Вы находитесь на странице: 1из 3

From the Office of:-

LEGAL NOTICE

Sri. B.NARAYANA SWAMY,


Advocate,
D.No.27/975,
Ambedkar Nagar,
Anantapuramu.
R.P.A.D/through courier

Date: 19-09-2016.

To
1. The Superintendent Engineer,
A.P.S.P.D.C.L.,
Near J.N.TU. Engineering College Road,
Anantapuramu.
Anantapuramu District.
2. The Assistant Engineer,
A.P.S.P.D.C.L.,
Thanakallu Mandal,
Anantapuramu District.
Sirs,
Under instructions from my clients,
1.Duginepalli Maruthi Kumari, W/o. Late Anjinappa @ Anji, Aged 22 Years,
Hindu, Female, Sinecure,
2. D.Venella, D/o. Late Anjinappa @ Anji, Minor, Aged 06 Years, Hindu, Female,
Rep. by mother and natural guardian,
3. D.Sandhya Rani, D/o. Late Anjinappa @ Anji, Minor, Aged 03 Years, Hindu,
Female, Rep. by mother and natural guardian,
4. D.Narayanamma, W/o. D.Kadirappa, Aged 52 Years, Hindu, Female,
Sinecure,
5. D.Kadirappa, S/o. Late Thirupal, Aged 58 Years, Hindu, Male,

All are residents of Gollavaripalli Village, Thanakal Mandal, Anantapuramu


District, I am issuing the following notice to you:-

1. My client No.1 is the wife of deceased D.Anjinappa @ Anji. My clients


No.2 and 3 are the daughters of the deceased D.Anjinappa @ Anji,
minors represented by No.1 of my client as she is the mother and natural

guardian of the children. My clients No. 4 and 5 are parents of deceased


D.Anjinappa @ Anji.
2. My clients state that the deceased D.Anjinappa @ Anji, was aged 26
years, hale and healthy and was only bread winner of his family and was
earning Rs.15,000/- per month by assisting the linemen belonging to
department of No.1 and 2 of you.
3. My clients state that the circumstances that led to electric shock and
death of deceased D.Anjinappa @ Anji are that on 21-01-2016, at about
08:00 A.M., Mr. Nagaraju, lineman of Vankapalli Village belongs to the
department of No.1 and 2 of you, sought the help of deceased
D.Anjinappa @ Anji, S/o. D.Kadirappa, Resident of Gollavaripalli Village,
Tanakal Mandal, stating that in the village of Peddakadapalavandlapalli,
and in the field of one Madhava Reddy, electric pole is having some
problem and took the deceased D.Anjinappa @ Anji for rectifying the
same. My clients state that my clients were informed by one D.Lakshmi
Narayana that the deceased, died due to electric shock when the
deceased climbed the electric pole as per the instructions of electricity
staff of No.1 and 2 of you.
4.

My clients state that my clients immediately went to the scene and


noticed that the deceased D.Anjinappa @ Anji died due to electric shock
and sustained burnt injuries on his right shoulder and right buttock. My
clients state that my client No.1 lodged complaint before Tanakal P.S. and
the same is registered as Cr. No.07/2016 U/Sec. 304-A against lineman
belongs to the department of No.1 and 2 of you. My clients state that the
Inquest and Post Mortem was held over the body of the deceased
D.Anjinappa @ Anji.

5. My clients state that my clients enquiry revealed that the concerned


lineman took L.C. form Sub-Station to stop electricity. After that the
deceased

D.Anjinappa

Anji

climbed

electric

pole

as

per

the

instructions of the lineman belongs to the department of No.1 and 2 of


you and sat on the electric pole, engaged in the repair work. At that time,
suddenly the department staff belongs to No.1 and 2 of you turned on
the L.C. thereby electricity passed over the electric pole on which the
deceased D.Anjinappa @ Anji was working. Due to turning on L.C., the
deceased D.Anjinappa @ Anji sustained electric shock and fell down
immediately and died. This is due to negligent attitude of department
staff belongs to No.1 and 2 of you.
6. My clients state that No.1 to 2 of you are jointly and severally liable for
the death of my clients family head i.e., Late D.Anjinappa @ Anji who
died due to the electrocution which was due to the negligence and
carelessness of your department people.

7. My clients state that due to sudden demise of the Late D.Anjinappa @


Anji my clients have been thrown to street and their position is miserable
and pitiable with the loss of the active earning member of the family.
8. Therefore you are hereby called upon to pay a compensation of Rs.
15,50,000/- (Rupees Fifteen Lakhs Fifty Thousands Only) to my clients
immediately after the receipt of this notice as the death of Late
D.Anjinappa @ Anji was due to the negligence and carelessness of your
department people. If you fail to comply with the demand of this notice
within 15 days of receipt of this notice, my clients will be constrained to
approach a Court of Law for compensation and you will be mulcted with
all the costs and consequences thereon including the costs of this notice
of Rs. 2,000/-.
Advocate,
Anantapuramu.