IN THE COURT OF THE FAMILY JUDGE, ONGOLE

M.V.O.P.NO.218/2013
Aaluri Yeliya and another

..Petitioners
Vs
A.Srinu and others
..Respondents

CHIEF AFFIDAVIT FILED ON BEHALF OF THE

PETITIONERS (PW-2) U/Or 18 R 4 & Sec.139 C.P.C
I, Gandi Abraham @ Anantaiah S/o.Tirupalu, aged about 47 years,
Cooly, resident of Singannapalem Village, Mundlamur Mandal, Prakasam
District, do hereby solemnly affirm and sincerely state as follows:I am the petitioner herein and 3 rd party to the above
proceedings.
I am well acquainted with the facts of the case. I am eyewitness to the above accident.
While so on, 05-05-2013 in the night hours, the
deceased herein i.e., Aaluri Pitchaiah, Lakkepogu China
Ankaiah, A.Ramesh, N.Hanook and A.Mozes, came to the
D.Kondala Raos house situated at Addanki Village from
Elchuru Village and also one Kanumuri Nagabhushanam,
G.Salmon Raju, and A.Narasiah came to the D.Kondala Raos
house situated at Addanki Village from Thurupu
Veerayapalem Village and also I came from Singannapalem
Village,
Mundlamur
Mandal
and
on
05-05-2013 at about 10-30 p.m., myself and the above said
persons boarded a cement lorry bearing No.AP 16 TB 9577
at Addanki Village to go to Chennai as a fare paid
passengers by paying an amount of Rs.100/- each one to the
1st respondent and in the meantime on 06-05-2013 at about
01-30 a.m., when the lorry after crossing the Kalikivai cross
road, Mulaguntapadu Panchayat, S.Konda Mandal, Prakasam
District, the 1st respondent drove the lorry bearing No.AP 16
TB 9577 with rash and negligent manner in high speed and
lost control over the steering, due to that, the lorry was
turned turtle on the left side road margin. By the time of
accident, myself and D.Kondala Rao, were sat in the cabin
and due to that myself and the above said persons, who sat
on the cement bags on the said lorry fell on the road and the
cement bags also fell on the deceased persons and all are
sustained bleeding grievous injuries all over their bodies.
Due to that impact I sustained grievous bleeding injuries all

over my body and the deceased herein and 9 other persons

died on the spot and 2 persons sustained grievous injuries.
After the accident I gave complaint to the S.Konda
Police and the same was registered as a case in
Cr.No.64/2013 U/Sec.337, 338 & 304-A I.P.C., and Sec.134,
187 of M.V.Act, and investigated into.
The accident was
occurred solely due to rash and negligent driving of the
driver of Lorry bearing No.AP 16 TB 9577, during the course
of his employment under the 2 nd respondent and the same
was insured with the 3rd respondent. Immediately after the
accident I was shifted to RIMS Hospital, Ongole for
treatment. Later I filed MVOP.272/2013 on the file of Family
Court, Ongole against the respondents 1 to 3.
Later I was examined by the Police. Hence, I am giving this
affidavit as I saw the occurrence.

DEPONENT
Solemnly affirmed and signed before me the contents of the affidavit is read
over and explained in Telugu to the deponent and admitted her to be correct
on this the day of May 2015.
ADVOCATE, ONGOLE

V.V.P.
K
Petitioners

IN THE COURT OF THE FAMILY

JUDGE :: ONGOLE

M.V.O.P.No.218/2013

CHIEF AFFIDAVIT FILED ON

BEHALF OF THE PW-2 UNDER
ORDER 18 R 4 & 139 C.P.C

FILED BY:Sri. V.V.PAVAN KUMAR

ADVOCATE, ONGOLE.