To,

1. The Managing Director,

HOSPITAL NAME

Subject: Legal Notice

Under the instructions and on behalf of my client, R/o, I hereby serve upon you
this legal notice :-

1. That my client is law abiding citizen of India who enjoys good reputation
and holds good will in the society. Additionally, my client is a true covid
warrior who has demonstrated unwavering courage and resilience through
the Covid-19 Pandemic. My client is a Doctor by profession with over
***** years of standing in the field.

2. That you, the Noticee number 1, are the parent organisation for Clear
Medi Hospitals & Cancer Care Centre i.e. Noticee number 2, and have
your registered address and business at

3. My client was employed by as…..at ……

4. That Noticee No.2 had placed an Employment Contract in the hands of

my Client on …..appointing my client as ….
5. That as per the terms and conditions of the employment contract dated
…. the total cost to company (CTC) was agreed upon at 6 Lac annually
for working hours of 11 hours per week, for a total period of11 months
commencing from …till ….

6. That despite the issues caused due to delay in disbursal of salary, my

client has not received her salary as of today for the months of, and
August of the year 2022. Moreover so, whenever my client would try to
approach her superiors about the same, she was met with perplexing
responses from your end.

7. That my client has raised several concerns regarding the non- payment of
her salary to Noticee No.2 through various modes including written and
oral communication with the management of the Noticee No. 2.

8. That due to the constant hardship caused to her, my client was forced by
circumstances to tender her notice of resignation on .. and as per the
policy set out in the employment contract, she left her position on …

9. That on ….., my client wrote to …….. in the Human Resources

Department of Noticee number 2 inquiring about her arrears of 5 months,
however, there was no response.

10. That it is clear you have been using dilatory tactics in order to avoid the
payment of arrears for ….. to my client. That accordingly, you are in
breach of the Employment contract dated ….

11. That despite the fact when there was an ongoing pandemic, my client was
taking care of her patients with the utmost commitment at your
establishment, she was compelled to run to pillar and post within the
management for her arrears. This not only caused financial hardships to
my client, but also led to severe mental agony.
 12. That Noticees are liable under inter alia Sections 405 and 415 of the
Indian Penal Code, 1860; for unfair trade deficiency of services under the
Consumer Protection Act, 2019; and for breach of contract and
accordingly, liable to pay compensation for loss and damage caused as per
the Indian Contract Act, 1872.

13. That the Noticees are not just liable to pay the outstanding arrears my
client has for services rendered to Noticee number 2. Moreover so, the
Noticees must also reimburse my client for the damages caused from the
lack of payment of arrears for … months.

14. That the Noticees have an outstanding Amount of …… as arrears to our

Client for services rendered to Noticee No.2 for the period of….

15. That in view of the above circumstances, you are hereby called upon you
to pay our client …….as arrears,…… as compensation for damage caused
by the breach of contract, and INR ….as compensation for mental
harassment and agony.

16. That you are hereby called to pay total sum of INR ….. as compensation
to my client within 15 days from the receipt of notice.

17. That in the event of failure to comply with this notice, you shall render
yourselves jointly and severally liable to face appropriate civil as well as
criminal proceedings under the relevant provisions of law.

Please note that the present notice is limited to the issues herein and the contents
hereof are illustrative rather than exhaustive of any points available to our client
in relation to the above matter, either at law or in equity. All of our client rights
are expressly reserved in this regard
***

ADVOCATE