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Legal Notice For Defamation-Pramod

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BY E-MAIL/SPEED POST/COURIER

Ref No. Legal/ 160/ 2024 /April Dated- 22-April-2024

My Client:
Henry Harvin India Education LLP
C/o-Henry Harvin House, B-12, Sector 6, Noida,
Uttar Pradesh 201301
Phone No.-+91 9891953953

To,
Pramod Kumar Sahu
Email: pramodksahu@gmail.com
Phone: 939885XXXX

LEGAL NOTICE
Sir/Madam,

On behalf of my client “Henry Harvin India Education LLP”, C/o-Henry Harvin House,
B-12, Sector 6, Noida, Uttar Pradesh 201301. I would like to serve upon you the
following notice:
1. Henry Harvin India Education LLP (‘Henry Harvin’) is an education technology
company that primarily offers both online and offline certification / diploma /
degree programs to professional adults and students. Henry Harvin also offers
consulting services in line with Big 4 consulting firms and publishes books on a
variety of topics. The company works as a training partner and education
provider to a number of leading management / technology colleges, corporate,
and government entities. Up till 2022, Henry Harvin had acquired a customer
base of more than 300,000 participants spread across 97 countries. Its
operational offices are in San Francisco (USA) and Delhi NCR (India) for more
than 10 Years.

2. We operate through our website bearing the web address www.henryharvin.com.


The agreement has been set out on the website itself. Prior to the purchase of
any course, all the users are required to click on the “SIGNUP” option, agreeing
to the terms and conditions, obligations, representations, warranties and
agreements thereby. In the event where the user is unwilling to accept the
Agreement, they may choose to do so. However, in that case, the user shall not
be authorized or allowed to proceed further to view or use in any manner the
content, information, ecourseware, products and services published, available
or provided on the website owned by us at Henry Harvin. Effectively, by signing
up for the course, the parties naturally enter into a clickwrap agreement.

3. It is also pertinent to mention here that you addressee, had enrolled yourself in
the "Project Management Course” to my client. The very moment you enroll
yourself in the above said course you addressee, agree to all terms and
conditions that have been clearly mentioned in my client’s official website for
your convenience I’m mentioning below the refund policy:

“CANCELLATION AND REFUND: ONLINE TRAINING”


For Self-Paced Learning:

· Money back guarantee is void if the participant has logged into the course.
· Any refund request beyond 7 days of purchasing the course will not be
accepted and no refund will be provided.
· Refund on discounted or subsidized course fee is not applicable for refund.
The only option is to change the course.
For Instructor Led Training:

· Raise refund request within 7 days of purchase of course.


· Money back guarantee is void if the participant has logged into the e-learning
course or has attended Online Classrooms/received recordings for more than 1
day.
· Any refund request beyond 7 days of purchasing the course will not be
accepted and no refund will be provided.
· Refund on discounted or subsidized course fees is not applicable. The only
option is to change the course.
· Refund on the batch rescheduled by the participant is not applicable.”

4. You Addressee, knowing very well that your contention regarding the refund
doesn't fall under the refund policy have mischievously and falsely given
derogatory and defamatory reviews against my client on the google only to
harass and coerce my client in order to fulfill your unlawful demands.It is also
pertinent to say here that my client is in constant touch with you with regards to
the classes. In addition to it you addressee are also provided with the requisite
services from our end that were promised during the time of enrolment. Hence
from the above act of my client it is safe to say here that my client in no manner
has lacked in providing you with the necessary services.
5. That you addressee, even knowing that my client in no manner has lacked in
providing the services that was promised, purposefully in order to defame my
client in the eyes of the general public have written derogatory and defamatory
statements against my client.
6. That on bare perusal of the impugned google review which is been circulated in
the social media makes it abundantly clear that you addressee have purposefully
made the scandalous imputations against my client with culpable malicious
intention to defame my client’s reputation in the eyes of general public and
thereby have spread untrue, false and derogatory statements against my client
referring as a “Fraud” with its name and also abused my client through various
modes of communication. Being a genuine user of the said course, you
addressee, must be truthful, honest, correct and highly responsible for making
any statement against any person but you addressee with a view to tarnish the
hard earned reputation of my client purposefully and maliciously given a
defamatory google review against my client.

In the view of the above stated facts and circumstances, you addressee have
clearly committed the offense of defamation of which you are liable to be
tried by the competent court of law. Moreover, by intentionally harming and
destroying the reputation of my client, you addressee yourself is liable to
make good and compensate an amount of INR 32,00,000 for the damages to
my client’s reputation that it has already suffered and still continue to
suffer. Hence, you are hereby called upon to remove the impugned
defamatory review within a period of 7 Days of the receipt of this notice. If
you addressee oblige with the demands of this legal notice and remove the
said Google Review, you addressee may avoid the consequence of a
litigation which may be commenced in both civil and criminal courts of the
competent jurisdiction and in such an event, the entire legal proceedings
shall be entirely at your own risk.

That it is also notified to you, addressee, that if you fail to comply with the present
legal notice, our clients have given us definite instruction to take all necessary
legal actions for damages, injunction, initiation of all civil and criminal
proceedings including but not limited to registering of FIRs against you,
addressee with immediate effect.

Needless to state, any proceedings which may be initiated by our client against
the you addressee, shall be entirely at the risk and costs of you,
A copy of this letter has been retained at our office for necessary action.

Regards

Shravan M.

Lawyer

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