IN THE COURT OF THE Vth ADDL.

DISTRICT
JUDGE ONGOLE
I.A.No.
/2011 in M.V.O.P.229/2010
Between:Ravuri Satya Sridhar S/o Late Kaladhara Rao,
Aged about 29 years, Hindu, Private Employee,
resident of Ongole, Prakasam District.
AND

..Petitioner

1. Nukapangu China Lakshmaiah S/o Ramaiah,

aged about 28 years, Hindu, Lingagiri Village,
Driver of the DCM AP 24 X 6069,
Huzur Nagar Mandal, Nalgonda District.
2. V.Rama Murthy S/o Mattaiah,
aged about 40 years, Owner of the DCM AP 24 X 6069,
11-149, Gandhi Park Centre,
Huzur Nagar Village & Mandal, Nalgonda District.
3. The Branch Manager,
TATA AIG General Insurance Co.Ltd.,
Block-A, 2nd Floor, My Home Tycoon,
Greenlands, Begumpet, Hyderabad-500016.

..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 Dr.Vajrala
Siva Kumar, M.Ch(Neuro),

V.R.L.S.Memorial Neuro Hospital,

Bundar Road, Vijayawada, 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:-05-09-2011.
ADVOCATE FOR
PETITIONER

IN THE COURT OF THE Vth ADDL. DISTRICT JUDGE

ONGOLE
M.V.O.P.229/2010
Ravuri Satya Sridhar

..Petitioner
Vs

Nukapangu China Lakshmaiah and 2 others

..Respondents

AFFIDAVIT FILED UNDER SECTION 139 C.P.C

I, Ravuri Satya Sridhar S/o Late Kaladhara Rao, aged about 29 years,
Hindu, Private Employee, resident of Ongole, Prakasam District, do hereby
solemnly affirm and sincerely state as follow: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 caused to me in a motor accident.

I submit that, while so, on 06-05-2009, I and my family
friends by name Guntur Vijay Kumar and his wife and their
children were going to Hyderabad on Vijay Kumars Maruti
Wagon R Car bearing No.AP 29 AC 6256 from Vijayawada. On
the way at about 17.30 hours, when we reached the out skirts
of Madhavaram Village, the crime vehicle DCM vehicle bearing
No.AP 24 X 6069 coming from opposite direction, driven by the
1st respondent in rash and negligent manner in high speed
without blowing horn and without observing vehicles on the
road, hit the Maruthi Car in its opposite direction. Due to that
hit

received

bleeding

injuries

all

over

my

body

and

immediately I was shifted to Govt.Area Hospital, Suryapet and

after first aid treatment, I was referred to V.R.L.S. Hospital,
Vijayawada for better and expert treatment.

In that Hospital I

stayed as an inpatient from 07/05/2009 to 13/05/2009. In all I

spent Rs.50,000/- towards Ambulance, treatment and Medical
expenses.

I am still suffering with immense pains.

Still I am

not able to carry on my works and my natural duties.

2

The above matter posted to for my side evidence.

examined as PW-1.

I was

I submit that unless and until the Doctor is

examined in my side, I could not able to prove my case 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 Doctors 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 Doctors, 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
Dr.Vajrala Siva Kumar, M.Ch(Neuro),

V.R.L.S.Memorial Neuro

Hospital, Bundar Road, Vijayawada, and to submit the report

before this Honble Court, or else I will be put to loss and injury.

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 05 th day of
September, 2011.
ADVOCATE, ONGOLE

K.N.R.G
Petitioner

IN THE COURT OF THE Vth

ADDL. DISTRICT JUDGE
ONGOLE

I.A.No.
/2011
M.V.O.P.No.229/2010

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

FILED BY:Sri K.NAGESWARA RAO,

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