IN THE COURT OF PRIL SENIOR CIVIL JUDGE KADAPA

OS NO: 57 /2018
Obul Reddy Bala Veera Reddy …Plaintiff
Vs.
Rekam Raja …Defendant

CHIEF-EXAMINATION AFFIDAVIT OF PW-1 (PLAINTIFF) FILED ON

BEHALF THE OF THE PLAINTIFF U/O 18 RULE 4 (1) OF C.P.C

I Obul Reddy Bala Veera Reddy son of Chinna Veera Reddy aged
about 64 year, Hindu agriculture residing at D.Kotta palli, Diguvapalli
post Valluru Mandal Kadapa District do hereby solemnly declare and
state as follows :-

1. I am the Plaintiff herein and I am deposing as PW-1 in this suit

and that I Know the facts of the suit.
2. I filed against suit the defendant Rs.13,56,300/- due on the
suit promissory note.
3. The defendant borrowed Rs: 8, 42, 000/- From the form me
on 07-08-2014 at Kadapa city for his ground nuts business by executing
suit promissory note promising to repay the principal amount of Rs:
8,42,000/- to me with interest at the rate of Rs:24% per annum on
demand. I sold my land of Acs: 7.65 to third party and keeping that
money with me. Then the defendant approached me and requested me
to lend the suit pronate amount to the defendant on interest for carrying
out his ground nuts business. Them I lent that amount of Rs: 8,42,000/-
to the defendant on interest. The defendant himself scribed the suit
pronate with his own hand writing.

4. I demanded the defendant to pay the suit pronate amount.

The defendant paid Rs:1,00,000/- to me on 31-12-2014 by making an
endorsement to that effect on the back of the suit pronote by writing
with his own hand writing. The defendant did not pay any other amount
to me even after several demands of me even unto now. Hence I am
forced to file this suit against the defendant.
 :: 2 ::

5. The defendant is living on business and not at all living on

agricultural income. So the Agricultural Debts Relief laws are not
applicable to the defendant. The defendant has to pay interest to me at
Rs: 24% P.A as agreed upon in the suit pronote.

6. I waited up to 30-12-2017 for the suit amount since the

defendant promised me that he will pay entire suit amount by 30-12-
2017 by 04:00 PM. So I calculated interest on the principal amount upto
30-12-2017. The defendant did not pay the suit amount on 30-12-2017
upto 04:00 PM. Hence I filed this suit at the fag end of the pronote before
expiry of limitation. The suit ought to have been filed on 31-12-2017, but
31-12-2017 and 01-01-2018 are happened to be public holidays. So the
suit was filed on 02-01-2018 on the next working day of the court. Hence
the suit was filed within the limitation.

7. The following documents may kindly be marked as exhibit A-1

and A-2 :-

I. Ex: A-1 original promissory note dated 07-08-2014 for Rs:8,

42, 000/- executed by the defendant in favour of the plaintiff
with endorsement dated 31-12-2014 made by the defendant
on the back of the suit pronote for paying Rs:1, 00, 000/- to
the plaintiff on 31-12-2014.
II. Ex: A-2 endorsement made by the defendant on 31-12-2014
on the back of Ex: A-1 i.e suit promissory note dated 07-08-
2014 after paying part payment of Rs: 1,00,000 by the
defendant to the plaintiff.

7. PRAYER: Therefore the I pray that the Honourable court may be

pleased to pass a decree and Judgment in my favour and against the
defendant.
i. Directing the defendant to pay the suit amount of
Rs:13,56,300/- with future interest at the rate of Rs: 24% P.A on
the principle amount of Rs:8,42,000/- from the date of filing of
the suit upto the date of realization of the suit amount from the
defendant.
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ii. Costs of the suit and pass such other orders as the Honourable
court deems fit in the circumstances of the case in the interests
of Justice.

Solemnly affirmed before me as true and correct and signed on 13th

Day of July 2018 at Kadapa.

Advocate
Filed by me

Advocate for the plaintiff

 IN THE COURT OF PRIL
SENIOR CIVIL JUDGE KADAPA
OS No: 57 /2018

Obul Reddy Bala Veera Reddy

…Plaintiff
Vs.

Rekam Raja
…Defendant

CHIEF-EXAMINATION
AFFIDAVIT OF PW-1
(PLAINTIFF) FILED ON BEHALF
THE OF THE PLAINTIFF U/O 18
RULE 4 (1) OF C.P.C

Filed by:

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

Advocate for the plaintiff,
Kadapa