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    L. S. GOGIA, Advocate,

    2/20, Nidhi Apartments,

    Shastrinagar, Ahmedabad.

    Before the Honble Motor Accident Claims Tribunal at City Civil Court,

    Ahmedabad.

    M.A.C.P. No. 1054/2005, 1051/05 and 1053/05

    Applicant : Kirti Shivprasad Koshti, and othersdaughter of deceased father Shivprasad Koshti.

    V/s

    Opponent : Iffico Tokio General Insurance Co. Ltd.

    Sub: Permission to file the Certified Copies of the Documents in respect

    of M.A.C.P. NOs. 1054/05, 1051/05 and 1053/05

    In addition to the list of documents already submitted on

    records, I have to submit the following Certified Copies of the Documents

    for the purpose of authentification, which may please be permitted, in the

    interest of justice.

    Ahmedabad. ( L. S. GOGIA )

    Date 23-7-2012. Advocate.

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    L. S. GOGIA, Advocate,

    2/20, Nidhi Apartments,

    Shastrinagar, Ahmedabad.

    Before the Honble Motor Accident Claims Tribunal at City Civil Court,Ahmedabad.

    M.A.C.P. No. 1054/2005, 1051/05

    and 1053/05

    Applicant : Kirti Shivprasad Koshti,

    daughter of deceased father Shivprasad Koshti.

    V/s

    Opponent : Iffco Tokio General Insurance Co. Ltd.

    LIST OF Certified Copies of DOCUMENTS.

    --------------------------------------------------------------------------------------------

    Sl. No. Subject Remarks.

    ------------------------------------------------------------------------Page No.---------

    M.A.CP. NO. 1054/05

    1.. F.I.R. 1-2

    2.. M.L.C. 3-4

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    3.. Death Intimation 5-8

    4.. Panchayatnama Avedan Patra 9-10

    5. Map Panchayatnama 11-12

    6. Handing over Dead Body 13

    7. Apex Hospital Certificate. 14

    8. Short Report of Death. 15

    9. P.M. Report 16- 21

    10. M. L. C Report 22-23

    11. Final Report 24-26

    M.A.C.P. No. 1051/05 ( Ramaben Shivprasad Koshti)

    1. Map Panchnama 1-2

    2. P.M. Report 3-8

    M.A.C.P. No./ 1053/05 ( Hiraben Subashbhai Koshti )

    1. Map Panchnama 1-2

    2. Handing over Dead Body 3

    3. Panchnama of Identification of Dead Body 4

    4. Crime Details form 5-6

    5. Short report of death 7

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    6. P.M. Report 8-13

    -----------------------------------------------------------------------------------------

    Ahmedabad ( L. S. Gogia ).

    Date : 23-7-2012 Advocate.

    L. S. GOGIA, Advocate,

    2/20, Nidhi Apartments,

    Shastrinagar, Ahmedabad.

    Before the Honble Motor Accident Claims Tribunal at City Civil Court,

    Ahmedabad.

    M.A.C.P. No. 1054/2005

    Applicant : Kirti Shivprasad Koshti,

    daughter of deceased father Shivprasad Koshti.

    V/s

    Opponent : Iffco Tokio General Insurance Co. Ltd.

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    There is another alternative method : Take the average of the original

    income added with its doubled amount viz. 12,422/ + 24,844/- =

    37,266/- divided by two which would come to Rs. 18,633/-

    B) There is another Judgment of Sushma Thomas in Para -23 of

    the above cited Judgment in which the contention had been raised by the

    Applicants that the income should be considered by taking the average of

    Pay drawn on the date of death occurred in 1988 and that of the Revised

    Pay raised by Revision of Pay Commission in the year 2005, while the case

    was lying in Appeal in High Court against the Award was passed by the

    Tribunal in 1993 which had been rejected on the basis that revised pay

    which has occurred after the period of 2 decades, can not be considered.

    (C) In our present case, I have to submit that the claimant had

    died in the year 2004 in which he was drawing salary of Rs. 12,422/-

    and then his pay had been revised by 6th Pay Commission from the

    year 2006, immediately after two years from the death of the claimant,

    therefore, it would be just and proper if we take the average of theOriginal salary of Rs. 12,422/- + Revised Salary of Rs. 36,714/- which

    would work out to Rs. 49,146/- divided by 2 = 24,573/-.

    (d) For considering the prospective income, the age has been fixed

    upto 60 years only.

    In summing of all the circumstances, I have to submit that

    there are clear views of the Judgments that the income should be

    considered with regards to the prospective income which means that

    prospective income should be based on the notional income but that means,

    if there is guaranteed income in near future could also be considered as real

    income, and accordingly, the whole income of the revised pay could be

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    taken as income, but however, as we have to follow the principles as

    Rule of Thumb, the income should be taken by taking the average of

    salary drawn added wity salary revised by 6 th Pay Commission would

    be most appropriate method and that way, it would work out to

    Rs. 24,573/- in the interest of justice.

    3. DEDUCTIONS TOWARDS PERSONAL AND LIVING

    EXPENSES:-

    There are guide lines to maintain Uniformity as explained in

    HIGH COURT OF DELHI IN 2009 ACJ 1298 P 1300-

    PARA -14, under Quantum : -

    Where the deceased was married, the deduction towards personal and

    living expenses should be

    One third (1/3rd), where the number of family members is 2 to 3.

    One-fourth (1/4th), where the number of family members is 4 to 6.

    One Fifth (1/5th), where the number of family members exceeds Six.

    In the present case, therefore, the dedufction is to be taken as

    1/3rd only.

    4. MULTIPLIER:- The age of the Deceased was just 45 years and

    odd, as such, the relevant multiplier would be 13.

    5. QUANTUM:-

    Future Loss of Income:

    24,573/- deduct 1/3 = 16,382/ X 12 x 13= 25,55,592-

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    L. S. GOGIA, Advocate,

    2/20, Nidhi Apartments,

    Shastrinagar, Ahmedabad.

    Before the Honble Motor Accident Claims Tribunal at City Civil Court,

    Ahmedabad.

    M.A.C.P. No. 1051/2005

    Applicant : Kirti Shivprasad Koshti,

    daughter of deceased father Shivprasad Koshti.

    V/s

    Opponent : Iffco Tokio General Insurance Co. Ltd.

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    (B) For considering the prospective income, the age has been fixed

    upto 60 years only.

    (C). DEDUCTIONS TOWARDS PERSONAL AND LIVING

    EXPENSES:-

    There are guide lines to maintain Uniformity as explained in

    HIGH COURT OF DELHI IN 2009 ACJ 1298 P 1300-

    PARA -14, under Quantum : -

    Where the deceased was married, generally, the deduction towards

    personal and living expenses should be based on :

    One third (1/3rd), where the number of f amily members is 2 to 3.

    One-fourth (1/4th), where the number of family members is 4 to 6.

    One Fifth (1/5th), where the number of family members exceeds Six.

    (D) With regards to Deductions towards Personal and Living

    Expenses the above case, there is one Judgment viz.

    2011 A CJ 998, envisaging therein the Judgment 2001 ACJ 1735 (S.C)

    which explains that for prospective income, instead of adding and then

    deducting, no deduction be made for the House Wife on account of

    personal expenses but to take the Original Income and hence, the originalincome of Rs.5000/- p.m. may be taken as per the above cited Judgment..

    3. But, In the present case, no deduction may be taken as this pertains

    to the House Wife.

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    4. MULTIPLIER:- The age of the Deceased was 38 years,

    according to which the relevant multiplier would be 16.

    5. QUANTUM:-

    Future Loss of Income:

    Rs. 4500/ X 12 x 16= 8,64,000-

    Loss of Estate / Loss of consortium 50,000-

    Loss of Education/ 50,000-

    Transportation 5,000-

    Funeral expenses 5,000-

    ----------------------------

    Total 9,74,000-

    --------------------------------

    6. It is prayed that the compensation of Rs. 9,74,000/- with the

    interest @ 15% may please be awarded in the interest of justice.

    7. Zerox Copy of the Judgment Judgment viz. -

    2011 A CJ 998, envisaging therein the Judgment 2001 ACJ 1735 (S.C)

    is attached herewith for kind perusal.

    Ahmedabad. ( L. S. GOGIA )

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    The above named Applicant, has to humbly submit his written

    submissions as under:

    1. This matter pertains to the deceased, Hiraben Subashbhai

    Koshti, who died in the vehicular accident due to negligence of the driver

    of the vehicle, the necessary documents of which have been produced

    and exhibited on the records of this Honble Tribunal, as such, the

    involvement of the vehicle has unequivocally been proved. Therefore,

    there remain the issues like - i) Income and the deductions to be made

    therefrom, ii) Age and iii) Multiplier, which are narrated as hereunder.

    2. INCOME : Deceased Hiraben Subashbhai was a House wife,

    whose husband was a Businessman and as she wanted to educate her

    children and maintain the standard of her family, she was helping her

    husband by doing the Accounting and Financing Work by which she

    was earning Rs.5000/- p.m.

    A) Unique Method : Increase the Original Income by adding 50%,

    by which the deceased would get Rs. 5000 + 50% of 5000/- i.e. 2500/

    which would come to Rs. 7500/-.

    OR:

    There is another alternative method : Take the average of the original

    income added with its doubled amount viz. 5000/ + 10,000/- = 15000/-

    divided by two which would come to Rs. 7500/-

    (B) For considering the prospective income, the age has been fixed

    upto 60 years only.

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    (C). DEDUCTIONS TOWARDS PERSONAL AND LIVING

    EXPENSES:-

    There are guide lines to maintain Uniformity as explained in

    HIGH COURT OF DELHI IN 2009 ACJ 1298 P 1300-

    PARA -14, under Quantum : -

    Where the deceased was married, generally, the deduction towards

    personal and living expenses should be based on :

    One third (1/3rd), where the number of f amily members is 2 to 3.

    One-fourth (1/4th), where the number of family members is 4 to 6.

    One Fifth (1/5th), where the number of family members exceeds Six.

    (D) With regards to Deductions towards Personal and Living

    Expenses the above case, there is one Judgment viz.

    2011 A CJ 998, envisaging therein the Judgment 2001 ACJ 1735 (S.C)

    which explains that for prospective income, instead of adding and then

    deducting, no deduction be made for the House Wife on account of

    personal expenses but to take the Original Income and hence, the original

    income of Rs.5000/- p.m. may be taken as per the above cited Judgment..

    3. But, In the present case, no deduction may be taken as this pertainsto the House Wife.

    4. MULTIPLIER:- The age of the Deceased was 34 years,

    according to which the relevent multiplier would be 17.

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    5. QUANTUM:-

    Future Loss of Income:

    Rs. 5000/ X 12 x 17= 10,20,000-

    Loss of Estate / Loss of consortium 50,000-

    Loss of Guardian /Shelter 50,000-

    Transportation 5,000-

    Funeral expenses 5,000-

    ----------------------------

    Total 11,30,000-

    -------------------------------

    6. It is prayed that the compensation of Rs.11,30,000/- with the

    interest @ 15% may please be awarded in the interest of justice.

    7. Zerox Copy of the Judgment Judgment viz. -

    2011 A CJ 998, envisaging therein the Judgment 2001 ACJ 1735 (S.C)

    is attached herewith for kind perusal.

    Ahmedabad. ( L. S. GOGIA )

    Date: 9 7 2012. Advocate of Applicants

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Legal Cell,

    Ahmedabad.

    Subject : Details of the Driving License. Of Bhopalsing G. God.

    File No. ARO/ MTD/INV/ .

    Sir,In the above matter I have received D.L. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the D.L. are as under :

    1. Name of License Holder : Bhopalsing G. God..

    2. License Number of Holder : GJ 01 058149/2008

    3. D.O.I : 19/4/2008.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : MCE5G, LMV, HGV, P.BUS.

    6. Validity : 11/4/2008 TO 18/4/2011.

    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    United India Insurance Co. Ltd.,

    Regional Office.

    Ahmedabad.

    Reference No. 3692. FILE NO : 500800/48/12/07/00000026

    Subject : Bill for Translation From Gujarati to English.

    Sir,

    1. Per page 50 * 8 400/-

    -----------

    Total 400/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 4/12/2012.

    Investigator.

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    T. P. CLIMS HUB,

    Ahmedabad.

    Subject : Details of the Driving License. Of Ramsinh Bhurasinh.

    File No. 210100/31/97/01/98000749. MACP 725/1996

    Sir,

    In the above matter I have received D.L. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the D.L. are as under :

    1. Name of License Holder : Ramsinh Bhurasinh.

    2. License Number of Holder : 433027/AR.

    3. D.O.I : 17/12/1982.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : MMV, HGV AND HPV ONLY

    6. Validity : 1. 17/12/1982 TO 16/12/19852. 18/3/1986 TO 17/3/1998

    3. 6/11/1992 TO 5/11/1995

    4. 4/11/1995 TO 5/11/1998

    5. 23/11/1998 TO 5/11/2001

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,T. P. Claims Hub.

    Ahmedabad.

    Subject : Investigation bill for the D. L. of Meghval Talsaji Dharmaji

    File No. 210100/31/97/01/98000749. MACP NO. 725/1996.

    Sir,

    1. D. L. Verification Fees 350/-

    -----------

    Total 350/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 02/11/2009.

    Investigator.

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,

    Claims Hub,

    Ahmedabad

    Subject : Investigation bill for Theft Claim of Vehicle No. GJ 1 FB 1273

    File No. 1591/2009

    Sir,

    With regards to the above cited investigation case, I have to submit my billfor the said investigation, showing the relevant expenditure incurred for the

    purpose as shown below :

    1. Investigation Fees 2,000/-

    2. Traveling Expenses 550/-

    Local Travelling Expenses

    3. NCRB Report 150/-

    -----------Total 1,700/-

    -------------

    Yours faithfully,

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    ( Jagdish L. Gogia ) Dated : 02/11/2009.

    Investigator.

    Jagdish L. GogiaM/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    T.P. Claims Hub,

    Ahmedabad.

    Subject : Details of the Permit and Fitness of Vehicle No. GJ 1 AU 4015.

    File No. 321/2064

    Sir,

    In the above matter I have received PERMIT AND FITNESS

    for the verification. Regarding this I have visited to the R.T.O. office

    Ahmedabad and collected the certificate and the same details of the Permit

    only because the details of the Fitness was not available in the R.TO. So I

    AM submitting only permit details which is as under :

    1. PERMIT NUMBER : 2005/NP/312.

    2. VEHILCE NUMBER : GJ 01 AU 4015.

    3. VALIDIDY OF PERMIT : 21/5/2010 TO 20/5/2015

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : National Permit

    6. Validity : 21/5/2009 TO 20/05/2010.

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,

    T. P. Claims Hub.Ahmedabad.

    Reference No. 3093. Date of Allo : 29/03/2011 By T.P HUB

    File No. 32/2064.

    Subject : Investigation bill for the Permit of Vehicle No. GJ 1 AU 4015.

    Sir,

    1. Permit Verification Fees 750/-

    -----------

    Total 750/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 07/07/2011.

    Investigator.

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Legal Cell,Ahmedabad.

    Subject : Details of the Permit and R.C Book of Vehicle No.GJ 1 UU 6139.

    File No. ARO/NIAC/PERMIT/FITNESS/08

    Sir,

    In the above matter I have received PERMIT AND FITNESS

    and R.C. BOOK For the verification. Regarding this I have visited to the

    R.T.O. office Ahmedabad and collected the certificate and the same details

    of the Permit AND R. C. Only Where as we have not get the certificate of

    Fitness because the details of the Fitness was not available in the R.TO. So

    I AM submitting only permit and R. C. Book and the details of which is are

    under :

    1. PERMIT NUMBER : 1/AD/1998/GCP/2790.

    2. VEHILCE NUMBER : GJ 01 UU 6139.

    3. VALIDIDY OF PERMIT : 06/8/2003 TO 07/8/2008

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    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : Goods Carriage for Gujarat

    6. Validity : 06/8/2003 TO 07/08/2008.

    7. Owner : Agrawal Radheshyam.

    8. Date of Reg. : 31/7/2008, Model 1998.

    9. Seating capacity : 2 Persons.

    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,

    T. P. Claims Hub.Ahmedabad.

    Reference No. 3093. Date of Allo : 29/03/2011 By T.P HUB

    File No. 32/2064.

    Subject : Investigation bill for the Permit of Vehicle No. GJ 1 AU 4015.

    Sir,

    1. Permit Verification Fees 750/-

    -----------

    Total 750/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 07/07/2011.

    Investigator.

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Legal Cell,

    Ahmedabad.

    Subject : Details of the R. C. Book . Of Vehicle No. GJ 1 UU 6139

    File No. ARO/LC/NIAC/PERMIT/FITNESS/08

    Sir,

    In the above matter I have received R.C. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the R.C. are as under :

    1. Name of Holder : Radheshyam H. Agrawal

    2. R.C BOOF OF : GJ 1 UU 6139

    3. D.O.I : 1998.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : 1998 TO 22/9/2009 and Then

    Transferred to Mehsana R.T.O.

    22/9/2008

    6. ENGINE NUMBER : 282475 AND CHASSIS : 200819

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,United India Insurance Co. Ltd.,

    Regional office.

    Ahmedabad.

    Reference No. 3095. Date of Allo : 04/07/2011 By R.O.

    File No.

    Subject : Investigation bill for Translation from Gujarat to English.

    Sir,

    1. Translation Pages 8 * 40 320/-

    -----------

    Total 320/-

    -------------

    Yours faithfully,

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    ( Jagdish L. Gogia)

    Investigator

    From : JAGDISH L GOGIA

    M/5/32/255, SHASTRINAGAR,

    NARANPURA,

    AHMEDABAD - 380 063.

    ( M ) 98250 56292

    TO,THE MANAGER,

    UNITED INDIA INSURANCE CO. LTD.

    O. D. CLAIMS DEPARTMENT,

    ASHRAM ROAD,

    AHMEDABAD.

    SUBJECT : APPLICATION FOR THE POST OF

    INVESTIGATOR.

    SIR,

    With reference to the subject mentioned above, I have to

    apply for the post of Investigator in your Own Damage Claims

    Department since I am having sufficient knowledge in the line

    based on my qualifications and experience of last 11 years in this

    line. My Bio data for the purpose is enclosed here-under for

    your kind perusal and consideration.

    Thanking You,

    Yours faithfully,

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    ( JAGDISH L. GOGIA )

    INVESTIGATOR

    BIO - DATA

    NAME : JAGDISH L. GOGIA

    DATE OF BIRTH : 16TH JUNE 1968.

    EDUCATIONAL &

    QUALIFICATION : B.COM AND LLB.

    EXPERIENCE : WORKING WITH NEW INDIA

    ASSURANCE COMPANY SINCE

    LAST 11 YEARS AS A

    INVESTIGATOR

    LANGUGES KNOWN: ENGLISH, GUJARAT, SINDHI AND

    HINDI.

    PLACE : AHMEDABAD.

    DATE : 8/7/2011

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,T. P. Claims Hub,

    Ahmedabad.

    Reference No. 3213. Date of Allo : 5/12/2011 By T.P HUB

    Subject : Details of the Fitness and R.C Book of Vehicle

    No.GJ 1 HD 7333. File No. 210100/31/10/01/9800040.

    Sir,

    In the above matter I have received FITNESS and R.C. BOOK

    For the verification. Regarding this I have visited to the R.T.O. office

    Ahmedabad and collected the certificate and the same details of the

    FITNESS AND R. C. Only Where as we have not get the certificate of

    Fitness because the details of the Fitness was not available in the R.TO. So

    I AM submitting only permit and R. C. Book and the details of which is are

    under :

    1. VEHILCE NUMBER : GJ 01 HD 7333.

    2. Issuing R.T.O. : Ahmedabad

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    3. Owner : Devjibhai J. Patel

    8. Date of Reg. : 2003.

    9. Engine Number : 34719.

    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,The New India Assurance Co. Ltd.,

    T. P. Claims Hub.

    Ahmedabad.

    Reference No. 3213. Date of Allo : 5/12/2011 By T.P HUB

    File No. 210100/31/10/01/9800040.

    Subject : Investigation bill for the R. C. Book of Vehicle.

    No. GJ 1 HD 7333

    Sir,

    1. R. C. Verification Fees 500/-

    -----------

    Total 500/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 13/12/2011.

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    Investigator.

    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Legal Cell,

    Ahmedabad.

    Subject : Details of the Driving License. Of Bhagvandatt k. yadav.

    File No. ARO/ MTD/INV/30.

    Sir,

    In the above matter I have received D.L. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the D.L. are as under :

    1. Name of License Holder : Bhagvandatt k. yadav.

    2. License Number of Holder : GJ 01 2005/0110146

    3. D.O.I : 26/8/2011.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : MCE5G, LMVCAB,TRAN S,

    P.BUS AND 3W-NT.

    6. Validity : 26/8/2011 TO 25/8/2014.

    7. Not Valid : 30/6/11 to 24/8/2011

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    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,Legal Cell.

    Ahmedabad.

    Reference No. 3132. Date of Allo : 24/12/2011 By Legal Cell.

    FILE NO : ARO/MTD/INV/30.

    Subject : Investigation bill for the D. L. of Bhagvandatt k. yadav.

    Sir,

    1. D. L. Verification Fees 350/-

    -----------

    Total 350/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 02/01/2012.

    Investigator.

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,Legal Cell,

    Ahmedabad.

    Subject : Details of the R.C Book of Vehicle No .GJ 18 T 9356

    File No. TPHUB CDU 210200 2006 800017/526

    Sir,

    In the above matter I have received R.C. BOOK For the

    verification. Regarding this I have visited to the R.T.O. office Ahmedabad

    and collected the certificate of R. C. Book and the details of which is are

    under :

    1. Name of Owner : Chartred Carries Ltd.

    2. VEHILCE NUMBER : GJ 18 T 9356.

    3. VALIDIDY From : 2003

    4. Issuing R.T.O. : Ahmedabad

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    5. Date of Reg. : 2003.

    6. Seating capacity : 2 Persons.

    7. Engine Number : 62256954

    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,The New India Assurance Co. Ltd.,

    T. P. Claims Hub.

    Ahmedabad.

    Reference No. 3263. Date of Allo. : 28/11/2011 By T.P HUB

    File No. 800017/526

    Subject : Investigation bill for the Permit of Vehicle No. GJ 18 T 9356.

    Sir,

    1. Permit Verification Fees 500/-

    -----------

    Total 500/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 31/01/2012.

    Investigator.

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,

    T. P. Claims Hub.

    Ahmedabad.

    Reference No. 3368. Date of Allo : 28/11/2011 By T.P HUB

    File No. 210200/2006/800017/526.

    Subject : Verification of R. C. Book and Bill of GJ 18 T 9356.

    Sir,

    1. R. C. Verification Fees 750/-

    -----------

    Total 750/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 1/03/2012.

    Investigator.

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,Legal Cell,

    Ahmedabad.

    Subject : R.C Book of Vehicle No.GJ 18 T 9356.

    File No. 210200/2006/800017/526

    Sir,

    In the above matter I have received R.C. BOOK For the

    verification. Regarding this I have visited to the R.T.O. office Ahmedabad

    and collected the certificate and the same details of the R. C. Book and the

    details of which is are under :

    1. Vehicle Owner : Shah Dipesh S.

    2. VEHILCE NUMBER : GJ 01 UU 6139.

    3. VALIDIDY OF PERMIT : 06/8/2003 TO 07/8/2008

    4. Issuing R.T.O. : Ahmedabad

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    5. Valid for : Goods Carriage for Gujarat

    6. Validity : 06/8/2003 TO 07/08/2008.

    7. Owner : Agrawal Radheshyam.

    8. Date of Reg. : 31/7/2008, Model 1998.

    9. Seating capacity : 2 Persons.

    For the above details we are submitting herewith Certificate for the record.

    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Legal Cell,Ahmedabad.

    Subject : Details of the R. C. Book . Of Vehicle No. GJ 1 CD 5250

    File No. TPH/

    Sir,

    In the above matter I have received R.C. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the R.C. are as under :

    1. Name of Holder : Kantibhai Ukabhai Vala

    2. R.C BOOF OF : GJ 1 CD 5350

    3. D.O.I : 2000.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : 8/9/2000 TO 14/9/2003 and Then

    Transferred

    6. ENGINE NUMBER : 06757 AND CHASSIS : 91757

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,T. P. Claims Hub.

    Ahmedabad.

    Reference No. 3383. By T.P HUB

    File No.

    Subject : Verification of R. C. Book and Bill of GJ 1 CD 5250.

    Sir,

    1. R. C. Verification Fees 500/-

    2. Driving License Verification 350/-

    -----------

    Total 850/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 26/03/2012.

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    Investigator.

    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The ManagerThe New India Assurance Co. Ltd.,

    T. P. Claims Hub,

    Ahmedabad.

    Subject : Details of the Driving License. Of Kantibhai Vala.

    File No. 210400/01/98000027.

    Sir,

    In the above matter I have received D.L. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collectedthe certificate and the same details of the D.L. are as under :

    1. Name of License Holder : Kantibhai Vala.

    2. License Number of Holder : GJ 01/011317/2000

    3. D.O.I : 19/8/2000.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : MCEX. 50CC

    6. Validity : 19/8/2000 TO 31/5/2016.

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    T. P. Claims hub,Ahmedabad.

    Subject : Details of the Driving License. Of Viral A. Jhaveri.

    File No. ARO/ TPH/INV/210100/31/04/01/98000177 .

    Sir,

    In the above matter I have received D.L. for the verification.

    Regarding this I have visited to the R.T.O. office Ahmedabad and collected

    the certificate and the same details of the D.L. are as under :

    1. Name of License Holder : Viral Ananatbhai Jhaveri.

    2. License Number of Holder : 99/M/10102.

    3. D.O.I : 29/01/1999.

    4. Issuing R.T.O. : Ahmedabad

    5. Valid for : M/Cycle Only.

    6. Validity : 29/1/1999 TO 28/1/2019.

    For the above details we are submitting herewith Certificate for the record.

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    Yours faithfully,

    ( Jagdish L. Gogia)

    Investigator

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    Jagdish L. Gogia

    Investigator,

    M/5/32/255, Shastrinagar,

    Ahmedabad.

    Mobile No. 98250 56292.

    To,

    The Manager,

    The New India Assurance Co. Ltd.,

    Claims Hub.

    Ahmedabad.

    Reference No. 4002. Date : 25/02/2013

    File No. 210001Claims Hub File Vehicle No. GJ 1 BY 5624.

    Subject : Bill for Translation from Gujarat to English.

    Sir,

    1. Translation Bill ( Pages 20 * 45 ) 900/-

    -----------

    Total 900/-

    -------------

    Yours faithfully,

    ( Jagdish L. Gogia ) Dated : 25/02/2013.

    Investigator.

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    FROM : L. S. Gogia Date : 21/6/2012

    2/20, Nidhi Apartments,

    Shatrinagar,

    Naranpura,

    Ahmedabad.

    To

    The Medical Officer, Date: 5- 7 -2012.

    C.G.H.S. Hospital,Pragatinagar,

    Ahmedabad.

    Subject : Issue of Letter to Shalbi Hospital.

    Sir,

    I have to request you to issue a letter to Shalbi Hospital for

    the Treatment as advised in the case paper attached herewith. Two copies

    of the C. G. H. S card and case papers are enclosed.

    Yours faithfully,

    ( L. S. Gogia )

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    4. TPH/DHK/175 REPORT TO BE PREPARED

    5. TPH/210200/2012/98000010 REPORT TO BE PREPARED

    6. TPH/210100/31/04/01/98000264 DUE TO NON RECIEPT

    OF CRIMINAL

    7. TPH/210601/31/96/01/98000391 DUE TO VERY OLD CASE

    PAPERS ARE NOT AVAILABLE IN THE CRIMNAL COURT.

    8. TPH/ORPHAN/11-12/701 DUE TO OUT STATION

    ACCIDENT PAPERS ARE PEDNING.

    9. TPH/210100/31/05/01/98000018 DUE TO SUMMARY

    FILED CASE PAPERS ARE NOT IN ORDER.

    10. 107160/LC/CCC DUE TO SUMMARY CASE PAPERS

    ARE NOT IN ORDER IN THE COURT

    11.TPH/2012/210600/31/09/02/98000046 ONLY

    CHARGESHEET IS PENDING DUE TO WRONG CHARGE

    SHEET IN THE CRIMINAL PAPERS.

    1. Eight cases are very old and very less chanses to be received

    criminal papers from the criminal court.

    2. Three case papers are ready only report prepared within couple of

    days.

    ( Jagdish L. Gogia)

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    Investigator

    Jagdish L. Gogia

    M/5/32/255, Shastinagar,

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    Naranpura,

    Ahmedabad. 380 063.

    MOBILE NO. 98250 56292.

    To

    The Manager

    The New India Assurance Co. Ltd.,

    Regional Office.

    Ahmedabad.

    Subject : Reply of your email.

    Sir,

    Regarding e. mail dated 5/2/2013, I have to state as under :

    1. I have to state that I have translated all the documents from Gujarati to

    English myself for which I am giving herewith in affirmation and

    confirmation that the translation is done by me, Which may please be

    taken as singed y me by this message.

    2. Regarding your matter of nomination I have to state that all the parties

    of the case are residing out side the Gujarat state as such there being

    no scope of getting the names of the nominees of the claimants I have

    not been able to comply with your requirements.

    Thanking You,

    Yours faithfully,

    ( Jagdish L. Gogia )

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    AFFFIDAVIT

    I, the undersigned, Abdulhak A. Shaikh aged 38 years, Muslim

    by caste, doing thee Job of Business, residing at 570, Noornagar, B/H, Port

    Office, Rakhail, Ahmedabad, do affirm and state on oath as under :

    1 Regarding the quirry as to how the distance between Vapi and

    Ahmedabad has been shown as per meter reading, whereas it is actually 470

    kms, I have to clarify that first I had gone to Jealpur after returning from

    Vapi of repairs where I found no repairers were available there for my

    vehicle and in that trip from Ahmedabad to Jetalpur and back, about 117

    kms were travelled. The Jetalpur repairers told me to go to Sarkhej-Sanand

    Road where the concerned repairers are available. So, thereafter, I had

    gone to Sarkhej-Sanand road for the repairs and in that trip I have travelled

    about 40 Kilometers from Rakhail to Sarkhej as such, return from accident

    place VVapi to Ahmedabad and later on Rakhail to Jetlpur and back Rakhail

    and again from Rakhail to Sarkhej-Sanand Road, the meter has shown the

    reading of 587 Kilo Meters in all.

    2.. The above statement is true as per my personal knowledge and I

    believe the same to be true and correct.

    Solemnly affirmed at Ahmedabad, on 13/3/2013,

    Identified by me, Deponent