By Registered A.D.
……………………………..
Advocate
……………………………..
……………… …………….
Date ……………………….
TO,
The Secretary to the Govt. of ……………………
………………….. Deptt.,
…………………..
Dear Sir,
Re: Notice under section 80, Code of Civil Procedure
Under instructions from my client Shri ………………….. resident of …………………… I
hereby give you notice that my client Shri ………………….. shall file a civil suit
against the Government in the court of competent jurisdiction after the expiry of
two months from the date of service of this notice for the cause of action and reliefs
mentioned in the draft plaint enclosed herewith, which may be treated as part of
this notice.
Yours faithfully,
………………….
Advocate
Enclosure: Plaint
Date ……………………….
TO,
Shri ……………………
Medical Superintendent,
………………….. Hospital,
…………………..
Re: Notice under section 80, Code of Civil Procedure
Dear Sir,
Under instructions and on behalf of my client Shri ……………. resident of
………………….. I hereby give you notice as follows:
1. On or about ………………….. you were the Medical Superintendent of
………………….. Hospital . ………………….. and you were also the Head of the Deptt.
of Surgery of the said hospital.
2. Shri ……………. was admitted to the said ………………. Hospital on …………….. for
surgical operation for removal of stones in the kidneys under your care and
supervision and ……………. was fixed the date of operation of the said Shri
………………
3. When the said Shri ……………. was being operated, you were personally present
in the operation theatre and doing the operation with the assistance of junior
doctors.
4. After removing the stones, you, while undertaking stitching, had negligently,
carelessly and willfully left a big piece of cotton inside the body, due to which my
client started to complain severe pain in the kidneys for which you had prescribed
some antibiotics on various visits.
5. When my client could not get treatment for his pain, he went to …………………..
and consulted Dr. ……………… of ………….. Nursing Home ……………… who opined
that there is some foreign element around the kidney, for which my client was
operated on ……………… in ………………. Nursing Home and a piece of cotton was
removed from inside the body and after the removal of the cotton, my client had got
relief from pain.
6. My client Shri ………………….. had to undergo physical and mental suffering for
the negligence, carelessness and mistake committed by you and he had to spend lot
of money for treatment of pain, which was caused due to leaving the piece of cotton
inside the body by you, while undertaking operation for removal of stones in the
kidney.
7. The said ……………. therefore demands from you Rs. ………….. as damages for
physical and mental suffering, Rs. ………………….. as expenses incurred by him in
the operation and treatment, Rs. ………………. as expenses incurred by him in
transport, hotel, etc. totaling Rs. ……….. and I hereby give you notice that if the
said amount is not paid, the said ………………….. will, on the expiry of two months
from the date of service of this notice, file a suit against you for the recovery of Rs.
…………… as damages and expenses incurred by him, at your entire risk as to cost
and consequences.
Yours faithfully,
…………………..
Advocate
