“I, Vutukuri Jaya Parvathi, W/o.Lava Kumar, age 45 years, Hindu, house-wife, R/o.Rama Krishna Puram, Chirala, do hereby solemnly affirm and sincerely state as follows: I submit that the plaintiff filed suit for partition against me and others with false allegations. I filed my written statement and contesting the suit. I filed my chief examination as DW.3. In my cross examination I deposed ‘item No.2 of the schedule property was given to me as gift by the defendants 1 to 4 and the mother of 6 to 8”, but wrongly recorded plaintiff also. And I deposed that “2 years after the death of my father the tiled house was collapsed itself”, but wrongly recorded as demolished. A portion of my deposition at M.C.1/2004 was marked as Ex.A.1, but there are some other sentences are also important which is necessary to prove my case. Hence, I request you, please, mark the entire document on my behalf to prove my case. I have got fair chances to succeed in the above suit, under the above circumstances, it is just and necessary to reopen and recall in above suit for the purpose of to give evidence on my side. It is therefore prays that the Hon’ble Court may be pleased to reopen and recall and permit me in the above suit for the purpose to hear on my side, otherwise I will be put irreparable loss.”
