IN THE COURT OF THE IVth ADDL.

DISTRICT JUDGE,
MARKAPUR
M.V.O.P.NO.225/2013
Gallepogu Siromani and others

..Petitioners
Vs
A.Srinu and others
..Respondents

CHIEF AFFIDAVIT FILED ON BEHALF OF THE

PETITIONERS (PW-1) U/Or 18 R 4 & Sec.139 C.P.C
I, Gallepogu Siromani W/o.late Salmon Raju, aged 26
years, Hindu, resident of D.No.3-49, S.C. Colony, Thurupu
Veerayapalem Village, Darsi Mandal, Prakasam District, do
hereby solemnly affirm and sincerely state as follows:I am the deponent herein and 1st petitioner in the above O.P. The
petitioners 2 to 5 are my children and they are being minors rep.by me as
natural guardian. Petitioners 6 & 7 are the parents of the deceased. I am
giving this affidavit on behalf of other petitioners also. The above O.P is filed
for compensation for the death of my husband, who died in a Motor accident.
I submit that while so on, 05-05-2013 in the night hours,
my deceased husband, and one K.Nagabhushanam and
A.Narasiah came to D.V.Kondala Rao, Pastors house situated at
Addanki from Thurupu Veerayapalem Village and on 05-052013 at about 10-30 p.m., the deceased and the above said
persons along with D.V.Kondala Rao, boarded the cement lorry
bearing No.AP 16 TB 9577 at Addanki to go to Chennai as a
fare paid passengers by paying an amount of Rs.100/- each one
to the 1st respondent and in the mean time on 06-05-2013 at
about 01-30 a.m., when the lorry after crossing the Kalikivai
cross road, Mulaguntapadu Panchayat, S.Konda Mandal,
Prakasam District, the 1st respondent drove the lorry bearing
No.AP 16 TB 9577 with rash and negligent manner in high
speed and lost control over the steering, due to that, the lorry
was turned turtle on the left side road margin. Due to that the
deceased and some other persons, who sat on the cement
bags on the above said lorry fell on the road and the cement
bags also fell on the deceased persons and all are sustained
bleeding grievous injuries all over their bodies. Due to that
impact the deceased and 9 other persons died on the spot and
3 persons sustained grievous injuries. After the accident a case
was registered in Cr.No.64/2013 U/Sec.337, 338 & 304-A I.P.C.,
1

and Sec.134, 187 of M.V.Act, and investigated into.

The
accident was occurred solely due to rash and negligent driving
of the driver of Lorry bearing No.AP 16 TB 9577 , during the course
of his employment under the 2 nd respondent and the same was
insured with the 3rd respondent.
We are the dependants on the income of the deceased. I
am the Wife of the deceased and I have been suffering with loss
of consortium, and the petitioners 2 to 5 are the minor children of
the deceased and they are suffering with loss of love and
affection due to immature death of the deceased at their child
age. Petitioners 6 & 7 are the parents of the deceased and they
are suffering with starvation after the death of the deceased at
their old age. We have lost our love and affection and we lost our
bright future due to immature death of the deceased, and we are
suffering with starvation after the death of the deceased. We
lost our bread winner and also sustained loss of future earnings
of the deceased.
R-1 is the driver of Lorry bearing No.AP 16 TB 9577, R-2 is the Owner
of Lorry bearing No.AP 16 TB 9577, R-3 is the insurer of the Lorry bearing
No.AP 16 TB 9577 and hence all the respondents are jointly and severally liable
to pay the compensation claimed by us.
A case was registered in Cr.No.64/2013 U/Sec.337, 338 & 304-A I.P.C.,
& Sec.134, 187 of M.V.Act of Singarayakonda P.S., Prakasam District.
I am filing documents along with my chief affidavit.
documents may be marked as exhibits on my behalf.

Those

Exhibit-A1:-Certified copy of F.I.R. in Cr.No.64/2013 U/s.337,

338

&
304-A

IPC

&

Sec.134,

187

of

M.V.ACT

of

Singarayakonda
P.S., Prakasam District.
Exhibit-A2:-Certified copy of Inquest Report relating to the
deceased
Gallepogu Salmon Raju @ Salmon,
Exhibit-A3:-Certified copy of P.M. Certificate relating to the
deceased
Gallepogu Salmon Raju @ Salmon,

Hence I pray that the Honble Court may be pleased to pass a decree
and judgment in our favour and against the respondents with joint and
several liability for compensation of Rs.8,00,000/- with subsequent interest
at 12% p.a. from the date of petition and with costs.

DEPONENT
Solemnly affirmed and signed before me the contents of the affidavit is read
over and explained in Telugu to the deponent and admitted her to be correct
on this the
day of October, 2015.
Advocate, Ongole.

V.V.P
.K
Petitioners

IN THE COURT OF THE IVth ADDL.

DISTRICT JUDGE :: ONGOLE

M.V.O.P.No.225/2013

CHIEF AFFIDAVIT FILED ON

BEHALF OF THE PETITIONERS
(PW-1) UNDER ORDER 18 R 4 &
139 C.P.C

FILED BY:Sri V.VENKATA PAVAN KUMAR,

ADVOCATE, ONGOLE