BEFORE THE MOTOR ACCIDENTS CLAIMS TRIBUNAL CUM

DISTRICT JUDGE: RANGA REDDY DISTRICT: AT L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay Yadav S/o. Alladi Ashok Kumar,

Aged about 9 years Occ : Student
Being minor represented by his father
and guardian Alladi Ashok Kumar Yadav,
S/o.Alladi Veeraswamy Yadav,
Aged about 40 years,
R/o.H.No.3-5-424, Vittalwadi, Narayanaguda,
Himayathnagar, Hyderabad. ..Petitioner

AND

1. Kanchi Parameswara Reddy S/o.Sundara rami Reddy

Aged Major, Occ: Owner of the crime vehicle
R/o. H.No.10-36-8/K/1, 2nd Line Janathapet
South Kavali, Kavali, Nellore District, A.P.

2.UNITED INDIA INSURANCE COMPANY LTD.,

Rep. by its Regional Manager,
Tirumala Towers, Judges colony, Malakpet
Hyderabad – 500036, T.S.

(Policy No.0522003116P105584610
Valid from 30-7-2016 to 29-7-2017)

3.Nikkala Prahlada S/o.late Shanthanna

Aged 42 years Occ: Driver R/o.H.No.4-63
Kanayapally village, Kothakota Mandal
Mahabubnagar District. ..Respondents

CLAIM PETIION FOR COMPENSATION UNDER SEC.166 OF THE M.V.ACT

1988 AND RULES 475/1B OF A.P.M.V.RULE 1989

The description and address of the petitioners for service of notice,

process, etc. is the same as Mentioned in the above title and also that of his
counsel M/s.A.MAHESH KUMAR, Advocate, # 303A 3rd floor, Om Sai
Swathi Avenue, Barkatpura, Hyderabad.

The address of the respondents for service of notice and process on

them are same as mentioned above.

I, the above named petitioner having been injured in motor vehicle

accident hereby apply for the grant of compensation for the injury sustained
necessary particulars in respect of the injury vehicle etc. are given below.
1. Name and father’s Name of the
Person injured
2. Full address of the person
injured
3. Age of the person injured
4. Occupation of the person injured
5. Named and address of employer of
the injured
6. Monthly income of the person
injured
7. does the person in respect of where
compensation is blamed pay
income tax
8. Place date time of the accident
9. Name and address of the police
station in whose jurisdiction the
accident took place of registered
10. Was the person in respect of
whom compensation is claimed
traveling by the vehicle involved
in the accident it so give the name
of places starting of journey and
destination
11. Nature of injuries sustained and
continuing effected any of the
dead
12. Name and address of the medical
officer/practitioner if any attended
on the deceased
13. Nature and period of the
treatment and expenditure if any,
incurred thereon
14. Disability for worker, if any
accused
15. Registration number and the type
of the vehicle involved in the
accident
16. Name and address of the owner of
the vehicle
17. Name & Address of the insurer of
the vehicle
18. Has any claim been lodged with
the owner insurer and if so with
result
Alladi Ajay Yadav S/o. Alladi Ashok
Kumar Yadav
H.No.3-5-424, Vittalwadi, Narayanaguda,
Himayathnagar, Hyderabad.
9 years
Student
N.A.
----
No
On 20-8-2016 at about 7.20 a.m. near
Gandiguda village on NH-44 road at
Hyderabad
P.S Shamshabad registered a case
vide Cr.No.200/2016 for the offence
U/Sec.338 I.P.C.
The petitioner along with his family
were boarded Auto bearing No.TS-11-
UA-8476 to go to Beechpally
Right Frontal and Parietal Bone
Fracture Right Clavicle Fracture and
also severe bleeding injuries to all
over body
The Duty Doctor, SVS Institute of
Neurosciences, Kachiguda, Hyderabad.
Still undergoing treatment.
Permanent disability
Lorry Bearing No.AP-26-U-5999
As shown in the cause title as R.1
As shown in the cause title as R.2
No
 26. Any other information may be
19. Whether the person injured necessary for helpful in the
had been involved in any road disposal of the claim the
petitioners submits as follows:
accident earlier.

20. Whether the person injured

had preferred claim for

damaged in any case earlier

and if so, with what result.

21. Whether he is related to or has -NIL-

know defendant and if so how.

22. Name and address of the -No-

Applicants

-No-
23. Relationship with the person
injured :
As shown in the cause title as
24. Title to the property of the petitioner
injured
self
25. Amount of compensation claimed

(i) FOR SPECIAL DAMAGES Self (injured)

(Particulars of loss expenses)

Rs.2,50,000/-
(a) Loss of earnings from 10-11-2015

(b) partial loss of earnings from

Rs.----

(c) Transport to Hospital

Rs.----
(d) Extras nourishment and medicine

Rs.1,25,522/-
(e) Damages to clothing and articles
--
[f) Others.
--
(ii) FOR GENERAL DAMAGES

(a) Compensation for pain and Rs.50,000/-

suffering

(b) Compensation for the continuing Rs.75,522/-

or permanent disability, if any

(c) Compensation future earning

powers and maintenance/loss of -----------------
consortium (loss conjugal Rs.2,50,000/- (Rupees Two Lakhs
happiness to the petitioners) ----------------- fifty thousand
permanent disability only)
 :: 4 ::

That the Petitioner most humbly submits as follows:-

1. That on 20-08-2016 morning at about 06.00 hours when the

petitioner and others were boarded an Auto Bearing No.TS-11-UA-
8476 and left from Hyderabad to go to Beechpalli of Mahaboobnagar
for Krishna Pushkaralu, on the way at about 07:20 hours when the
said auto reached near Parking garage, Gandiguda Village limits,
Shamshabad Mandal on NH-44 Road, mean time one Lorry bearing
No.AP-26-U-5999 its driver drove the said lorry in rash and negligent
manner, proceeding in same direction and hit to said auto from back
side. As a result of the petitioner and other inmates of said auto
sustained grevious injuries. Immediately the petitioner was shifted to
Trident Hospital, Shamshabad for treatment by 108 ambulance,

2. That the Police Shamshabad registered a case in Cr.No.200/2016

for the offences U/Sec.337 IPC against the driver of Lorry bearing
No.AP-26-U-5999.

3. That the petitioner was aged 9 years and he was hale and healthy
at the time of accident. Due to fracture injuries the petitioner is not in
a position to attend his studies. The petitioner lost his academic year.
The petitioner’s parents incurred huge amounts for his treatment and
medicines, still he is suffering with physical pain and has been taking
treatment in private hospitals by incurring huge amounts.

4. That the driver of the vehicle Lorry bearing No.AP 26-U-5999

drove the vehicle in rash and negligent manner with high speed and
caused the accident. The Respondent No.1 is owner, Respondent No.2
is the Insurance company and Respondent No.3 is driver of crime
vehicle. Hence all the Respondents are jointly and severally liable to
pay the claimed compensation to the petitioner.

Jurisdiction : That the accident occurred within the limits of PS

Shamshabad, hence this Hon’ble Court having jurisdiction to entertain
the present petition.
 :: 5 ::

It is submitted that this is the first case between the parties and
there is no other case or proceedings are pending in any other Court
or authority

Therefore it is prayed that the Hon’ble Court may be pleased to

award compensation of Rs.2,50,000/- together with costs and interest
@ 18% p.a. from the date of the petition till the date realization of
compensation amount towards special and general damages against
the Respondents Jointly & Severally liable to pay the compensation in
the interest of Justice.

L.B.Nagar
Date: -01-2017 Petitioner

VALUATION

That the claim 475 of the petitioners is for the sum of Rs.2,50,000/-
In the shape of general damage and a Court Fee of Rs.
Is paid under Rule 475/1B of A.P.M.V. Rules 1989 which is sufficient
and proper and the petitioners have filed the petition for court fee
exemption.

VERIFICATION

I/We the above named petitioner do hereby state that the facts
stated in the said claim petition are true and correct to the best of my/
our knowledge, belief and information, hence verified on the day
of January, 2017.

L.B.Nagar

Date: -01-2017 Petitioner

Counsel for the Petitioner

 BEFORE THE MOTOR
ACCIDENTS CLAIMS
TRIBUNAL CUM
DISTRICT JUDGE: RANGA
REDDY DISTRICT:
AT: L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
Alladi Ashok Kumar Yadav

..Petitioner

AND

Kanchi Parameswara Reddy

& others
..Respondents

CLAIM PETITION FOR

COMPENSATION U/SEC.166
OF THE M.V.ACT.1989 & R.
475/1B OF A.P.M.V.RULE
1989 R/W SEC. 163-A 140
(C) OF A.P. M.V.ACT.1989

Filed on: -01-2017

Filed by:

Address for Service:

M/s.A.MAHESH KUMAR,
Advocate,
# 303A 3rd floor, Om Sai
Swathi Avenue, Barkatpura,
Hyderabad.

Counsel for the Petitioner

 BEFORE THE MOTOR ACCIDENTS CLAIMS TRIBUNAL CUM
DISTRICT JUDGE: RANGA REDDY DISTRICT: AT L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
and guardian Alladi Ashok Kumar Yadav ..Petitioner

AND

Kanchi Parameswara Reddy & others ..Respondents

AFFIDAVIT

I, Alladi Ashok Kumar Yadav S/o. Alladi Veeraswamy Yadav,

aged about 40 years, R/o.H.No.3-5-424, Vittalwadi, Narayanaguda,
Himayathnagar, Hyderabad, do hereby solemnly affirm and state on
oath as follows:

1. I am the deponent herein and father of the Petitioner in the

above O.P., as such well acquainted with the facts of the case.

2. I submit that I have filed the above O.P. for compensation

against the Respondents herein due to injuries sustained by my son in
a road accident occurred on 20-08-2016 at 07.20 a.m. due to rash and
negligent driving of driver of Lorry bearing No.AP-26-U-5999.

3. That the P.S. Shamshabad has registered a case in

Cr.No.200/2015 U/Sec.337 IPC. The Respondent No.1 being the
owner, Respondent No.2 is insurer and Respondent No.3 is driver of
the said crime vehicle, all are liable jointly and severally to pay the
compensation of Rs.2,50,000/- to the petitioner.

That I have not filed any claim petition before any court of law or
tribunal for same relief, except this present O.P.

Hence this affidavit.

Sworn and signed before me DEPONENT

On this the day of
January, 2017 at Hyderabad.

Advocate, Hyderabad
 BEFORE THE MOTOR
ACCIDENTS CLAIMS
TRIBUNAL CUM
DISTRICT JUDGE: RANGA
REDDY DISTRICT:
AT: L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
and guardian Alladi Ashok
Kumar Yadav

..Petitioner

AND

Kanchi Parameswara Reddy

& others
..Respondents

AFFIDAVIT

Filed on : -01-2017

Filed by:

Address for Service:

M/s.A.MAHESH KUMAR,
Advocate,
# 303A 3rd floor, Om Sai
Swathi Avenue, Barkatpura,
Hyderabad.
 Counsel for the Petitioner

BEFORE THE MOTOR ACCIDENTS CLAIMS TRIBUNAL CUM

DISTRICT JUDGE: RANGA REDDY DISTRICT: AT L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay
Represented by his father
and guardian Alladi Ashok Kumar Yadav ..Petitioner

AND

Kanchi Parameswara Reddy & others ..Respondents

THIRD PARTY AFFIDAVIT

I,

do hereby solemnly affirm an state on oath as follows:

1. I am the deponent herein and third party to the above O.P.

proceedings as such I am well acquainted with the facts of the case.

2. I submit that I know the petitioner herein since long as I am also

resident of same locality. I know that the petitioner sustained injuries
in a road accident. The petitioner has filed the above O.P. against the
respondents for claiming compensation. The petitioner is being minor
representing by his natural father and guardian. That the petitioner’s
father having no adverse interest against the person or property of
minor petitioner.

Hence this affidavit.

Sworn and signed before me DEPONENT

On this the day of
January, 2017 at Hyderabad.

Advocate/Hyderabad
 BEFORE THE MOTOR
ACCIDENTS CLAIMS
TRIBUNAL CUM
DISTRICT JUDGE: RANGA
REDDY DISTRICT:
AT: L.B.NAGAR

O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
and guardian Alladi Ashok
Kumar Yadav

..Petitioner

AND

Kanchi Parameswara Reddy

& others
..Respondents

THIRD PARTY AFFIDAVIT

Filed on : -01-2017

Filed by:

Address for Service:

M/s.A.MAHESH KUMAR,
Advocate,
# 303A 3rd floor, Om Sai
Swathi Avenue, Barkatpura,
Hyderabad.

Counsel for the Petitioner

 BEFORE THE MOTOR ACCIDENTS CLAIMS TRIBUNAL CUM
DISTRICT JUDGE: RANGA REDDY DISTRICT: AT L.B.NAGAR

I.A.No. of 2017
In
O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
and guardian Alladi Ashok Kumar Yadav ..Petitioner/Petitioner

AND

Kanchi Parameswara Reddy & others ..Respondents/Respondents

AFFIDAVIT

I, Alladi Ashok Kumar Yadav S/o. Alladi Veeraswamy Yadav, aged

about 40 years, Occ: , R/o.H.No.3-5-424, Vittalwadi,
Narayanaguda, Himayathnagar, Hyderabad, do hereby solemnly affirm
and state on oath as follows:

1. I am the deponent herein and father of the Petitioner in the

above O.P., as such well acquainted with the facts of the case.

2. I submit that I have filed the above O.P. for compensation

against the Respondents herein due to injuries sustained by my son
Alladi Ajay Yadav in a road accident.

3. I submit that the petitioner is my minor son, I being the father

and natural guardian of the petitioner representing this case on behalf
of the minor child. I am a fit person to represent the case on behalf of
minor; I am not having any adverse interest against the minor
petitioner.

Hence it is prayed that this Hon’ble Court may be pleased to

permit me to represent the case on behalf of the minor son i.e.
Petitioner herein in the interest of Justice.

Sworn and signed before me DEPONENT

On this the day of
January, 2017 at Hyderabad.
 Advocate, Hyd
BEFORE THE MOTOR ACCIDENTS CLAIMS TRIBUNAL CUM
DISTRICT JUDGE: RANGA REDDY DISTRICT: AT L.B.NAGAR

I.A.No. of 2017
In
O.P.No. of 2017

Between:

Alladi Ajay Yadav S/o. Alladi Ashok Kumar,

Aged about 9 years Occ : Student
Being minor represented by his father
and guardian Alladi Ashok Kumar Yadav,
W/o.Alladi Veeraswamy Yadav,
Aged about 40 years,
R/o.H.No.3-5-424, Vittalwadi, Narayanaguda,
Himayathnagar, Hyderabad. ..Petitioner/Petitioner

AND

1. Kanchi Parameswara Reddy S/o.Sundara rami Reddy

Aged Major, Occ: Owner of the crime vehicle
R/o. H.No.10-36-8/K/1, 2nd Line Janathapet
South Kavali, Kavali, Nellore District, A.P.

2.UNITED INDIA INSURANCE COMPANY LTD.,

Rep. by its Regional Manager,
Tirumala Towers, Judges colony, Malakpet
Hyderabad – 500036, T.S.

(Policy No.0522003116P105584610
Valid from 30-7-2016 to 29-7-2017)

3.Nikkala Prahlada S/o.late Shanthanna

Aged 42 years Occ: Driver R/o.H.No.4-63
Kanayapally village, Kothakota Mandal
Mahabubnagar District. ..Respondents/Respondents

PETITION FILED UNDER RULE 172 OF C.R.P.

For the reaons stated in the accompanying affidavit, it is prayed

that this Hon’ble court may be pleased to permit father of the
petitioner to represent the above case on behalf of the Minor petitioner
as his natural mother and guardian, and to pass such other order or
orders in the interest of Justice.

L.B.Nagar
Date : -01-2017 COUNSEL FOR PETITIONERS
 BEFORE THE MOTOR
ACCIDENTS CLAIMS
TRIBUNAL CUM
DISTRICT JUDGE: RANGA
REDDY DISTRICT:
AT: L.B.NAGAR

I.A.No. of 2017
In
O.P.No. of 2017

Between:

Alladi Ajay Yadav

Represented by his father
and guardian Alladi Ashok
Kumar Yadav
..Petitioner/Petitioner

AND

Kanchi Parameswara Reddy

& others
..Respondents/Respondents

PETITION FILED U/R.172

OF C.R.P.

Filed on: -01-2017

Filed by:

M/s.A.MAHESH KUMAR,
Advocate,
rd
# 303A 3 floor, Om Sai
Swathi Avenue, Barkatpura,
Hyderabad.

Counsel for the Petitioner