IN THE COURT OF THE 1st ADDL.

DISTRICT JUDGE,
ONGOLE
I.A.No.
/2015
M.V.O.P. No.65/2014
Between:Devarakonda Srinivasa Rao S/o.Vasantha Rao,
aged about 40 years, Hindu,
H.No.7-785-3, Samatha Nagar,
Ongole, Prakasam District.
AND

..Petitioner

1. Thammisetty Venkateswarlu S/o.Thirupalu,

Aged about 25 years, Hindu,
Driver of Auto bearing No.AP 27 Y 0741,
R/o.Vaddepalem, Gangavaram Village,-523328
S.N.Padu Mandal, Prakasam District.
2. P.Rangaiah S/o.Subbaiah,
Hindu, aged about 40 years,
Owner of Auto bearing No.AP 27 Y 0741,
(As per Registration Certificate),
R/o.2-66(7), S.N.Padu (V) & (M),-523225
Prakasam District.
3. Eerla Srinivasulu S/o.Ayyanna,
Hindu, aged about 45 years,
Owner of Auto bearing No.AP 27 Y 0741
(As per Insurance Policy Copy)
R/o.Ganugapalem, S.N.Padu (V) & (M),-523225
Prakasam District.
4. Bajaj Allianz General Insurance Co.Ltd.,
Rep.by its Branch Manager,
D.No.58-8-13(2), GNR Complex,
opp.Raja Matha Devi Towers,
Santhapet, Trunk Road, Ongole.

..Respondents

PETITION FILED ON BEHALF OF THE PETITIONER

U/Or 26 RULE 1 & Sec.151 C.P.C
For the reasons stated in the accompanying affidavit, it is
prayed that the Honble Court may be pleased to appoint an
Advocate Commissioner to record the evidence of the M.Bala
Sundara Rao, D.S.P, SC & ST Cell, In charge to Administrative
Officer,

D.P.O.,

Ongole,

Prakasam

District,

(or)

The

Administrative Officer, D.P.O., Ongole, Prakasam District and

to submit Report before the Honble Court for kind perusal and pass
such other necessary orders, in the interest of Justice.

Be pleased to Consider
Ongole,
Dt:-07-11-2015.
1

ADVOCATE FOR
PETITIONER

IN THE COURT OF THE 1st ADDL. DISTRICT

JUDGE, ONGOLE
M.V.O.P. No.65/2014
Devarakonda Srinivasa Rao

..Petitioner
Vs

Thammisetty Venkateswarlu and others

..Respondents

AFFIDAVIT FILED UNDER SECTION 139 C.P.C

I, Devarakonda Srinivasa Rao S/o.Vasantha Rao, aged
about 40 years, Hindu, H.No.7-785-3, Samatha Nagar, Ongole,
Prakasam District, do hereby solemnly affirm and sincerely
state as follows:I am the deponent herein and sole petitioner in the above
O.P., and I am well acquainted with the facts of the case. I filed
the above O.P., for compensation for the injuries sustained by
me, in a motor accident.
I submit that I was examined as PW-1 and Ex.A1 to A12
marked on my behalf of. One Dr.C.Kamaraj, Head of the
Department of Orthopedic Surgeon, Kamineni Hospitals,
Hyderabad, was examined as PW-2 by the Advocate
Commissioner and Ex.X1 & X2 were marked and the matter is
coming up for my further evidence.
It is further submits that prior to the date of accident I
have been working as AR Constable in District Armed Reserve, Ongole and
earning Rs.23,994/- p.m and maintaining my family with that
amount.
Ex.A12 is my salary certificate issued by the
Administrative Officer, District Police Office, Ongole.
I submit that unless and until the witness is examined on
my side, I could not able to prove my earnings at all. I am
advised to file this application seeking the aid and assistance of
this Honble court. There are no willful laches on my part in not
filing the said application earlier.
So, I am advised to file this petition to record the evidence
on my side. I am ready to pay the commissioners fee towards
appointment of commissioner. The above witnesss evidence is
very essential to prove my case.
The matter is posted for further evidence on my side. So, it
is just and necessary to appoint an Advocate Commissioner to
record the evidence of the said witness, and to file the
commissioner record before the Honble Court.
Hence I pray that the Honble Court may be pleased to
appoint an Advocate Commissioner, to record the evidence of
M.Bala Sundara Rao, D.S.P, SC & ST Cell, In charge to
Administrative Officer, D.P.O., Ongole, Prakasam District,
(or) The Administrative Officer, D.P.O., Ongole, Prakasam
District and to submit the report before this Honble Court, or
else I will be put to loss and injury.
2

DEPONENT
Solemnly affirmed and signed before me the contents of the affidavit
is read over and explained in Telugu to the deponent and admitted
him to be correct on this the 07th day of November, 2015.

ADVOCATE, ONGOLE

V.V.P.K
Petitioner

IN THE COURT OF THE 1st

ADDL. DISTRICT JUDGE
::ONGOLE::

I.A.No.

/2015

M.V.O.P.No.65/2014

PETITION FILED ON
BEHALF OF THE
PETITIONER UNDER
ORDER 26 RULE 1 &
Sec.151C.P.C

FILED BY:Sri V.V.PAVAN KUMAR,

ADVOCATE, ONGOLE.

IN THE COURT OF THE 1st ADDL. DISTRICT

JUDGE, ONGOLE
M.V.O.P. No.65/2014
Devarakonda Srinivasa Rao

..Petitioner
Vs

Thammisetty Venkateswarlu and others

..Respondents

MEMO FILED ON BEHALF OF THE PETITIONER

It is submitted that the petitioner is herewith not pressing the above
I.A.No.

/2015, in the interest of justice.

Ongole,

Be pleased to Consider

Dt.07-11-2015.
Advocate for Petitioner