IN THE COURT OF THE Ist ADDITIONAL DISTRICT JUDGE,

ONGOLE
M.V.O.P. No.146/201
Rebbavarapu Raghava Rao ..Petitioner
Vs
Musunuru Nagabhushanam and others ..Respondents
CHIEFAFFIDAVIT FILED ON BEHALF OF THE
PETITIONER (PW-1 !"Or 1# R $ C.P.C.
I, Rebbavarapu Raghava Rao S/o Ratnam, aged 37
years, Ex-Serviceman, resident of Sitaramapuram Viage,
!addipadu !anda, "ra#asam $istrict, do hereby soemny
a%rm and sincerey state as foo&s'-
I am the deponent herein and soe petitioner in the
above ()"), and I am &e ac*uainted &ith the facts of the
case) +he above ()") is ,ed for compensation for the in-uries
sustained by me in a !otor accident)
.hie so, that on /0-10-/10/ in the morning hours at
about 17-31 a)m), I &as started my motor cyce bearing
2o)3" /7 4 5167 from my house at Sitarampuram to go to
!addipadu on 28-7 road and as there &as 7 9! running for
"oice seections &ere conducting by the "oice, the tra%c
&as diverted and &hen I reached near 9oshtau :entre, I
observed that a orry &as proceeding ahead and I tried to
overta#e the orry and at that time, the crime orry bearing
2o)3" 06 ++ 7705 &as proceeding from Vi-aya&ada to
2eore, drove the same in a rash and negigent manner &ith
high speed and &ithout bo&ing horn, hit my motor cyce in
its opposite direction on my right side and caused the
accident) 3s a resut of it, I fe on the road and sustained
grievous in-uries to me i)e), fracture of right thigh, fracture of
right eg, beeding in-ury on forehead, bone exposed beo&
#nee and acerated &ound over right thigh and other in-uries
a over the body and immediatey after the accident, I &as
shifted to RI!S 8ospita, (ngoe by 01; 3mbuance, after ,rst
aid treatment, on the advice of the duty doctor, I &as ta#en
1
to !iitary 8ospita, Secunderabad and as there &as no
proper faciities for treatment in that hospita, I &as again
shifted to 3mar (rthopedic 8ospita, 9othapet, <untur for
better treatment) In that hospita, I &as admitted as an
inpatient and three time necessary surgeries &ere conducted
to my right eg and I too# treatment from //-10-/10/ to /=-
1/-/10/ and from 00-13-/10/ to /3-13-/10/ in 3mar
(rthopedic 8ospita, 9othapet, <untur and I incurred an
amount of Rs)3,61,111/- to&ards treatment and medicine
from the date of accident and ti the date of discharge,
besides I incurred an amount of Rs)0,11,111/- to&ards
nutrition, transport and attendant charges) $ue to the
accident I am sti su>ering severe pains and con,ned to bed
and unabe to &a# and sti ta#ing treatment in that hospita
as an outpatient once in a month) I am ony the bread &inner
to my famiy and due to the accident, the ,nancia position of
my famiy is in turmoi)
+he accident too# pace soey due to the rash and
negigent driving of the driver of the crime vehice i)e), orry
bearing
2o)3" 06 ++ 7705 by the 0
st
respondent, during the course of
his empoyment under the /
nd
respondent and the same &as
insured &ith the 3
rd
respondent)
Immediatey after the accident as I &as unabe to &a#
due to fractures and as I am ma#ing hectic e>orts to shift me
to the hospita, ta#ing advantage of the situation, the 0
st
respondent gave a report to the poice, as if the accident &as
occurred due to my negigent driving, though it is other&ise)
R-0 is the driver of orry bearing 2o)3" 06 ++ 7705, R-/
is the (&ner of orry bearing 2o)3" 06 ++ 7705, R-3 is the
orry bearing
2o)3" 06 ++ 7705, and hence a the respondents are -ointy
and severay iabe to pay the compensation caimed by me)
3 case &as registered in :r)2o)00//10/ ?nder Section
33; I": of
2
!addipadu ")S)
I am ,ing documents aong &ith my chief a%davit)
+hose documents may be mar#ed as exhibits on my behaf)
Exhibit-30'-3ttested copy of @)I)R) in :r)2o)00//10/ of
!addipadu ")S),
"ra#asam $ist)
Exhibit-3/'-3ttested copy of .ound :erti,cate issued by
3mar
(thopedic 8ospita, <untur,
Exhibit-33'-3ttested copy of :harge Sheet in :):)2o) //103
on the ,e
of Sp) !obie !agistrate :ourt, (ngoe,
8ence I am caiming compensation of Rs)7,71,111/- I
pray that the 8onAbe :ourt may be peased to pass a decree
and -udgment in my favour and against the respondents 0 to
3 &ith -oint and severa iabiity for compensation of
Rs)7,71,111/- &ith subse*uent interest at 0/B p)a) from the
date of petition, ti the date of reaiCation and &ith costs)
$E"(2E2+
Soemny a%rmed and a%xed signed before me the contents
of the a%davit is read over and expained in +eugu to the
deponent and admitted him to be correct on this the /0
st
day
of 3pri, /105)
3dvocate,
(ngoe)
3
V.V.P.%
Petitioner
IN THE C!RT " THE Ist
#$$%. $I&TRICT '!$(E
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M.*..P.No.1+,-2.13
CHIE" #""I$#*IT "I%E$ N
/EH#%" " THE PETITINER
0P1213 !N$ER R$ER 14 R + 5
136 C.P.C
+
FILED BY:-
&ri *.*.P#*#N 7!M#R8
#$*C#TE8 N(%E
9