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S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
daughter of late Padarthi Rathnam, all are Hindus, aged about 32, 29, 26, 20 and
District. Their address for service of all notices etc., on them is that of their
advocates Smt. G. Seshamma, B.Sc., B.L., and Sri G. S. Prasad, B.A., B.L., Kovur,
2. The petitioners submit that one Padarthi Rathnam is their father and
his legal heirs to succeed to his estate and liabilities. The said accident is
registered as Crime No.84/2016 in Kavali Rural P.S. The mother and wife of the
said Padarthi Rathnam are predeceased to him. The petitioners are filing the
Family Members Certificate showing that their father Padarthi Rathnam resident
3. After the demise of the said Rathnam, the 1 st petitioner approached the
Depot Manager, APSRTC, Kavali for the death benefits of his father and the
Depot Manager who forwarded his request to the Secretary, APSRTC Staff
Benevolent cum Thrift Fund, Hyderabad and the Depot Manager, Kavali received
him that the said Rathnam has shown his wife as his nominee and as she was
predeceased to him and has not executed any revised Nomination Form and so
directed the Depot Manager, Kavali to advise the 1 st petitioner and other family
Hundred and Fifty Eight only) approximately to settle the issue. The Depot
21.12.2016 to the 1st petitioner informing the same and advised him to submit
Succession Certificate for the said amount from competent civil court as early as
possible. In the circumstances the petitioners are constrained to file this petition
Copy of FIR in Crime No.84/2016 in Kavali Rural P.S. and Letter bearing No.
Manager, APSRTC, Kavali along with the letter addressed to him by the
Secretary, APSRTC SBT, Hyderabad and the petitioners crave leave of the
Hon’ble Court to refer the contents of the same as part and parcel of this petition.
// 3 //
Rathnam died leaving the petitioners as his legal heirs and as the Depot
Village, Kodavalur Mandal, SPSR Nellore District within the jurisdiction of this
Hon’ble Court and hence this Hon’ble Court has got jurisdiction.
6. A fixed court fees of Rs.3/- is paid under Schedule II, Article II (L) (2) of
A.P.C.F and S.V. Act.
(c) grant such other and further reliefs as the Hon’ble Court deem just
Kovur, 2 .02.2017 1.
2.
3.
4.
5.
Filed by me,
We, the petitioners, do hereby declare that
the above contents are true to the best of
our knowledge, information and belief.
Advocate for Petitioners.
1.
2.
3.
4.
5.
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE, KOVUR
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
PETITION SCHEDULE
Kovur, 2 .02.2017 1.
2.
3.
4.
5.
Filed by me,
We, the petitioners, do hereby declare that
the above contents are true to the best of
our knowledge, information and belief.
Advocate for Petitioners.
1.
2.
3.
4.
5.
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE, KOVUR
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend … Petitioners
Vs.
Nil … Respondents
AFFIDAVIT
1. I submit that I am the 1st petitioner herein and petitioners 2, 4 and 5 are
my brothers and 3rd petitioner is my sister. Our father Padarthi Rathnam while
as his legal heirs to succeed to his estate and liabilities. The said accident is
showing that our father Padarthi Rathnam resident of North Rajupalem Village,
legal heirs.
2. I further submit that after the death of our father, I approached the Depot
Manager, APSRTC, Kavali for the death benefits of our father and the Depot
cum Thrift Fund, Hyderabad and the Depot Manager, Kavali received a letter
the said Rathnam has shown his wife as his nominee and as she was
predeceased to him and has not executed any revised Nomination Form and so
// 2 //
directed the Depot Manager, Kavali to advise me and other family members to
Rs.1,82,358/- (Rupees One Lakh Eighty Two Thousand Three Hundred and Fifty
Eight only) approximately to settle the issue. The Depot Manager, Kavali in turn
the same and advised me to submit Succession Certificate for the said amount
from competent civil court as early as possible. In the circumstances I and other
petitioners are constrained to file this petition for grant of Succession Certificate
Rathnam.
Crime No.84/2016 in Kavali Rural P.S. and Letter bearing No. E1/756(09)/2016-
along with the letter addressed to him by the Secretary, APSRTC SBT,
Hyderabad and craves leave of the Hon’ble Court to refer the contents of the
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
AFFIDAVIT
1. I submit that I am the 1st petitioner herein and petitioners 2, 4 and 5 are
my brothers and 3rd petitioner is my sister. Our father Padarthi Rathnam while
as his legal heirs to succeed to his estate and liabilities. The said accident is
showing that our father Padarthi Rathnam resident of North Rajupalem Village,
legal heirs.
Succession Certificate from the competent Civil Court. The 5 th petitioner is minor
petitioner is also entitled to receive the death benefits payable to us. As both of
my parents died and 5th petitioner being minor, is in my custody and I am looking
// 2 //
after his welfare as his elder brother. I have no adverse interest against the claim
of 5th petitioner and I will safeguard his interest and I will not act against his right
permit me to file the petition on behalf of the 5 th petitioner as his next friend /
guardian, otherwise the 5th petitioner will be put to serious hardship and injury.
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
For the reasons mentioned in the accompanying affidavit the Hon’ble court
may be pleased to:
a) permit the 1st petitioner to file the petition on behalf of the 5 th petitioner as
b) grant such other and further reliefs as the Hon’ble Court deem just and
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
1. I am plaintiff in the above suit and I filed the above suit against the
defendant for recovery of the amount due under the suit promissory note. I have
verified the pleadings and contents that are mentioned in the plaint are all true
and correct and I pray the Hon’ble Court may be pleased to treat the contents of
the plaint as part and parcel of this affidavit and pray the Hon’ble Court may be
Kovur, 13.10.2016.
Solemnly affirmed and signed before me at
Kovur on this 13th day of October, 2016.
Filed by me,
O.S.No. / 2016
1. I am plaintiff in the above suit and I filed the above suit against the
defendant for recovery of the amount due under the suit promissory note. I am
furnishing the Registered Address of the defendant hereunder for service of
summons.
Nataru Venkateswarlu,
S/o Ramanaiah,
R/o Chandrasekharapuram Village
Allur Mandal,
SPSR Nellore District.
Kovur, 13.10.2016.
Solemnly affirmed and signed before me at
Kovur on this 13th day of October, 2016.
Filed by me,
S.O.P.NO. / 2017
1. Padarthi Rambabu
2. Padarthi Praveen
3. Musunuru Anusha
4. Padarthi Sannibabu
5. Padarthi Vineeth
(being minor rep. by his brother
Padarthi Rambabu as guardian / next friend) … Petitioners
Vs.
Nil … Respondents
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