IN THE COURT OF THE MOTOR ACCIDENTS CLAIMS TRIBUNAL:

HINDUPUR.
(BEFORE THE HON’BLE II ADDL. DISTRICT JUDGE: HINDUPUR)

O.P. No.77/2019

Between:

Mandoji Sadik Vali @ M.Sadiq Vali … Petitioner

and

1.Patan Chand Basha

2. The Regional Manager, APSRTC, Anantapuramu. … Respondents

CHIEF AFFIDAVIT OF P.W.1 MANDOJI SADIK VALI @ M.SADIQ VALI

FILED ON BEHALF OF THE PETITIONER UNDER
ORDER 18 RULE 4 OF C.P.C.

I, Mandoji Sadik Vali @ M.Sadiq Vali, Son of Mahaboob Khan,

Aged 42 years, Muslim, Conductor in Private Bus, R/o. D.No.1-72,
Obuladevara Cheruvu Mandal, (Old) Anantapuramu District, (New) Sri
Sathya Sai District, do hereby solemnly affirm and state as follows :

1. I am the deponent herein and the petitioner in the above O.P.

2. I submit that I have filed the above O.P. against the respondents
for grant of compensation on account of the injuries and disability
caused to me in motor vehicle accident.
3. I submit that before accident I was working as a conductor in a
private bus and getting income of Rs.10,000/- per month. I am the
only earning member in my family. Due to the accident, I lost my
left leg and got permanent and total disablement and I could not
attend to my day to day activities and I lost my livelihood.
4. I submit that on 28-02-2016 at about 09:30 A.M., I board the bus
at O.D.C. to go to Kadiri. I was getting down from APSRTC bus
bearing No.AP28-Z-4813, the driver of the bus without observing
that all passengers are getting down from the bus at in-gate of RTC
bus stand, Kadiri drove the bus in a rash and negligent manner,
for which I fell down from the bus and the bus passed on my left
leg and the leg was crushed and I sustained grievous injuries.
Immediately after the accident, I was admitted to Area Hospital,
Kadiri. Later I was shifted to St. John Medical Hospital, Bangalore
and there I was undergone operation and got treatment as in-
patient for 2 months. There my left leg was amputated, since then I
 was unable to move and not able to do anything. I spent more than
Rs.1,00,000/- towards medical, transport and attendant charges.
On the complaint of one Rahamthulla, the S.H.O., Kadiri Town
P.S., registered a case in Cr. No.34/2016 under Sec.338 IPC
against the driver of the APSRTC bus bearing No.AP28-Z-4813 of
Hindupur Depot and the charge sheet was also filed.
5. I submit that the accident occurred due to sole rash and negligent
driving of the APSRTC Bus bearing No.AP28-Z-4813 by its driver.
The 1st respondent being the driver, the 2nd respondent being the
owner of the crime vehicle are jointly and severally liable to pay
compensation to me and I am claiming a sum of Rs.15,00,000/-
towards compensation under different heads which is just and
reasonable.
6. I, therefore pray that the Hon’ble Court may be pleased to pass a
decree for the amount claimed by me with costs and future interest
from the date of accident till payment against the respondents 1
and 2 jointly and severally and grant such other relief or reliefs as
the Hon’ble Court deems fit and proper in the circumstances of the
case, in the interests of JUSTICE.
List of Documents
Description of the Document Remarks
S.No.

1. Attested Copy of FIR in Cr. No.34/2016 of Ex. A-1

Kadiri Town P.S.

2. Attested Copy of Wound Certificate Ex. A-2

3. Attested Copy of Charge Sheer Ex. A-3

4. Original Disability Certificate Ex. A-4

5. Case Summary and Discharge Record of St. Ex. A-5

John Hospital, Bangalore

6. Medical Bills of St. John Hospital, Bangalore Ex. A-6

I swear accordingly,

DEPONENT

Solemnly affirmed and signed before me on - -2022 at Hindupur.

Advocate, Hindupur.
 IN THE COURT OF THE
MOTOR ACCIDENTS CLAIMS
TRIBUNAL: HINDUPUR.

(BEFORE THE HON’BLE II

ADDL. DISTRICT JUDGE:
HINDUPUR)

O.P. No.77/2019

CHIEF AFFIDAVIT OF
P.W.1 MANDOJI SADIK VALI
@ M.SADIQ VALI FILED ON
BEHALF OF THE
PETITIONER UNDER
ORDER 18 RULE 4 OF C.P.C.

FILED BY:-

D.RAMESH BABU,
ADVOCATE,
ANANTAPURAMU.

CELL No. 9440557488