1 .
KAMAL RANI AGED ABOUT 57 YEARS WIFE· OF
LATE SH. ANIL KUMAR,
2 . MOHIT KANDHARI AGED ABOUT 36 YEARS SON OF
LATE SH. ANIL KUMAR,
3. SAMRITI KANDHARI AGED ABOUT 40 YEARS
DAUGHTER OF SH. ANIL KUMAR,
ALL R/0. H.NO. P-3-9814, KALI SADAK, NEW
ANANDPURI, LUDHIANA.
CLAIMANTS
VERSUS
1 PARDEEP SINGH SON OF SH. AJIT SINGH, R/0.
WARD NO. 2, TOWER LINE, SUBHASH NAGAR,
LUDHIANA. (DRIVER OF THE OFFENDING VEHICLE
BEARING REGISTRATION NO. PB-11-CB-8199)
2. HARMEET SINGH SON OF SH. SATNAM SINGH, R/0 ..
H.NO. 62, GURU TEG BAHADUR NAGAR,
JALANDHAR, (OWNER OF THE OFFENDING
VEHICLE BEARING REGISTRATION NO. PB-11-CB-
8199)
IIND ADDRESS:
# 79, TRANSPORT NAGAR, LUDHIANA.
3 HDFC ERGO GENERAL INSURANCE COMPANY LTD.
5TH FLOOR, SURYA TOWERS, THE MALL,
LUDHIANA. (INSURER OF THE SAID OFFENDING
1
/ VEHICLE
2315-2046-4588-3300-000)
VIDE POLICY NO.
RESPONDENTS
Petition Under Section 166 of The
Motor Vehicle Act for grant of
compensation of Rs. 80,00,000/-
and Under Section 140 for the
grant of ad-interim compensation.
Sir,
WE, KAMAL RANI AGED ABOUT 57 YEARS WIFE OF
LATE SH. ANIL KUMAR & MOHIT KANDHARI SON OF
LATE SH. ANIL KUMAR, SAMRITI KANDHARI AGED
ABOUT 40 YEARS DAUGHTER OF SH. ANIL KUMAR,
ALL R/0. H.NO. P-3-9814, KALI SADAK, NEW
ANANDPURI, LUDHIANA, do hereby apply for
the grant of compensation on account of
death of Sh. Anil Kumar, who died in a
Motor Vehicle Accident on 25/03/2023 due to
rash and negligent driving of respondent
no. 1. Necessary particulars regarding the
claimants, accident and the deceased, etc.
are given below:-
l.Name and Father's Anil Kumar S/o.
name of deceased Surinder Nath
2.Full address of the
H.No. 9814, Anand Vihar
person of deceased.
Kali Sadak, New Anandpuri
Ludhiana.
3.Age of the person dead.
About 64 Years.
4.0ccupation of the person
The deceased was
of the deceased.
a skilled worker
Vallabh Textile
and was doing job as
operator of flat machines
and was drawing salary of
Rs. 20,000/-. Beside
5.Name and address of the M/s. Kansal Hosiery
employer of the deceased Exports, Industrial Area-A
Ludhiana.
6.Monthly income of the Rs.20,000/- to Rs.
deceased. 25,000/- per month.
7.Does the person in respect No.
of whom compensation is
claimed, pay income Tax, if
so state the amount of Income
Tax & Support documentary evidence.
8.Place, date and time of the The accident took
accident. place on ll/03/2023
3
at 09:00 AM at
Samrala Chowk,
Ludhiana.
9.Name & address of the police FIR No. 44 dated
station in whose jurisdiction 15/03/2023, U/s.
accident took place or case 304-A, 279, 337
was registered. 338 , 427 I PC .
P.S. Moti Nagar
Ludhiana.
10.If the person in respect The deceased
of compensation i s claimed, was going to his
travelling by a vehicle work on his Activa
involved in accident? I f so, Scooter bearing
give the names and places of no. PB-10-HX-7627
s t a r t i n g of journey and
destin~tion.
11.Nature of injuries sustained The deceased received
multiple grievous
injuries on his body.
& address of medical Firstly the deceased
12.Name
was taken to Civil
p r a c t i t i o n e r , i f any
Hospital, Ludhiana
attended the injured
and thereafter he
was taken to DMC
4
Hospital,
Ludhiana,
where he
remained
admitted and
treated
till
23/03/2023. After
that the deceased
was
discharged. But due
to
critical
condition, he
was again admitted to
Pancham
Hospital,
Ludhiana on 24/03/2023
where he died on
25/03/2023. His post
mortem was conducted on
25/03/2023 at Civil
Hospital, Ludhiana.
13.Period of treatment and
Approximately Rs. · 40, 000/-
the expenses incurred on
were spent on the
treatment of deceased.
However remaining expenses
of treatment were paid
through Insurance Policy
as well as through ESI.
However Rs. l,50,000/-
was spent on the
cremation and his last
rites ceremonies.
5
14.Registration No. & Type of
Truck/Canter bearing
of motor vehicles involved
registration no.
in the accident.
PB-ll-CB-8199 &
Activa Scooter
bearing no.
PB-10-HX-7627
15.Name & Address of the insurer
Respondent No. 3
of the offending vehicle
,I
16.Has any claim been lodged No
with the owner/insurer, if
so with what results.
17.Name & Address of the Owner As mentioned above.
of the offending vehicle
18.Name & Address of Claimants As mentioned above
19.Relationship with deceased The claimant no.1 is
wife, claimants no.
2 & 3 are children
of the deceased.
20.Title of the property The claimant no. 1 is
of the deceased. wife and claimants no.
2 & 3 are the son &
daughter of deceased.
6
21.Amount of compensation
80 Lacs
cl.aimed
22.Any other information that
The claimants were
may be helpful for the
totally dependent upon
early disposal of the
the deceased
claim petition
The deceased was very
energetic and hardworking
person. But due to
sudden death of deceased,
the claimants have
suffered a huge shock and
unbearable loss.
23. Reasons or grounds for late Within limitation.
submission of the claim
applicable on which condonation
of delay is claimed.
24.Cause of accident with brief On 11/03/2023 at
description. at about 8:30 AM the
deceased alongwith
his son claimant no.2
were going to their
work/factory at
Cheema Chowk on their
separate vehicles.
The deceased was driving his Activa Scooter No. PB-10-
HX-7627 and claimant no. 2 was following him on
7
separate motor cycle no. PB-10-HR-3616. At about
AM 09:oo
when the deceased made turn
from Samrala Chowk to
Cheema Chowk side, then suddenly one
bearing Truck/Canter
no. PB-ll-CB-8199 being driven
by respondent
no. 1 in
a very rashly and negligently came from
side back
in very high speed and hit against the Activa
Scooter
of deceased very forcefully, due to which
the
deceased f e l l down with his vehicle and respodent no. 1
dragged the
deceased on the road through front side
tyre of his canter. After the respondent no. 1
stopped
his
vehicle and ran away from the spot by leaving
the
vehicle
there. Due to the said accident, the deceased
multiple grievous injuries on his body and his l e f t leg
was also fractured. The Activa Scooter of deceased
was
also badly damaged. Thereafter the claimant no. 2
arranged a private vehicle and took the deceas~d to DMC
Hospital, Ludhiana where he remained admitted and
treated till 23/03/2023. After that the deceased was
discharged. But due to critical condition, he was again
admitted to Pancham Hospital, Ludhiana on 24/03/2023
where he died on 25/03/2023. His post mortem was
conducted on 25/03/2023 at Civil Hospital, Ludhiana.
The accident has taken place due to rash and negligent
driving of the respondent no.1.
It is, therefore, prayed that the claim
petition may kindly be accepted and an award of Rs.
80,00,000/- may kindly be granted to the claimants with
costs.
8
It
is, further prayed that the
interest may
also be allowed@
18% per annum from the date of filing
the
claim petition t i l l the actual
realisation of the
award amount.
kctVVlaJ k.1:1 YU. ~l~dl1'CtJ½
' .,:::
Claimant s,
Advocate
Verification:-
Verified that the contents of paras no. 1 to 24 of the
claim petition are true and correct to the best of our
knowledge and belief and information. Last para is
prayer clause, which is also true and corre C t •
Verified at Ludhiana.
k AVVI ,J R"' IJ,t' l---1,1,N- ~"'°~
Joi~f k,,Jtiwu'
on - - - - - /2023 Claimants
