INJURIES CAUSED BY NEGLIGENCE ON A RAILROAD
Table of Contents
A.B., the above named plaintiff, states as follows:–
1. On the …… day of …… 19….., the defendants were common carriers of passengers by railway between…… and ……
2. On that day the plaintiff was a passenger in one of the carriages of the defendants on the said railway.
3. While he was such passenger, at …. [or near the station of. or between the stations of and ..], a collision occurred on the said railway caused by the negligence and unskillfulness of the defendants servants, whereby the plaintiff was much injured [having his leg broken, his head cut, etc., and state the special damage, if any, as], and incurred expenses for medical attendance and is permanently disabled from carrying on his former business as [a salesman].
[As in paras 4 and 5 of Form No. 1, and relief claimed.]
[Or thus:–2. On that day the defendants by their servants so negligently and unskillfully drove and managed an engine and a train of carriages attached thereto upon and along the defendants’ railway which the plaintiff was then lawfully crossing, that the said engine and train were driven and struck against the plaintiff, whereby, etc., as in para 3.
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