Before the Learned Commissioner Workmen’s Compensation

West Bengal

CLAIM CASE NO 141 OF 2013

Mrs. Mejora Bibi, wife of Late Kitab

Mondal, residing at Village –
Colonypara, Teinpur, P.O.- Karimpur,
District – Nadia, West Bengal, and
Another.
………….Applicants

-VS-

M/s. Subam Shelter Private Limited,

Plot No.3, Door No.3, 4th Main Road, 8th
Cross Street, Ramnagar South,
Madiakkam, Chennai-600091.

……..Opposite Parties

The humble petition filed on behalf of the applicant above named

Most Respectfully Sheweth:

1. That today, the instant case has been fixed for OPW(L.Ch.) by your Honour.

2. That certain document is required to be proved in the present case. The

opposite party is the custodian of those documents.

3. That for the reason stated above the E. Karthick, one of the Supervisor of the
opposite Party, M/s. Subam Shelter Private Limited is required to be
summoned as a witness to give evidence in the instant case as OPW.

4. That as the E. Karthick, one of the Supervisor of the opposite Party, M/s.
Subam Shelter Private Limited is the custodian of those documents, it is
required to summon him to produce those documents before this Learned
Court.

5. That unless E. Karthick, one of the Supervisor of the opposite Party, M/s.
Subam Shelter Private Limited is summoned as a witness to produce the
documents before the Court and depose as OPW, your petitioner shall suffer
irreparable loss and injury.

-2-
 6. That this petition is made bona-fide and in the interest of justice.
For the facts and circumstances stated above your
petitioner most humbly prays that issue summon
against the E. Karthick, one of the Supervisor of the
opposite Party, M/s. Subam Shelter Private Limited
as a witness and production of such documents
before your court and to fixed the matter for the
same which is help to your petitioner to get proper
Justice in instant claim case being no 141 of 2013
and to pass such other order or orders as your
honour may deem fit and proper.
And for this act of kindness your petitioner as in duty bond shall ever pray.

Person to be Summoned

The E. Karthick son of S. Ezhumalai, one of the Supervisor of the opposite Party,
M/s. Subam Shelter Private Limited,
Limited residing at No 235, Fourth Street,
Kamatchi Amman Nagar, Narayana Puram, Pallikkaranai, Chennai-
600100.

Documents to be produced
i) All the documents relevant to the death of Kitab Mondal, which is under
custody of the Opposite Party.

VERIFICATION

I Mrs. Mejora Bibi, wife of Late Kitab Mondal, residing at Village –

Colonypara, Teinpur, P.O.- Karimpur, District – Nadia, West Bengal , do
hereby solemnly declare and say that the statements give above are true and correct
to the best of my knowledge and belief and I put my L.T.I on this verification on
day of 17th Septembar,2018 at my advocate chamber.