PANDEY BIPUL KUMAR Chamber No—129

Advocate Bihar Bar Council Bhawan. PATNA

PATNA HIGH COURT Mobile—7004542925

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Dated: 21—9—2023

To

Jantantra Jyoti
Shivshakti Nagar
MUZAFFARPUR
8092151554
Email—jantantrajyoti@gmai.com

LEGAL NOTICE

Dear Sir,
Pursuant to the instructions and with the consent of Director,
Phular Superspeciality Hospital, Juran Chapra, Muzaffarpur (BIHAR)
(hereinafter referred to as “My Client”) I do hereby address this letter
to you as under—
1. That Phular Superspeciality Hospital, Juran Chapra,
Muzaffarpur is a Multispeciality Hospital in Muzaffarpur (hereinafter
referred to as the Hospital).
 2. That the abovenamed Hospital is a renowned and reputed
name in the field not only in Muzaffarpur but in the entire North
Bihar.
3. That you the Noticee operate in Electronic and Print Media.

4. That on 16-9-2023 at 02-48 A.M. one Lalita Devi wife of

Sukesh Sah, resident of Village Chainpura, P.S.—Goraul , District—
Vaishali (hereinafter referred to as the patient) came to the Hospital
in a critical condition.
5. That the Doctor on duty examined the patient and as her
condition was very critical she was admitted in the hospital. Later on
the patient was examined by renowned surgeon Dr Smit Shahi and her
attending relatives and husband were clearly informed about her
serious condition. The patient's husband and other relatives insisted
and consented for surgical operation of the patient. The hospital has
got proper video-recording of the informed consent and after the
written consent of the patient's husband she was operated upon by Dr.
Smit Shahi on 16-9-2023 itself.
6. That unfortunately the patient could not recover and died in the
evening of 17-9-2023. The treating doctors tried their best to save the
patient's life but the destiny prevailed and the patient died.
7. That you the Noticee published defamatory video pertaining to
the Hospital on 17-9-2023 and video-recorded some people present
in the hospital and Later on you the Noticees posted the videos on
YouTube and on the other platforms which went viral. In the said
videos some unscrupulous persons at the instance of you the Noticees
leveled baseless charges on the hospital and its staff.
8. That it is pertinent to mention here that you the Noticees did not
care to contact the management or the doctors present in the hospital
at that very time.
9. That you the Noticees have put the abovementioned videos on
media platforms and have tried to tarnish and malign the reputation of
the hospital which is illegal and without authority. There is no one
iota of truth in the abovementioned videos and the hospital and the
management denies it.
10. That the abovementioned videos are defamatory against my
client and my client can sue you for your ill intention and also for
spreading rumors by leveling baseless charges against him. That my
client claims that you the Noticees have tried to create pressure upon
my client and the hospital through the abovementioned videos and
tried to rupture its business and goodwill in order to extract money
from my client.

Thus, through this letter you the Noticees are requested

hereby and given an opportunity to tender unconditional apology to
my client within 15 days from receiving this notice and publish news
through your channels that the defamatory videos which went viral
against my client were found to be fake and contrary to the truth. And
in the event of failure to comply with this notice My Client has asked
me to file civil as well as criminal cases against you in the competent
Court of Law and in that event you will be fully responsible for the
same.
A copy of this notice is being preserved in my office for record
and future course of action.

Thanking You.
PANDEY BIPUL KUMAR
ADVOCATE