Mr. Z


Dear Sir


We act for Company 1. Our client has instructed us to serve notice upon you as follows:

01.              That you published a news item in the front page of your newspaper namely “The Independent” on July 24, 2000 under the caption “NO RELIEF IN SIGHT FOR DYING BURIGANGA – AUTHORITIES WARY OF TREADING ON ENCROACHERS’ TOES” along with a picture of the River Buriganga and its bank and two buildings with a footnote “RIVER DEVOUR: SIKDER MEDICAL COLLEGE HAS BEEN BUILT ENCROACHING ON THE BURIGANGA RIVER”.

02.              That the news item along with the picture of the buildings gives impression that our client has built the Medical College encroaching on the river Buriganga. The picture published in your newspaper is absolutely misleading and the aforesaid news item is false, incorrect and gives a wrong impression about our client. The factual position as evident from the official Mouza Map annexed with this notice is that the Company 1campus is situated about one Kilometre to the East of the river Buriganga in the Mouza Buraikhali. In between the Medical College campus and the river Buriganga there is another Mouza namely Srikhanda. As such the question of devouring the river by Company 1 and encroaching the river by the said medical college is completely false and misleading and has been published with an intention to harm the reputation and goodwill of our client.

03.              That the building shown in the photograph does not belong to the Medical College and Hospital and is located over about three-quarter of a mile from the Medical College and Hospital. Such misleading and malafide publication of photograph in a leading newspaper like “The Independent” without verifying the fact has damaged the reputation and goodwill and has demeaned our client in the eye of the general public, in particular the readers of your much circulated daily.

In the premises stated above, you are requested to publish an apology in a conspicuous space on the front page of your newspaper giving the actual location of the medical college in the area, withdrawing the allegation and correcting the record within 24 hours of receipt of this notice. Should you fail to comply with our requests within the stipulated period, we have instructions from our client for taking appropriate legal action (both civil and criminal) against you in the appropriate court of law for redressing the loss of reputation and goodwill of our client.

A copy of this notice is kept in our office for future reference.

Yours faithfully


For: “The Lawyers & Jurists”