Before the Motor Accident Claims Tribunal

IN THE COURT OF THE DISTRICT JUDGE::ONGOLE

M.V.O.P. No.
/2014
BETWEEN:-

1. Veluthurla Venkata Reddy S/o.Late Ramana Reddy,

aged about 27 years, Business,
2. Ambati Venkata Ratnam W/o.Govinda Reddy,
Aged about 24 years, House Wife,
3. Veluthurla Krishna Reddy S/o.Late Ramana Reddy,
aged about 22 years, Army Employee,
Petitioners 1 & 3 are residents of
Kurichedu Village and Mandal,
Prakasam District and 2nd petitioner is the
resident of Lakshmi Narayana Puram Village,
Darsi Mandal, Prakasam District.

..Petitioners

Their address for service is that of their Counsel, Sri Abburi

Venkateswarlu and Vemula Venkata Pavan Kumar, Advocates,
Ongole.
AND
1. T.Raja Ramesh Babu S/o.Satyanarayana,
Hindu, aged about 45 years,
R/o.D.No.3-203, 4th line, Satyanarayanapuram,
Ongole-523001, Prakasam District.
Owner of lorry bearing No.AP 27 Y 0108
2. Royal Sundaram Alliance Insurance Co.Ltd.,
Rep.by its Branch Manager,
1st Floor, Kaizen Hights, Sunday Market,
Gandhi Nagar, Nellore-524001.
(Cover Note No.0268676 valid from 20-07-2013 to 19-07-2014).
Their addresses for service are the same as above.

..Respondents

CLAIM APPLICATION FILED UNDER SECTION 166 (1)(c) & 168

OF MOTOR VEHICLES ACT, 1988
1. Name and fathers name of the :
person/dead
:

Veluthurla Adhi Lakshmi,

W/o.Late Ramana Reddy,

2. Full address of deceased

Veluthurla Adhi Lakshmi,

W/o.Late Ramana Reddy,
Kurichedu (V) & (M)
Prakasam Dist.

3. Age of the deceased

4. Occupation of the deceased

45 years
Agriculturist

5. Name and address of the

employer, if any of the
deceased.

Self Employed

Rs.6,000/- per month

6. Monthly Income of the person

deceased

7. Whether the person in respect of whom

compensation is claimed pays income :
tax ( to be supported by documentary
evidence)
8. Place, date, time of the accident :
9. Name and address of the P.S. in
whose jurisdiction the accident
took place or was registered.

--No--

On 26-06-2014 at about 01-40 hours, at

Bodduvaripalem on NH-16, Kodavalur
(V), Nellore Dt.
: Cr.No.105/2014 of Kodavalur P.S.
U/s.304-A, 337 IPC.

10. Was the person in respect of

:
whom compensation is claimed
traveling by the vehicle involved
Not travelling in Crime Vehicle
in the accident. If so state the name
of place or starting of journey and
destination.
11. Nature of the injuries, sustained
and the continuing effect, if any,
of the injuries.

Death Occurred.

12. Name and address of the Medical

Officer/Practitioner if any who
attended on the injured.

: DSR Govt. Hospital, Nellore

13. Nature of and period of treatment

and expenditure, if any injured
:
thereon ( to be supported by
documentary evidence)
14. Disability for work if any caused

Death Occurred

Death Occurred

15. Registration number and type of : Lorry bearing No.AP 27 Y 0108

the vehicle involved in the accident.
16. Name and address of the
Owner of the vehicle.
17. Name and address of the insurer
of the vehicle.
18. Has any claim been lodged with
the Owner/insurer of the vehicle
and if so with what result?
19. Whether the person injured was

: R-1 is the Owner of Lorry

: R-2 is the Insurer of Lorry

--No--

involved in any road accident

earlier (in case he was details of
the accident should be set out)

--No--

--No--

21. Whether he is related to for has

know to the defendant and if
so how?

--No--

22. Name and address of applicants

23. Relationship with the deceased

: Sons & Daughter of the

deceased.

24. Title to the property injured

20. Whether the person injured had

preferred claim for damages in
any case earlier and if so with
that result?

Shown as petitioners in cause

title.

L.Rs of deceased.

25. Amount of compensation claimed

1. Pecuniary damages.
Rs.
: Rs.7,00,000/- (Rupees
Seven lakhs only)
2. Non-Pecuniary damages Rs.
26. ANY OTHER INFORMATION THAT MAY BE NECESSARY OR
HELPFUL FOR THE DISPOSAL OF THE CLAIM.
The 1st petitioner is the Elder Son, the 2nd petitioner is
the daughter, and the 3rd petitioner is the younger son of the
deceased, V.Adhi Lakshmi. The husband of the deceased was
also died in the same accident.

The Deceased had been

working as Agriculturist and she used to get an income of

Rs.6,000/- per month and contributing the same her family
i.e., petitioners. The deceased was hale and healthy prior to
accident.

The deceased was aged about 45 years at the

time of accident.
While so, on 25-06-2014 at about 8-00 p.m., the
deceased herein and her husband V.Narayana Reddy, her
sons P1 & P3 and her daughter, i.e., 2 nd petitioner herein and
2nd petitioners daughters namely Gita and Keerthi, Ambati
Govinda Reddy, who is husband of the 2 nd petitioner and
their relatives, Gangireddy Kasamma, Syamala Srihari,

V.Aswini were started at Kurichedu Village on Chevrolet Car

bearing No.AP 27 TW 1290 to go to Tirumala and at about
01-30 a.m., on 26-06-2014 when the car reached near
Bodduvaripalem (V) on NH-16, Kodavalur Mandal, Nellore District, due to
decrease of air to the car tyres, the inmates of the car get down from the car
and waiting on the left side road margin and the driver of
said car taken out the car for filling up air to the car tyres
and in the meantime, the driver of Lorry bearing No.AP 27 Y
0108 drove the same with rash and negligent manner in high
speed without blowing horn and without observing the
persons who were on the left side road margin and went
extreme

left

and

dashed

against

the

deceased

and

petitioners 1 to 3 and others, while proceeding towards

Nellore side. Due to that hit, the deceased herein, V.Ramana
Reddy, and Gangireddy Kasamma were died on the spot and
the other persons were shifted to DSR Govt. Hospital, Nellore
for treatment and one Syamala Sri Hari S/o.Venkateswarlu
was succumbed to the injuries while undergoing treatment.
The accident was occurred solely due to rash and negligent
driving of driver of Lorry bearing No.AP 27 Y 0108, during the
course of his employment under the 1st respondent and the
same was insured with the 2nd respondent.

After the

accident the 2nd petitioner gave report to the Police and the
same was registered as in Cr.No.105/2014, U/s.304-A, 337
IPC of Kodavalur P.S. Nellore District.
The family members lost their bread winner.

The

petitioners 1 & 3 are the sons, the 2 nd petitioner is the

daughter of the deceased and they are suffering with loss of
love and affection and they lost their bread winner and they
are suffering with lot of mental agony due to immature death
of the deceased and lost their future plans and future
earnings of the deceased.
R-1 is the Owner of the Lorry bearing No.AP 27 Y 0108
and R-2 is the insurer of the said Lorry bearing No.AP 27 Y 0108 and

hence both the respondents are jointly and severally liable to

pay the compensation claimed by the petitioners.
The petitioners did not file any other petition in any
other Tribunal except this claim petition.
A case was registered in Cr.No.105/2014 u/s.304-A I.P.C of Kodavalur
P.S.
Hence, the petitioners are claiming compensation of
Rs.7,00,000/-.
27.

A court fee of Rs.6,360/- is paid under rules 475 of M.V.

Rules on compensation of Rs.7,00,000/- dt.

-08-2014 on

S.B.I, District Court Branch, Ongole.

28. PRAYER:The petitioners therefore pray that the Honble Court may be pleased
to pass a decree and Judgment in favour of the petitioners and against the
respondents with joint and several liability;
i)

for compensation of Rs.7,00,000/- rupees Seven lakhs only;

ii) for subsequent interest at 12% p.a. from the date of petition, till the date
of realization;
iii) for costs of the petition; and
iv) for such other and further reliefs in the interests of justice.

ADVOCATE FOR PETITIONERS

PETITIONERS
The facts stated above are true to the best of my knowledge, belief and
information.

ONGOLE,
PETITIONERS
Dt:- -08-2014
List of Documents:1. Xerox copy of F.I.R. in Cr.No.105/2014 u/s.304-A, 337 I.P.C of
Kodavalur P.S.
2.Xerox copy of Inquest Report, relating to deceased, V.Ramana Reddy,
3.Xerox copy of P.M. Certificate relating to deceased, V.Ramana Reddy.
Advocate for Petitioners

A.V.S
Petitioners

BEFORE THE MOTOR ACCIDENTS

CLAIMS TRIBUNAL
IN THE COURT OF THE DISTRICT
JUDGE ::ONGOLE::

M.V.O.P.No.

/2014

CLAIM APPLICATION FILED

ON BEHALF OF THE
PETITIONER UNDER SECTION
166 (1)(c) & 168 OF M.V.ACT, 1988

FILED BY:Sri.ABBURI VENKATESWARLU,

Sri.V.V.PAVAN KUMAR,
ADVOCATES, ONGOLE.