All sample legal documents

Sample Personal Injury Pre-Action Letter

A worked England and Wales public-liability pre-action letter recording a supermarket fall, injury evidence, special damages, disclosure requests and the proposed next steps.

Jurisdiction: Illustrative England and Wales personal-injury pre-action correspondence — the applicable protocol, limitation period, evidence and costs position must be checked

Download Sample

An editable Microsoft Word version is available from the interactive page.

Important: This sample provides general legal information only and is not legal advice. Check the law, prescribed forms and signing requirements that apply to your exact jurisdiction and circumstances before use.

PERSONAL INJURY PRE-ACTION LETTER

Important legal-advice, jurisdiction and formality warning

This fictional letter is a worked educational example, not legal advice, a medical report, an admission of liability or a universally valid Letter of Claim. It is written on the assumption that an accident occurred in England and Wales and that the Pre-Action Protocol for Personal Injury Claims or the relevant low-value public-liability process may apply. The correct protocol, defendant, limitation date, evidence, valuation, costs rules and court procedure depend on the facts. A claimant should obtain independent legal advice before sending this letter, accepting an offer, signing a statement of truth or allowing a limitation period to expire. The figures below are fictional and must not be copied as a valuation.

Date: 18 October 2026

To: The Claims Department, Fenwick Grocers Limited, 41 Station Parade, Reading RG1 1LQ

For the attention of: Claims Manager, Fenwick Grocers Limited, company number 08743126

By email: claims@fenwickgrocers.example.test

From: Naomi Elise Carter, 27 Larchfield Crescent, Reading RG2 9HN Telephone: 0118 555 4027 Email: naomi.carter@example.test

Proposed defendant: Fenwick Grocers Limited Accident location: Fenwick Grocers, 41 Station Parade, Reading RG1 1LQ Date and approximate time: 12 April 2026 at 16:35 Subject: Fall near the chilled-food aisle — personal injury claim

1. Purpose of this letter and parties

I write to notify Fenwick Grocers Limited of my claim arising from a fall inside its Reading store on 12 April 2026. I was a lawful customer buying food for my household. The store was operated by Fenwick Grocers Limited, and I understand that it controlled the premises, staff and inspection arrangements. If another company was responsible for cleaning, maintenance or the relevant area, please identify it and provide its insurer’s details; I reserve the right to add or substitute a proper defendant after receiving that information.

The accident happened beside the refrigerated dairy cabinets, approximately six metres beyond checkout 4 and opposite the end of aisle 7. I was walking at ordinary speed in flat shoes when my left foot slid on a clear, greasy liquid. I fell backwards and to my right, striking my right wrist, right hip and the back of my head on the tiled floor. I did not run, use a mobile telephone or carry an unstable load. A shopping basket containing a loaf of bread, milk and a packet of rice fell beside me.

2. Circumstances and alleged liability

Immediately after the fall I saw a clear puddle approximately 1.1 metres long and 0.6 metres wide. There was no cone, barrier or warning sign. The liquid had a sheen and a strong dairy smell. Customer Peter Malcolm Ives, of 8 Eldon Road, Reading RG1 6QE, helped me sit up and told a nearby employee that he had seen the wet area before I fell. Employee Marta Louise Green, whose name was printed on her badge, attended with a yellow cleaning trolley. She wrote an incident entry and placed two warning cones around the area at approximately 16:42.

I allege that Fenwick Grocers Limited was negligent and in breach of its duty as occupier. In particular, the store failed to maintain a reasonably safe customer route, failed to discover and remove or isolate the spill within a reasonable time, failed to display an adequate warning, and failed to keep a sufficient inspection and cleaning system. I do not know how long the liquid had been present or its source. I therefore request the inspection records, cleaning logs, staff rota, incident report, CCTV and stock or refrigeration records identified below. This account is based on my own observation and the contemporaneous records available to me; I invite correction of any objectively inaccurate detail.

Please preserve all CCTV and digital material for the accident area from 15:45 to 17:15 on 12 April 2026, including footage from the dairy aisle, checkout 4, entrances and staff route. Please also preserve the incident report, photographs, cleaning and inspection records, relevant training records, staff statements, maintenance reports for the dairy cabinets and any complaint or prior-incident records concerning that area. This request is made to preserve evidence, not to require disclosure of irrelevant personal data.

3. Injury, treatment and current position

An ambulance was not required. I attended Royal Berkshire Hospital urgent treatment centre at 19:10 on 12 April 2026. A radiograph confirmed a non-displaced fracture of the right distal radius, and the clinician fitted a removable wrist splint. I was advised not to lift with the right hand and to arrange follow-up. The fracture clinic at Royal Berkshire Hospital reviewed me on 28 April 2026 and 26 May 2026. The splint was discontinued on 26 May, and I began hand therapy with Priya Nanduri MCSP at Thames Hand Therapy, 3 Reading Road, Reading RG1 5BT, on 2 June 2026.

The consultant’s report of 9 September 2026 by Dr Malcolm R. Keating, consultant orthopaedic surgeon at Wessex Independent Medical Reports, records a fracture that united without surgery. I continue to experience aching after typing for more than 45 minutes, reduced grip and difficulty opening tight jars. Dr Keating considers that further improvement is likely over six to nine months, but he recommends a review in March 2027 if symptoms persist. I have no previous right-wrist injury and disclosed my relevant medical history to him. The medical report, treatment records and photographs are available subject to appropriate confidentiality arrangements.

I am employed as a payroll administrator by Alderbrook Engineering Services Limited. I could not work from 13 April to 1 May 2026 and returned on reduced keyboard duties from 4 May to 15 May. My employer paid statutory sick pay of £116.75 for the first week and ordinary salary for the reduced-duties period, but deducted £684.20 from my normal net earnings over the three-week absence. I have retained the payslips and an employer confirmation dated 18 May 2026. I required help from my sister, Rachel Ann Carter, with cooking, fastening clothing and cleaning for 14 days, averaging 45 minutes per day. She kept a dated diary and does not seek payment herself.

4. Schedule of financial loss to date

The present special-damages calculation is:

* net loss of earnings: £684.20; * taxi fares to the urgent treatment centre and two fracture-clinic appointments: £74.80; * prescribed pain relief and wrist supports not supplied by the NHS: £38.45; * physiotherapy co-payment for six sessions at £42.00 each: £252.00; * replacement of a broken prescription spectacle frame damaged in the fall: £168.00; * assistance with domestic tasks, calculated conservatively at 10.5 hours at £13.50 per hour: £141.75.

The total of these identified items is £1,359.20. I have not included a speculative future loss, the value of unpaid family assistance beyond the period recorded, or a claim for the cost of a further medical review. I will update the schedule if a reasonable additional loss is incurred and supported by evidence. The receipts, payslips, travel records, therapy invoices and spectacle invoice are numbered NC-01 to NC-08.

General damages for pain, suffering and loss of amenity cannot responsibly be valued finally before the medical prognosis is complete. I invite Fenwick Grocers Limited to obtain its own medical evidence or agree a joint expert process. My present position is that settlement should include the special damages of £1,359.20 and an appropriate sum for the wrist fracture, symptoms and treatment, together with any recoverable interest and costs. This is not a Part 36 offer and is not intended to have the formal consequences of one.

5. Response and information requested

Please acknowledge this letter within 21 days and provide the name and address of the public-liability insurer, policy number if disclosure is appropriate, and the claims reference. Please give a reasoned admission or denial of liability within the period required by the applicable protocol, explaining any factual or legal basis for a denial. Please also confirm the intended timetable for exchanging statements, medical evidence and the schedule of loss.

If liability is disputed, please identify whether you allege that the liquid was absent, that an adequate inspection system operated, that a warning was present, that I caused or materially contributed to the fall, or that another person is responsible. I will consider a proportionate meeting or telephone discussion after the documents are exchanged. If no satisfactory response is received, I may commence proceedings in the County Court after taking advice and observing the applicable pre-action requirements. I will not issue a claim without considering whether further information or an alternative dispute-resolution step is proportionate, except where necessary to protect my position.

My current address and contact details are above. Please communicate in writing and do not contact my employer or sister without my consent. Nothing in this letter is an admission, waiver or acceptance of any limitation, valuation or causation argument. I reserve all rights, including the right to amend the claim when further medical evidence or disclosure is available.

Yours faithfully,

Naomi Elise Carter

Signed electronically by Naomi Elise Carter on 18 October 2026

Create a version for your situation

Create a tailored Personal Injury Pre-Action Letter