IN THE COURT OF THE PRL.

DISTRICT JUDGE, ONGOLE

M.V.O.P.No.388/2016

Potthuri Nagaveni & 3 others .. Petitioners

AND
Srinivaslu K & 2 others .. Respondents

CHIEF AFFIDAVIT FILED ON BEHALF OF THE PETITIONERS

(PW-2) U/Or 18 R 4 & Sec.139 C.P.C

I, Kothimera Suresh S/o.Raghavulu aged 28 years, Hindu, Tractor

Driver, R/o.S.C.Colony, Doddavarappadu Village, Maddipadu Mandal,
Prakasam District, do hereby solemnly affirm and sincerely state as
follows:-
I am the deponent herein and 3rd party to the above proceedings. I
am well acquainted with the facts of the case. I am eye-witness to the
above proceedings.
I submit that while so on, 25-07-2016 in the morning hours I
came to Komitineni Raghava Raos Tea Shop, which was situated on NH-
16, Western side of the Doddavarappadu X road and at about 7-30 a.m.,
when I was drinking tea in the above said Tea Stall at that time, one
Potthuri Srinivasa Rao, who is my co-villager, coming from
Seetharamapuram Kostalu on his motorcycle with water babuls with
tightening rope on NH-16, Guntur to Ongole road and when he reached
near Doddavarappadu X road while passing through Zebra line on NH-
16 road and the front wheel of the motor cycle crossed the middle of the
road i.e., the place in between Ongole Vijayawada road and Vijayawada
Ongole road and at that time a car bearing no.AP-26-AF-0826 which is
coming from Vijayawada side towards Ongole side without observing
traffic controller signal point (orange blinking light) came extreme his
right side of the road driven by its driver in a rash and negligent manner
with high speed without blowing horn dashed the rear side of the motor
cycle on which the deceased was going. Due to that hit the deceased fell
down from the motor cycle on the road. Due to the accident the
deceased sustained grievous injuries all over his body including injury

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to his head. After the accident the car was stopped to a distance. Later
who witnessed the accident came to the accident spot, myself and one
Nagineni Ravikanth shifted the deceased to Sangamitra Hospital, Ongole
for treatment on the said crime car bearing No.AP 26 AF 0826.
The accident was took place due to rash and negligent driving of
the driver of the car bearing No.AP 26 AF 0826. After the accident I
gave complaint to the Maddipadu P.S., and also I was examined by the
Police as LW-1.
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 him to
be correct on this the 28th day of June, 2017.
Advocate, Ongole.

V.V.P.K
Petitioners

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IN THE COURT OF THE PRL.
DISTRICT JUDGE :: ONGOLE

M.V.O.P.No.388/2016

CHIEF AFFIDAVIT FILED ON

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

FILED BY:-
Sri V.V.PAVAN KUMAR
ADVOCATE, ONGOLE