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IN THE COURT OF PRIL SENIOR CIVIL JUDGE AT KADAPA

O.S No.257/2018
Sudha Suryamumi Reddy … Plaintiff
Vs.
Malreddy Sreedhar Reddy … Defendant
CHIEF-AFFIDAVIT OF PW-1 (PLAINTIFF) FILED ON BEHALF OF
THE PLAINTIFF UNDER ORDER 18 RULE 4(1) OF C.P.C
I, Sudha Suryamuni Reddy son of Sudha Muni Reddy aged
about 48 years, Hindu farmer residing at choutapalle village hamlet
of Machanuru, Pendlimarry Mandal, Kadapa District do here by do
here by solemnly declare and state as follows.
1. I am the plaintiff herein and I am deposing as PW-1 in this suit.

2. I filed the suit agaist the defendant for suit amount Rs.
3,40,000/- due on suit promissory note.
3. I humbly submit that the defendant borrowed
Rs.2,00,000/- on 18-07-2015 from me at Machupalle village in
Pendlimarry Mandal Kadapa District for his family necessitie by
executing suit promissory note on 18-07-2015 in favour of me by
promissing to repay the prinicipal amount of Rs.2,00,000/- with
interest at the rate of Rs. 24% P.A on demand either to me or to his
order. I demanded the defendant several temes for suit pronote
amount, but the defendant used to post pone the repayment on
some false pretext or the other. I issued lagel notice dated 06-04-
2018 through my advocate to the defendant demanding the suit
amount. The defendant recived that legal notice on 07-04-2018 and
that the defendant utterly failed either to pay the suit amount to me
or to give reply notice to me. Hence I am forced to file this suit
against the defendatn for suit amount. The defendant did not pay
any amount to me upto now.
4. I humbly submit that the defenadant has to pay the
interest at the rate of Rs. 24% P.A as agreed upon in the suit
promissory note and that the suit amount is Rs. 3,40,000/-
:: 2 ::
4-A. THE FOLLOWING DOCUMENTS MAY KINDLY BE
MARKED AS EXHIBITS A1 TO A4 ON MY BEHALF:
i. Ex.A-1 is the Original promissory note dated 18-07-2015
executed by the defendant in favourt of the plaintiff for Rs.
2,00,000/-.
ii. Ex.A-2is the Office copy of the legal notice dated 06-04-2018
issued by the counsel of the plaintiff to the defendant.
iii. Ex.A-3 is the Postal receipt dated 06-04-2018 adressed to the
defendant for serial No. 2 legal notice to the defendant.
iv. Ex.A-4 is the Postal Ack-nowledgement dated 07-04-2018
signed by the defendant.
5. Prayer:- Therefore I pray that the Honourable court may
be pleased to pass a decree and judgement in my favourt of and
against the defendant by
(1). Directiong the defendant to pay the suit amount of Rs.
3,40,000/- to me with future interest on Rs. 2,00,000/- at the rate of
Rs. 24% P.A up to the date of realisation of decree amount from the
defendant.
(2). Costs of the suit and pass such other orders as the
Honourable court deams fit in the circunstances of the case in the
interest of Justion.

Solemnly affirmed and signed before me on this the th day of


January, 2018 at Kadapa.

FILED BY ME ADVOCATE

ADVOCATE FOR THE PLAINTIFF


IN THE COURT OF PRIL SENIOR
CIVIL JUDGE AT KADAPA

O.S No.257/2018

Sudha Suryamumi Reddy


… Plaintiff
Vs.
Malreddy Sreedhar Reddy
… Defendant

CHIEF-AFFIDAVIT OF PW-1
(PLAINTIFF) FILED ON BEHALF
OF THE PLAINTIFF UNDER
ORDER 18 RULE 4(1) OF C.P.C.

Filed by:

Sri. K. Venkata Reddy, B.Com., B.L.,


ADVOCATES FOR PLAINTIFF,
Kadapa.

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