A Combined Notice under section 106 of the Indian Railways Act 1989 and under section 80 of the Code of Civil Procedure 1908

Regd. with AID
The General Manager,        Railway                                    Dated…….
(Address)
Dear Sir
Please take notice that my client (name, description) of……..(address) will institute a suit against the Union of India, owning and administering the aforesaid Railway in a court of competent jurisdiction after expiry of two months after service of this combined notice of claim under s. 106 of the Indian Railways Act and s. 80 of the Code of Civil Procedure for reliefs hereunder claimed unless they are all granted to my client by the said Railway within the said period of two months.
The relevant facts justifying my client's claim and constituting cause of action of the proposed suit and relief thereunder will appear herein below:
(a) On or about the…….day of……….my said client made over to the said Railway a consignment of………..bags each bag……….weighing……..kg……..of………for carriage for reward from…….a station on the said Railway to………..a station on the same Railway under P.W.B. No……… dated……… consignor being M/s….. and the consignee being self-endorsed to my client for valuable consideration. The said consignment has not reached as yet so far the said destination and so was not delivered to my client uptill now in spite of repeated demands.
(b) The loss and consequent non-delivery of the consignment is due to wilful act, default, misconduct, carelessness and gross negligence of the aforesaid Railway Administration, its agents and/or employees concerned. My client is at this stage unable to give full particulars of the same until after full disclosure of facts and evidences by the Railway as to how they have dealt with the consignment during the period the same was in possession and control of the Railway.
(c) My client hereby claims a sum of Rs………as damages suffered on account of the loss or non-delivery of the consignment and is entitled to recover the same as against the Railway.
The following are particulars of the claim:
(i) Loss for shortage of at
Rs                                                                           Rs	
(as per Bijuk/market rate)
(ii) For proportionate railway freight
(in case of partial delivery) paid                            Rs
(iii) Other costs (packing costs, etc.)                     Rs.
(iv) Costs of notices etc.                                        Rs.
                                                                Total      Rs.
The cause of action arose on the………..day of…….. on account of wrongful loss caused to my client because of the non-delivery of goods without any just or sufficient cause.
(d) The names, addresses and description of the plaintiff and the defendant, nature of cause of action and relief claimed as required to be stated in the notice under s. 80 of CPC are contained in the particulars hereinbefore given.
Yours faithfully