IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE O.S.NO: 32/2010 Plaintiff : Smt. K. Lakshmamma Smt.

J. Kala and another.

Defendants :

CHIEF-EXAMINATION AFFIDAVIT OF D.W.-1 FILED UNDER ORDER 18,RULE 4: C.P.C. I, J. Kala, W/o. J. Joseph, aged about 49 years, Christian, residing at Fleshing pet, Madanapalle, do hereby solemnly affirm and state as follows: 1. I am the 1st Defendant in the above suit and Deponent herein. 2. I submit that the Plaintiff has filed the above suit for recovery of the suit amount on the basis of suit pronote , with all false allegations and we have been contesting the matter by filing our detailed Written Statement with true and correct facts. 3. I submit that we have never borrowed even a single pie from the Plaintiff at any point of time and the Plaintiff seems to have forged and fabricated the suit pronote with false recitals to take vengeance against us in view of the enemity between us for the following reasons. 4. I humbly submit that I hail from a poor family and I am an illiterate and destitute lady as my husband also deserted me about 20 years back after begetting the 2nd Defendant, and since then, I have been depending on my relatives for educating my daughter and running the family by borrowing amounts from third parties. Thereafter, I sustained fracture to my back bone and completely became unable to do any work and still, I am suffering from the said fracture. I contracted debts from the son of the Plaintiff namely K. Chandra Sekhar, one Lalitha, V.Simon, M. Lakshmi Devi, B.Ramesh and Meenakshamma for the purpose of education of 2 nd Defendant during the period of 2000-2005 and the above said creditors including the son of the Plaintiff squeezed me by collecting higher rates of interest. Thereafter, due to my pathetic financial condition, I could not pay amounts to the son of the Plaintiff and others stated above and they started to pressurize me to discharge their debts by insulting me in the eye of Public and threatening me with dire consequences for which, I was constrained to lodge a complaint before the

Honble Sub-Collector: Madanapalle by explaining about my pathetic situation and the learned Sub-collector: Madanapalle also conducted enquiry with regard to the same and chastised the said creditors to behave on humanitarian grounds. Having been aggrieved by the lodging complaint by me, the Plaintiff and her son bore grudge against me and waiting for taking vengeance against me. Thereafter, I also discharged the said debt due to the son of the Plaintiff with the help of my relatives. But, the said K.Chandra Sekhar who was well acquainted with our signatures in view of earlier transaction, seems to have forged our signatures and created the suit pronote in the name of the Plaintiff with false recitals with active collusion of attestors and scribe. We never borrowed any amount from the Plaintiff and the very fact that the Plaintiff has not issued any legal notice to the Defendants prior to the filing of the suit itself speaks volumes of truth about the falsity of the case set up by the Plaintiff. Thus, the allegations mentioned in the plaint that the Plaintiff made several demands to us and we were postponing to discharge the same are all nothing but white lies invented for purpose of this case. Thus, we are not liable to pay any amount to the above said K.Chandra Sekhar to take revenge against the Defendants and as such, the suit is liable to be dismissed with costs. 5. It is therefore most humbly prayed that the Hon'ble court may be pleased to dismiss the suit with costs, in the interest of justice.

Deponent

Solemnly affirmed and signed before me on 31-07-2012 at Madanapalle

Advocate