Pre-litigation · Common law of torts read with Limitation Act 1908
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LEGAL NOTICE FOR DAMAGES IN TORT
From: counsel_name Advocate counsel_address Contact: counsel_contact
To: recipient_name recipient_address
Date: notice_date
Subject: Notice for damages of Rs. damages_claimed on account of tort_type committed by you against my client client_name on tortious_act_date.
Sir,
Under instructions from and on behalf of my client, client_name, son of client_father, holder of CNIC No. client_cnic, resident of client_address, I have to address you as under:
1. That my client is a law-abiding citizen of repute and has not, by any conduct, given you any cause for grievance or for the act and conduct complained of herein.
2. That on tortious_act_date at approximately tortious_act_time, at tortious_act_place, you committed the following tortious act against my client: tortious_act_description. The said conduct, by its very nature, amounts to tort_type actionable at common law.
3. That as a direct consequence of your wrongful act, my client has suffered the following actual loss and harm: actual_harm_description. The financial loss occasioned to my client to date is detailed as follows: loss_breakdown.
4. That, in addition to the actual loss above, my client has been put to severe mental agony, embarrassment, and reputational injury, for which compensatory damages are claimed in the sum of Rs. general_damages, in line with the principles of common-law tort liability as adopted and applied by the superior courts of Pakistan.
5. That your conduct further calls for an unconditional public apology and a clear undertaking that no such conduct shall be repeated. The cause of action being recent, this notice is well within the period of limitation prescribed by the Limitation Act 1908.
Through this notice, you are hereby called upon to: (a) tender an unconditional written apology to my client; (b) pay actual damages of Rs. actual_damages; (c) pay general/compensatory damages of Rs. general_damages; (d) issue a written undertaking that the offending conduct shall not be repeated; and (e) bear the costs of this notice in the sum of Rs. notice_cost, all within compliance_period days from the receipt of this notice.
Take notice that, in the event of your failure to comply with the above demand within the stipulated period, my client shall be constrained to institute a civil suit for damages and a permanent injunction against you, before the competent court of law, entirely at your cost, risk, and consequences, besides resort to any criminal remedy available in law in respect of the conduct complained of. A copy of this notice is being retained for production before the appropriate forum in due course. All other rights and remedies of my client in law and equity are expressly reserved.
_____________________________ counsel_name Advocate For and on behalf of client_name
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