IN THE HIGH COURT OF MALAYA AT IPOH

IN THE STATE OF PERAK DARUL RIDZUAN

CIVIL SUIT NO : 2-22-06-2016

BETWEEN

ALFRED LIM KUAN THONG

(NRIC : 960222-08-6785) …PLAINTIFF

AND

AMAR SINGH DHILLON

(NRIC : 720414-08-5643) …DEFENDANT
 STATEMENT OF CLAIM

1. The Plaintiff, Alfred Lim Kuan Thong, is a first-year student at University

Teknologi Petronas (UTP) situated in Ipoh, Perak having an address for

service at No 12A, Taman Silibin, 30100 Ipoh, Perak.

2. The Defendant, Amar Singh Dhillon, is a senior associate in an accounting

firm situated in Ipoh, Perak having an address for service at No 54, Taman

Ipoh Permai, 31400 Ipoh, Perak.

3. On 13th May 2016 at about 4.30 p.m. the Plaintiff was driving a white Proton

Myvi bearing the registration number of AJN 7077. The Plaintiff was driving

home after class from University Teknologi Petronas (UTP) campus.

4. While driving along a straight road, the Plaintiff’s car collided into a black

Toyota Hiace van (“the said van”) driven by the Defendant bearing the

registration number of MAD 9999.

5. The said van was emerging out of a side road on the left side at a fast speed.

6. The accident was caused by the negligence of the Defendant.

 PARTICULARS OF NEGLIGENCE

The Defendant was negligent in that he:

a) Did not look to the right before proceeding out of the side road.

b) Due to failing in noticing the presence of the Plaintiff’s car, there was

a collision between both of those mentioned vehicles.

c) Failed to supply signals that are supposed to provide caution to the

Plaintiff.

d) Failed to consider or take into consideration the safety of other road

users, especially the Plaintiff.

e) Failure to give proper warning to Plaintiff, at the time of the accident.

f) Failed to stop or swerve to avoid the accident.

g) Failure to timely avoid the accident or at all to avoid the accident.

h) Failed to hit the brakes, slow down, stop the vehicle or by any other

means to avoid the accident.

i) Failure to pay sufficient attention and use efficiency in this situation to

prevent the accident from happening.

j) Failed to investigate clearly the position of the Plaintiff.

7. As a result of the accident, the Plaintiff suffered injuries and losses.

 PARTICULARS OF INJURY

The plaintiff has suffered injuries as follows:

a) Fractured legs.

b) Fractured left hand.

c) Fractured rib.

d) Cuts and bruises all over the face and body.

e) Temporary loss of walking ability.

8. The details regarding the plaintiff's injuries are as specified in the Medical

Report. The plaintiff will rely on these reports on the date of the trial.

PARTICULARS OF SPECIAL DAMAGE

A. PLAINTIFF RM

i. Medical Report 120

ii. Nutritious Food 500

iii. Hospital Medical Expenses

- Medical Registration Fee 30

- Third Class Ward Charges 9

- Radiology Examination 720

- Hospital Bill 42

- Ambulance Charges 200

 iv. Traveling Expenses to and from the Hospital 1000

v. Medication Bill 1800

vi. Walking Aids

- Wheel Chair 340

- Crutches 150

vii. Totaled Vehicle (Proton Myvi, AJN 7077) 35000

viii. Car Towing Charges 500

ix. Loss of Books 500

x. Loss of Mac Notebook 6000

xi. Loss of Tag Heuer Watch 13000

__________

TOTAL ____59911_

Therefore, the Plaintiff claims from this Honourable Court are as follows:

a) Special Damages;

b) General Damages;

c) Costs;

d) Interest on general damages at the rate of 8% per annum from the date of the

accident until the date of judgment;

e) Interest on special damages at the rate of 4% per annum from the date of the

accident until the date of judgment.

f) Interest on the judgment sum at the rate of 8% per annum from the date of

judgment until the date of settlement and;

g) Such further or other relief as this Honourable Court deems fit.

Dated 27th April 2017

______________________
(Solicitors for the Plaintiff)

THIS STATEMENT OF CLAIM is filed by Messrs Sandhu & Co,

Solicitors for the Plaintiff above named and have an address of service at No
14, Persiaran Greentown 7, Pusat Perdagangan Greentown, 30450 Ipoh, Perak
Darul Ridzuan. Tel No: 05-2410 777. Fax No: 05-2410 707. Email:
sandhu&co@hotmail.com.