be done nor any decision shall be taken by them which will jeopardise or in any way harm the
system of “SAHAJ MARG”, the pious object for which the mission was founded. 
The constitution of the said Mission further stipulates that the Mission will discourage and stop by legal means the improper and evil practices or mistaken and wrongful
ideas in the name of spirituality or in any way thwarting, degrading, supressing, minimising, injuring or effecting the cause or standard of Spirituality of the Mission.
3. That the system of SAHAJ MARG has become very popular around the world and it has also gathered huge following of the people all over the world over a span of
seven decades, by practicing the same free of cost. 
There are thousands of centres of SAHAJ MARG system all over the world including India. 
My above said clients namely Shri Shubh Chintak Kishore S/o Late Parmatma Kishore Mathur R/o A-6/2,
Rana Pratap Bagh, Delhi-110007, 
Shri Sharad Chandra S/o Late Prakash Chandra
R/o Rai Bahadur Buildings, Mohalla Dewan, Jograj, Keruganj, Shahjahanpur U.P-242001 and 
Shri Anand Sarup Khullar S/o Late I.S. Khullar R/o B-75, Swami Nagar (North), near Panchsheel Enclave, New Delhi-110018 
are few of the true admirers and followers of “SAHAJ MARG” system amongst the persons following the said
system all over the world. 
Shri Shubh Chintak Kishore, Shri Sharad Chandra and
Shri Anand Sarup Khullar are closely associated with “SAHAJ MARG” system spiritually, emotionally and sentimentally and they have been practicing “SAHAJ MARG” system for more than 50 years, 37 years and 34 years respectively, by
realizing its beneficial impact of transformation in their thinking and daily routine of life in a natural way. 
In this way, my above said clients have also been successful in suggesting other fellow beings strengthened by transformation in their personal conduct to try and practice SAHAJ MARG system as a natural means for leading a
normal, happy and satisfied life, thereby my said clients are also professing and communicating spiritual teachings of “SAHAJ MARG” system.
4. That you, the noticee, Shri Kamlesh Desaibhai Patel, a businessman of USA citizenship, has also been associated with SAHAJ MARG system since the year 1978
without any complaint about the system all these years, thereby signifying your satisfaction for the system.
5. That you, the noticee despite having been associated with SAHAJ MARG system for more than three decades, got registered an institute in USA (Texas) in the name of
HEARTFULLNESS INSTITUTE, with emphasis more on physical relaxation. 
You have mala-fide and dishonest intention, right from the inception of getting the HEARTFULLNESS INSTITUTE registered, to divert the followers of “SAHAJ MARG”
and innocent people towards HEARTFULLNESS, by using the popular name and specialized technique of SAHAJ MARG without naming it so. 
You, the notice, also have mala-fide and dishonest intention to replace SAHAJ MARG by
HEARTFULLNESS by practising HEARTFULLNESS in SAHAJ MARG Centres all over the world.
6. That with the abovesaid malafide intention to replace SAHAJ MARG system with HEARTFULLNESS 
and diverting the followers of SAHAJ MARG towards 
HEARTFULLNESS, you, the noticee had published quarter page advertisements on front page for HEARTFULLNESS in the newspaper, ‘Times of India’ on 01.01.2017
and 04.01.2017 in a big way offering three days free online lessons scheduled to be held on 2nd, 3rd and 4th January, 2017. 
You, the noticee has been misusing builtin facilities at every SAHAJ MARG centre in India and abroad, by practising
HEARTFULLNESS system inside them. 
You, with malafide intention to replace
SAHAJ MARG system with HEARTFULLNESS and diverting the followers of SAHAJ MARG towards HEARTFULLNESS in collusion with others, have been practising a different system named HEARTFULLNESS in SAHAJ MARG centres all over the world including India for promotion and popularization of HEARTFULNESS, to support your undeclared vested interest. You have been unauthorizedly and mischievously
misguiding that Heartfulness is same as Sahaj Marg and thereby practicing, altogether a new undefined concept of HEARTFULLNESS in all the centres of SAHAJ MARG system all over the world and that your such activities are utmost
detrimental to the aim and object for which RAM CHANDRA MISSION was founded.
7. That you, the notice, through your advertisement in Times of India newspaper on
1st and 4th January, 2017, advertising online free Heartfulness practise for 3 days have given room for justified reason for confirmed belief under the law that you
have been charging for practise of Heartfulness at all the centres of Shri Ram Chandra Mission on regular basis and have received huge funds for the practise of Heartfulness all these years and from 5th January 2017 onwards in fulfilment of your undeclared vested interests but without disclosing to the members of Sahaj Marg mission whether or not you have registered Heartfulness with the Income-tax authorities in India and that whether or not you are also duly filing the income-tax return for the income derived from Heartfulness practise and that your failure to do so raises the natural presumption that you are clandestinely transferring such funds to the country of your residence or elsewhere as per your choice thereby infringing the provisions of FEMA.
8. That you, the noticee ,have debased with impunity with complete disregard to the pious special technique of SAHAJ MARG system by showing it as passing through television satellite waves thereby making mockery of that special technique just to enhance your undefined vested interest.
9. That you, the noticee, take notice that imparting of moral and ethical (spiritual) education by the name of SAHAJ MARG is already registered by its founder and the
services are being rendered free of cost since 1945, but you have also illegally registered at Kolkata, California (USA) and running parallel wise, calling it non-profit organisation in the name of SAHAJ MARG SPIRITUALITY FOUNDATION or SMSF without explaining the need for doing so . 
Therefore your such acts of running other organizations are highly objectionable as SAHAJ MARG system is rendering 
subtle services like spirituality, which is not a subject of any business to be run by any other Organisation/Corporation.
10. That SAHAJ MARG system of moral and ethical (spiritual) education is to bring pure humanity for realization of reality free of cost, which further helps people to
educate themselves to live, happy and balanced satisfactory life, while HEARTFULLNESS is mainly physical relaxation at a cost. When SAHAJ MARG system is not using the banner of any other organization, it would also not allow any other
organization to use or adulterate its techniques by mixing it with something else or altering it to suit their vested interest and inflict serious damage to the Nature’s sponsored cause of SAHAJ MARG being propagated for bringing pure humanity or spirituality free of cost for benefit of general masses.
11. That as stated above, you offered three days free online lessons scheduled to be held on 2nd, 3rd and 4th January, 2017 by publishing advertisement of HEARTFULLNESS in the newspaper, ‘Times of India’ on 01.01.2017 and 04.01.2017.
This has involved into incurring of huge expenses on various activities connected with the practice of HEARTFULLNESS. This has led to a reasonable question as to wherefrom the money has been financed or collected or invested for the said purpose in India. That you, being a foreign national, have incurred expenses in India which is evidenced by your aforesaid advertisements and your aforesaid illegal activities without any permission from the appropriate authority, attracts the provisions of FEMA.
12. That you, the noticee, being a foreigner is not entitled to become the head of any organization registered in the country. It is further intriguing what authority in
Sahaj Marg System is supporting you?
13. That you are also utilising the funds collected by using the name of “SAHAJ MARG” system for the promotion of aim and objects of HEARTFULLNESS which is a
different organisation from RAM CHANDRA MISSION.
14. That performing the pious duty in achieving only the aim and object (“SAHAJ MARG” system like in the present case) of the society for which it is established, is fundamental requirement in the concept of rule of Societies Registration Act, 1860.
You, the noticee, having been associated with “SAHAJ MARG” system for more than three decades, have become the protector and preserver of “SAHAJ MARG” system.
At the time of undertaking the sacrosanct duty to propagate “SAHAJ MARG” system, it was expected from you, the notice, that you will adhere to rules and the constitution of RAM CHANDRA MISSION positively and shall act objectively for the promotion and preaching the teaching of “SAHAJ MARG” system. But you have acted in such a manner by which the ultimate aim and object of promoting “SAHAJ
MARG” system has been frustrated and it was not at all desirable from you to promote a different technique of HEARTFULLNESS under the shelter of “SAHAJ MARG” system. Neither office bearers of the said mission nor its members or any other person are allowed to act in manner which are detrimental and damaging to the aims and object of the mission i.e. “SAHAJ MARG” system. You are intentionally deceiving people into belief that HEARTFULLNESS is the primary aim and object of
““RAM CHANDRA MISSION” like the “SAHAJ MARG” system, which is in fact not true at all. In fact, you have not done anything for promotion of “SAHAJ MARG” system.
15. That you, the noticee, take notice that your activities as mentioned above are in the nature of thwarting, degrading, supressing, minimising, injuring or effecting the cause or standard of Spirituality of the mission i.e. “SAHAJ MARG”. You have acted in such a manner that has caused damage to “SAHAJ MARG” system, the primary aim and object of the RAM CHANDRA MISSION. You have intentionally and
deliberately acted in a manner that the aims and object of the mission is either failed or deviated in any other way from the standard set-up by RAM CHANDRA MISSION. You have acted with mala-fide and dishonest intention which has
jeopardised and harmed the object of “SAHAJ MARG”.
Please take notice that I, upon the instructions and on behalf of my aforesaid clients, hereby requesting you to stop all the activities, which are detrimental to “SAHAJ MARG” system, the primary aim and object of RAM CHANDRA MISSION forthwith, failing which, my aforesaid clients have instructed me to take all legal actions against you in accordance with law in this regard. The copy of the present notice has been retained at my office for the purpose of utilising the same before any Court of law.
Jubair Ahmad Khan
Advocate
.


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