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1. Mr.

Tahir, Booking & Information Manager,


2. Mr. Banaras Khan, Security Guard
DAEWOO Bus Service Khanewal Road, Multan.

Subject: - LEGAL NOTICE.

Sir,
I have been instructed by my client Sh. Muhammad
Faheem Advocate High Court, 28-District Courts, Multan, to serve
this notice upon both of you for the reasons and inter-alia on the
following: -
GROUNDS
1. That my client intended to travel through, Bus No. LXK 5297,
scheduled that 8:30 a.m. on 20.9.2002 by ticket No. 376089
and seat No. 12 from Multan to Lahore.
2. That the ticket was purchased by the Rana Shahid Manzoor
Advocate and Mr. Hammad Afzal Bajwa Advocate High
Court, the associate of my client; and both were present at
Terminal with the ticket. My client is a resident of Bosan Road
and due to heavy rush of students of that road, he reached at
the terminal a few minutes before the departure of bus. It was
just 2 or 3 minutes before the departure of the bus, my client
along-with both the associates reached on the bus, Mr. Tahir
was present there. He was duly informed about the arrival, but
on the pretext that the bus is cleared now and cautioned the
driver to move. During the exchange of arguments against the
point of exit, the driver and hosts tried to stop the bus, but Mr.
Tahir again waved his hand as a sign of “GO”.
3. That the matter was still under the arguments when Mr.
Banaras Khan interrupted in the matter vigorously and caught
hold of my client from the right upper arm and by way of
pushing him Mr. Banaras ordered that no more talks with Mr.
Tahir ( ). On the protest of my client and his
associates Mr. Tahir and Mr. Banaras Khan tried to make it a
matter of quarrel, but calling the other Security Guards and
other, but my client and his associates avoided this situation
and escaped their person and honour from the high-
handedness of you and your staff members.
4. That many passengers and a near about all the staff was
gathered at the spot. This situation caused an agony, disgraced
and mental torture for my client and his associates. It is
pertinent to point out that the travelling is not a matter for
anybody, but the choice to travel by your company is due to
your mannered and etiquetted staff, more facilities and proper
accommodation, compensation and vigilance towards your
passengers.
5. That my client and his associates are attached with a noble
profession and enjoying a good reputation in the society and
known as a man of principles besides the profession my client
has his own status being a writer and columnist not only the
people gathered at the spot due to the news published in the
different newspapers. This matter brought a lot of mental
torture to my client.
6. That then and there my client filed a complaint against you on
the said moment but neither you nor your company tried to
reconcile my client and forced him to go to the court of law
for the redressal of his grievance. My client claims the cost as
under: -
i) Mental torture: Rs. 50,00,000/- (five million).
ii) Defamation: Two hundred million
iii) Loss caused due to non-travelling: One million
7. You are hereby directed in your own interest that within two
weeks after the receipt of this notice, you shall pay an amount
of Rs. 2,60,00,000/- to my client along-with a written apology
failing which my client reserves right to file civil/criminal
proceedings against you and you shall be responsible for each
and every expense incurred in the litigation.

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