NOTICE OF SUIT UNDER SECTION 80 OF THE CODE OF CIVIL PROCEDURE, 1908 AGAINST THE CENTRAL GOVERNMENT

[Advocate’s Letterhead]

[Name of Advocate]
Ch. No. …, Delhi High Court
New Delhi
Contact: [Phone Number]

Date: [Insert Date]

To,
The Secretary to the Government of India
Education Department
Central Secretariat
New Delhi

Subject: Notice under Section 80 of the Code of Civil Procedure, 1908

Dear Sir/Madam,

Under instructions from my client, [Client’s Full Name], an employee in Section [Section Details] of the Department of Education, Central Secretariat, New Delhi, I hereby serve you this notice under Section 80 of the Code of Civil Procedure, 1908. My client intends to initiate legal proceedings against the Union of India, represented by the Department of Education, Central Secretariat, New Delhi, upon the expiry of two months from the date of this notice, unless the reliefs sought hereunder are granted within this stipulated period.

Particulars of the Claim

1. Name and Description of the Plaintiff:
   [Full Name of Client], son/daughter of [Parent’s Name], by occupation [Designation/Position], residing at [Residential Address].

2. Cause of Action:
   a. My client, [Client’s Name], was an employee in [Section Name] of the Department of Education, Central Secretariat, New Delhi.
   b. My client was wrongfully dismissed from service with effect from [Date of Dismissal] based on false and baseless allegations.
   c. It was alleged that my client was involved in a theft incident dated [Date of Incident], which led to the issuance of a charge sheet on [Date of Charge Sheet].
   d. Despite furnishing appropriate explanations and evidence refuting the allegations, my client was dismissed from service arbitrarily and without following due process of law.
   e. The cause of action for the intended suit arose on [Date of Cause of Action], being the date of dismissal, and continues to persist as my client remains deprived of lawful employment and salary.

3. Reliefs Claimed:
   a. Reinstatement of my client, [Client’s Name], to his/her previous position in the Department of Education, Central Secretariat, New Delhi.
   b. Payment of arrears of salary, including all applicable allowances and benefits, for the period from [Date] to [Date].
   c. Compensation for the mental agony, financial loss, and hardship suffered due to the illegal dismissal, amounting to ₹[Amount Claimed].

Conclusion

In light of the above, I request you to address the grievances of my client and provide the reliefs sought herein within two months from the date of receipt of this notice. Failing compliance, my client shall be constrained to file a suit in the competent court of law against the Union of India and other appropriate parties, holding them accountable for the wrongful actions and claiming the reliefs mentioned above.

This notice is being issued without prejudice to any other legal rights and remedies available to my client under applicable law.

Yours faithfully,

[Advocate’s Full Name]
[Signature]
Advocate for the Plaintiff
Ch. No. …, Delhi High Court
New Delhi
Contact: [Phone Number]

Enclosures (if any):

1. Copy of dismissal order
2. Copy of charge sheet
3. Any supporting documents