Not giving me actual physical possession of apartment.

To
The Director / Manager, Customer Care
Shrachi Burdwan Developer Pvt. Ltd.
Sub- In connection of actual physical possession of the Apartment No: R-NK-Rh5-3A
Notice under section 80 Civil Procedure Code. It’s written below:-
1. That, my client Mrs. Kusum Rai, Resident of F/6, Sadhanpur Govt. Housing, Burdwan, PIN-713101, is your consumer and owner of apartment R-NK-Rh5-3A, Renaissance Township, Goda, Nawabhat more on NH2, Burdwan.
2. That, Shrachi Burdwan Developer Pvt. Ltd. had given possession letter for Rh5-3A apartment to my client on dated 11 July, 2012 and also started to take Maintenance Charges Rs 687/- per month from above said date for that possession.
3. That, my client had gone for taking actual physical possession of her apartment Rh5-3A with Executive Officer Sumit Bhagat sent by Manager Customer Care, Shrachi Burdwan Developer Pvt. Ltd., and found there that all walls of the apartment were damped as water was leaking from the roof, ceiling & joint wall of connected building and from Underground water supply pipe fitting, and slopes of the floors of all rooms are not correct for draining water. Seeing that, the Executive Officer of Customer Care, Sumit Bhagat, has suggested her to give a complaint letter with key-set of apartment for repairing, and he assured to inform her to take final possession after getting repaired. My client had given key-set of apartment with complaint letter (no: 24) on above said date i.e. 11 July, 2012.
4. That, my client has contacted many times by telephone and gone herself to the office after giving key-set and complaint letter to Sumit Bhagat. But her apartment neither maintained yet nor given actual physical possession till today.
5. That, my client have loan for her apartment (R-NH-Rh5-3A) from LICHFCL and she has to pay Rs 12160/- per month as EMI for Home Loan. Apart from this she has to give House Rent about Rs 6000/- for present residence at F/6, Sadhanpur govt housing, Burdwan. Not only this, she has to give Rs 687/- per month for CAM to Shrachi & extra Electricity Fix charges.
6. That, my client is giving above said amount from July, 2012 to till now. If you had given the actual physical possession of the apartment after repairing and maintaining in time, then she had not to bothersome physical, mental and financial losses and inconveniences.
7. That, it is proper to justify that your company would have to pay Rs 50,000/- per month as compensation to my client for her mental and physical harassment and financial loss from July, 2012 to till now and also till then you will be able to get repaired fully the apartment (Rh5-3A) and call her by letter to give actual physical possession to my client.
8. That, if you have not replied for above said notice by satisfying us within 60 days in relation of mentioned reasons and prevention of all facts of above notice, my client is free to do legal process.
Notice Provider on behalf of Kusum Rai

Keshava Kumar Rai (Advocate)
Dated: 13-08-2014 Regd. No: UP 3775/86
Address: F/6, Sadhanpur Govt Housing, Burdwan. PIN: 713101