LAWGORITHMZ

(Advocates & Legal Consultants)

Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

Dated: 21/03/2025

BY SPEED POST/E-MAIL
WITHOUT PREJUDICE

TO:

1. Mahindra Holidays & Resorts India Ltd.

2. Sh. Manoj Bhat – Managing Director & CEO

3. Mrs. Preeti Chaudhary – Admin Team, Jasola

4. Mr. Vikram Kocher – Admin Team, Jasola

5. Sh. Prashant Joshi – Sales Team

6. Sh. Govind Verma – Sales Team

7. Sh. Sumit Dixit – Sales Team

Corporate Offices:

 Mahindra Towers, 1st Floor, “A” Wing, Dr. G.M Bhosle Marg, P.K Kurne
Chowk, Worli, Mumbai-400018
 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

 Mahindra Towers, 2nd Floor, 17/18, Patullos Road, Mount Road, Chennai-
600002

 P-2, Unit No. 215-217, 2nd Floor, Best Business Park, Netaji Subhash Place,
Pitampura, New Delhi-110034

 Salcon Aurum, 2nd Floor, Jasola Vihar, Delhi-110025

LEGAL NOTICE

Subject: Deceptive Trade Practices, Financial Fraud, Cybercrime

& Deficiency in Service

Dear Sir/Madam,

That under instructions from and on behalf of my client, Sh. Raghav Kapoor,
S/o Sh. R. Kapoor, R/o H.No. 1102, Mukherjee Nagar, Delhi-110009
(hereinafter referred to as “My Client”), I hereby serve upon you the present
Legal Notice, calling upon you to cease and rectify the fraudulent, deceitful,
and unlawful practices perpetrated by you.

That it has come to my client’s knowledge that you have engaged in unfair
trade practices, deliberate misrepresentation, financial fraud, and
cybercrime in the course of selling and executing a holiday package, thereby
 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

causing significant financial loss, emotional distress, and mental anguish to

my client.

FACTUAL BACKGROUND

1. That my client was invited by Ms. Neha Gupta (Employee ID: 20850) to
attend a 45-minute promotional seminar at Barbeque Nation, Model Town-III,
Delhi on April 25, 2024, along with his family.

2. That during the seminar, Mr. Sumit Dixit (Employee ID: 40169) and Mr.
Govind Verma (Employee ID: 27628) promoted a holiday package named
“Go Zest”, falsely representing that:

o That the membership was for three years, with no annual membership fee.

o That the total cost was ₹1,24,898/-, reduced from the original ₹1,58,872/- as a
one-time special offer.

o That the package included 7 nights of stay per year across Club Mahindra
resorts.

o That additional perks such as a ₹10,000/- Kalyan Jewellers voucher and other
incentives were assured.
 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

3. That my client was further misled by Mr. Prashant Joshi, who reaffirmed
these benefits and insisted that the offer was available only for that day,
coercing my client into an immediate purchase.

4. That my client made an upfront payment of ₹77,414/-, with the remaining

₹47,484/- to be paid in six interest-free EMIs of ₹7,914/- each, starting
December 2024.

FRAUDULENT TRANSACTIONS, CYBER CRIME & BREACH OF

TRUST

5. That subsequent to the payment, my client was asked to provide Aadhaar

details and bank account information under the false pretext of activating his
membership.

6. That on April 28, 2024, my client was fraudulently induced into sharing an
OTP, purportedly for verification purposes, which was later used for
unauthorized transactions.

7. That while my client availed of membership benefits until September 2024, he

later received unjustified demands for outstanding dues, which were
contrary to the agreed terms.

8. That on November 2024, an EMI deduction of ₹9,983/- was made instead of

₹7,914/-, indicating willful financial misrepresentation and cyber fraud.
 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

9. That despite multiple complaints, Mrs. Preeti Chaudhary provided false

assurances, yet in December 2024, an additional unauthorized deduction of
₹9,983/- was made.

10.That my client was subsequently threatened with membership cancellation

unless he paid an additional ₹5,000/-, a demand that was neither agreed upon
nor legally justified.

11.That upon verification, my client discovered that your internal records

fraudulently listed the package cost as ₹1,58,872/- instead of ₹1,24,898/-,
exposing a deliberate scheme of deceit and financial misrepresentation.

12.That despite a formal grievance email sent on February 17, 2025, your
representatives engaged in further coercion, compelling my client to attend a
meeting at your Jasola office on February 26, 2025, under the pretense of
dispute resolution.

13.That during the meeting with Mr. Vikram Kocher and Mrs. Preeti
Chaudhary, my client was once again subjected to false assurances, and no
concrete resolution was provided.

14.That on March 1, 2025, despite previous commitments, you failed to address

the grievances, underscoring your malafide intent, fraudulent business
practices, and utter disregard for consumer rights.

VIOLATIONS UNDER APPLICABLE LAWS

 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

That your actions constitute gross violations of the following legal provisions:

1. Criminal Breach of Trust – Section 316, Bharatiya Nyaya Sanhita

(BNS), 2023
2. Cheating & Fraud – Section 317, BNS, 2023
3. Cyber Fraud – Section 174, Bharatiya Sakshya Adhiniyam (BSA),
2023
4. Unfair Trade Practices – Section 2(47), Consumer Protection Act,
2019

DEMANDS

That in light of the above, I hereby call upon you to:

1. Immediately rectify all fraudulent transactions and provide written

confirmation of the original membership terms.

2. Refund the excess amount charged and ensure that my client's membership
terms remain as originally agreed.

3. Compensate my client with ₹5,00,000/- for financial loss, mental harassment,

and emotional distress.

4. Reimburse legal expenses of ₹50,000/- incurred for issuing this notice.

CONSEQUENCES OF NON-COMPLIANCE
 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

That if you fail to comply within 15 days from the receipt of this notice, my
client shall be constrained to:

 Initiate criminal proceedings under the IPC and IT Act for fraud, breach of
trust, and cybercrime.

 File a consumer complaint before the Consumer Disputes Redressal

Commission for deficiency in service.

 Institute civil proceedings for the recovery of financial losses, damages, and
compensation.

That this notice serves as a final opportunity for you to amicably resolve the
matter. That a copy of this notice is retained for legal proceedings, should you
fail to comply.

On Behalf of

Sh. Raghav Kapoor

LAWGORITHMZ

Pooja Sareen (Advocate)

(Advocates & Legal Consultants)

Contact: +91-9716299846

Office : 1403, Capital Residence-360

Sector 70-A, Gurugram, Haryana

 LAWGORITHMZ
(Advocates & Legal Consultants)
Contact: +91-9716299846
Office : 1403, Capital Residences- 360, Sector 70-A,
Gurgaon, Haryana
E-mail: [email protected]

E-mail: [email protected]