IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
O.S. No: /2023
1. Smt. Muneeswaramma
2. Boya Gopal
3. Boya Venkta Ramudu
4. B. Ramudu - - PLAINTIFFS
- Vs –
1. Kuruva Chinna Ramudu
2. Kuruva Nadipi Ramudu
3. Kuruva Pedda Yellappa - -DEFENDANTS
PLAINT FILED ON BEHALF OF THE PLAINTIFFS UNDER ORDER VII
RULE 1 OF C.P.C.
The Plaintiffs above named humbly beg to state as follows: -
PLAINTIFFS:
1. Smt. Muneeswaramma, W/O, Thalari Siddaiah, aged about 65 years,
Hindu, Agriculturist,
2. Boya Gopal, S/O Chinna Venkanna, aged about 38 years, Hindu,
Agriculturist,
3. Boya Venkata Ramudu, S/O. Pedda Venkanna, aged about 40 years,
Hindu, Agriculturist,
4. B. Ramudu, S/O. Thirupathaiah, aged about 43 years, Hindu,
Agriculturist,
All are residents of ponnakallu village, Gudur mandal, Kurnool
district.
The above are the addresses of the Plaintiffs for service of all
processes on them, and that of his Counsel is M.D.V. Jogaiah Sarma,
Advocate, Kurnool.
(2) DEFENDANTS:
(1) Kuruva Chinna Ramudu, S/O Kuruva Thippanna (Late), aged about 45
years, Hindu, Agriculturist,
(2) Kuruva Nadipi Ramudu, S/O Kuruva Thippanna (Late), aged about 47
years, Hindu, Agriculturist,
(3) Kuruva Pedda Yellappa, S/O. Kuruva Thippanna (Late), aged about 70
years, Hindu, Agriculturist,
All are residents of ponnakallu village, Gudur mandal, Kurnool district.
(3) Late Sunkulamma W/o Thalari Gopanna and Late Goruku
Rangamma W/o Kattubadi Timmappa were the absolute owners of the Suit
Schedule land, they having purchased the same from its then rightful
owners Putturu Dibbanna S/O Timmanna and Venkata Giriramakka W/O
Giddayya, for valuable consideration, under the Registered Sale deed
dated 07-06-1962 (Doc.No.874/1962). The Plaintiffs are herewith filing the
said Original Registered Sale deed dated 07-06-1962 (Doc.No.874/1962)
for the kind consideration of this Hon’ble Court. The said two purchasers
had jointly enjoyed the Suit Scheduled land during their lifetime and their
names were also mutated in the revenue records in respect of the Suit
Schedule land. After the demise of the said two purchasers, the plaintiffs,
who are their successors had continued to enjoy the suit schedule land as
per their convenience, and they have got their names mutated in the
revenue records. The Revenue authorities have also issued Pattadhar
Passbooks and Title deeds in favour of the plaintiffs herein, showing the
respective portions of the suit schedule property, mutated in their names.
The plaintiffs are herewith filing the xerox copies of the Pattadhar
Passbooks and Title deeds of the respective plaintiffs (as their originals
are required for the day-to-day enjoyment of the Suit Schedule property),
along with the IB register Extracts, and also the Adangal Extracts for the
kind appreciation of this Hon’ble Court. Ever since the date of their
purchase, the Predecessors of the Plaintiffs and after their demise the
Plaintiffs alone had been in peaceful physical possession and enjoyment
the Suit Schedule land openly, and to the knowledge of the entire world
includes the Defendants herein. As such, the Defendants have no right,
title, or possession of any nature over the suit schedule land.
(4) Being so, due to the steep hike in the market value of the suit
schedule land, the Defendants had developed a concealed evil intention of
the knocking away the suit land from the Plaintiffs, by taking advantage of
the innocence, and ignorance of the Plaintiffs. With the said malafide
intention, the Defendants along with their highhanded henchmen had
made a sudden attempt to highhandedly trespass in to the suit schedule
land, Yesterday, i.e.., 08-11-2023, at about 10 am, when the Plaintiffs
were getting their land ploughed, to make it ready for next sowing season.
But however, the Plaintiffs, with great difficulty, and with the help of the
persons gathered at that time, Boya Linganna, S/O Boya Lodda Sunkanna
and Kuruva Gouranna S/O Kuruva Yellappa, could prevent the Defendants
from proceeding further with their forceful acts. However, even though
the Defendants had temporarily retreated from the schedule land, they
had posted an open threat that they would make fresh attempts with
more muscle men, and with the Political support and somehow dispossess
the Plaintiffs from the schedule land, and that nobody on this earth could
protect their possession over the schedule land. The Plaintiffs humbly
submit that they being a poor and helpless citizens and rustic villagers,
cannot protect their possession against the mighty Defendants. Since the
Defendants are bent upon, trespassing the Suit Schedule property and
dispossess the Plaintiffs from the Suit Schedule land, the Plaintiffs are
advised to file this suit, seeking declaration of their title over the suit
schedule land, also the consequential relief of Permanent Injunction
Hence this suit.
(5) The cause of action for this suit arose on 07-06-1962, the date of
purchase of the Suit Schedule land, by the predecessors of the Plaintiffs,
for valuable consideration from its rightful owners, and on 08-11-2023,
when the Defendants herein, suddenly came upon the Suit Schedule land,
along with their highhanded henchmen, and attempted to forcibly
trespass and dispossess the Plaintiffs therefrom, at ponnakallu village,
Gudur mandal, Kurnool district, within the territorial and pecuniary limits
of this Hon’ble court, and hence this Hon’ble court has got jurisdiction to
entertain this suit.
(6) Since the Defendants are bent upon to repeat similar highhanded
attempts to trespass in to and interfere with the peaceful physical
possession of the Plaintiffs over the Suit Schedule land, even during the
pendency of the above suit, the Plaintiffs are advised to file a separate
petition seeking Interim Orders of Injunction against the Defendants.
(7) This suit is valued at Rs. __________/- for the purpose of Court Fees
and jurisdiction, and a Court Fees of Rs. __________/- is payable and is paid
under Sec. 24 (__) of the A.P. Court Fees and Suits Valuation Act.
(8) PARTICULARS OF CLAIM:
Market Value of the Suit Schedule land . -- Rs. ________
½ of the Market Value. - - Rs. _________
-----------------
Total - - Rs.
-----------------
The Plaintiffs therefore pray that the Hon’ble court may be pleased
to pass a Decree and Judgment, in their favour and against the
Defendants:
(a) granting the relief of Declaration of their title over the Suit Schedule
land;
(b) granting the consequential relief of Permanent Injunction restraining
the Defendants, their men, agents, successors, or anybody on their
behalf, from trespassing in to and highhandedly interfering with the
peaceful physical possession and enjoyment of the Plaintiffs over the Suit
Schedule land;
(c) granting costs of the Suit; and
(d) granting such other and further reliefs this Hon’ble Court deems fit and
proper in the circumstances of the case.
SCHEDULE
The Agricultural land of an extent of Ac. 2-50 Cents out of Ac. 10-80
Cents located in S. No. 151 of Ponnakallu village limits, Gudur Mandal,
Kurnool District, Gudur S.D. Kurnool R.D.,
Bounded on :
East – by the land of Kuruva Mallanna;
West – by Vanka;
North – by Vanka; and
South – by the Land of Kuruva Edanna.
. (1)
(2)
(3)
(4)
ADVOCATE FOR PLAINTIFFS PLAINTIFF
We, the Plaintiffs abovenamed, do hereby declare that what is
stated herein above is true to the best of our knowledge, information, and
belief, and signed on this the day of June, 2023, at Kurnool.
(1)
(2)
(3)
(4)
PLAINTIFF
LIST OF DOCUMENTS
(1) Original Registered Sale deed dated 07-06-1962 (Doc.No.874/1962) (2)
Copies of Pattadar Passbooks and Title deeds ( No’s).
(3) I-B Register Extracts ( no’s)
(4) Adangal Extracts for the
(5) Valuation Certificate
ADVOCATE FOR PLAINTIFFS
IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
O.S. No: /2023
1. Smt. Muneeswaramma
2. Boya Gopal
3. Boya Venkta Ramudu
4. B. Ramudu - - PLAINTIFFS
- Vs –
1. Kuruva Chinna Ramudu
2. Kuruva Nadipi Ramudu
3. Kuruva Pedda Yellappa - -DEFENDANTS
PROOF AFFIDAVIT OF THE PLAINTIFF
I, Smt. Muneeswaramma, W/O, Thalari Siddaiah, aged about 65
years, Hindu, Agriculturist, resident of ponnakallu village, Gudur
mandal, Kurnool district., dohereby solemnly affirm and sincerely
state as follows: -
(1) I am the Plaintiff in the above suit. I know the facts of the case.
(2) I am the absolute owner of the Plaint Schedule land, after the demise
of my predecessors, who have purchased the same from its then rightful
owners Putturu Dibbanna S/O Timmanna and Venkata Giriramakka W/O
Giddayya, for valuable consideration, under the Registered Sale deed
dated 07-06-1962 (Doc.No.874/1962) which is filed for the kind
consideration of this Hon’ble Court. The said two purchasers had jointly
enjoyed the Suit Scheduled land during their lifetime and their names
were also mutated in the revenue records in respect of the Suit Schedule
land. After the demise of the said two purchasers, I, being one of the
successors had continued to enjoy the suit schedule land as per my
convenience and have got my name mutated in the revenue records. The
Revenue authorities have also issued Pattadhar Passbooks and Title deeds
in my favour, showing the respective portions of the suit schedule
property, mutated in my name. The xerox copies of the Pattadhar
Passbook and Title deeds (as the originals are required for the day-to-day
enjoyment of the Suit Schedule property) along with IB register Extracts,
and the Adangal Extracts have been filed for the kind consideration of this
Hon’ble Court. Ever since the date of their purchase, our Predecessors and
after their demise, I, along with other Plaintiffs, alone had been in peaceful
physical possession and enjoyment the Suit Schedule land openly, and to
the knowledge of the entire world includes the Defendants herein. As
such, the Defendants have no right, title, or possession of any nature over
the suit schedule land.
(3) Being so, due to the steep hike in the market value of the suit
schedule land, the Defendants had developed a concealed evil intention of
the knocking away the suit land from me, by taking advantage of my
innocence, and ignorance. With the said malafide intention, the
Defendants along with their highhanded henchmen had made a sudden
attempt to highhandedly trespass in to the suit schedule land, Yesterday,
i.e.., 08-11-2023, at about 10 am, when I was getting the land ploughed,
to make it ready for next sowing season. But however, with great
difficulty, I, along with the help of the persons gathered at that time, Boya
Linganna, S/O Boya Lodda Sunkanna and Kuruva Gouranna S/O Kuruva
Yellappa, could prevent the Defendants from proceeding further with
their forceful acts. However, even though the Defendants had temporarily
retreated from the schedule land, they had posted an open threat that
they would make fresh attempts with more muscle men, and with the
Political support and somehow dispossess me from the schedule land, and
that nobody on this earth could protect their possession over the schedule
land. I humbly submit that I being a poor and helpless senior citizen and
rustic villager, cannot protect my possession against the mighty
Defendants. Since the Defendants are bent upon, trespassing the Suit
Schedule property and dispossess me from the Suit Schedule land, I am
advised to file this suit, seeking declaration of their title over the suit
schedule land, also the consequential relief of Permanent Injunction
Hence this suit.
(4)The cause of action for this suit arose on 07-06-1962, the date of
purchase of the Suit Schedule land, by m predecessors, for valuable
consideration from its rightful owners, and on 08-11-2023, when the
Defendants herein, suddenly came upon the Suit Schedule land, along
with their highhanded henchmen, and attempted to forcibly trespass and
dispossess me therefrom, at ponnakallu village, Gudur mandal, Kurnool
district, within the territorial and pecuniary limits of this Hon’ble court,
and hence this Hon’ble court has got jurisdiction to entertain this suit.
(5) Since the Defendants are bent upon to repeat similar highhanded
attempts to trespass in to and interfere with the peaceful physical
possession of the Plaintiffs over the Suit Schedule land, even during the
pendency of the above suit, the Plaintiffs are advised to file a separate
petition seeking Interim Orders of Injunction against the Defendants.
It is therefore just and necessary that this Hon’ble court may be pleased
to pass a Decree and Judgment, in my favour and against the Defendants,
granting the relief of Declaration of my title over the Suit Schedule site,
granting the consequential relief of Permanent Injunction restraining the
Defendants, their men, agents, successors, or anybody on their behalf,
from trespassing in to and highhandedly interfering with my peaceful
physical possession and enjoyment over the Suit Schedule land, granting
costs of the Suit, and granting such other and further reliefs this Hon’ble
Court deems fit and proper in the circumstances of the case. Else, I stand
to suffer great loss and hardship.
Solemnly affirmed and signed herein
after the contents read over and
agreed to be true on this the day
of June, 2023 at Kurnool. DEPONENT
BEFORE ME,
ADVOCATE, KURNOOL
IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
I.A.No. /2023 IN O.S. No: /2023
1. Smt. Muneeswaramma
2. Boya Gopal
3. Boya Venkta Ramudu
4. B. Ramudu - -PETITIONER/PLAINTIFF
- Vs –
1. Kuruva Chinna Ramudu
2. Kuruva Nadipi Ramudu
3. Kuruva Pedda Yellappa - -RESPONDENTS/DEFENDANTS
AFFIDAVIT OF THE PETITIONER/PLAINTIFF
I, Smt. Muneeswaramma, W/O, Thalari Siddaiah,
aged about 65 years, Hindu, Agriculturist, resident of ponnakallu
village, Gudur mandal, Kurnool district., dohereby solemnly affirm
and sincerely state as follows: -
(1) I am the Plaintiff in the above suit. I know the facts of the case.
(2) I am the absolute owner of the Plaint Schedule land, after the demise
of my predecessors, who have purchased the same from its then rightful
owners Putturu Dibbanna S/O Timmanna and Venkata Giriramakka W/O
Giddayya, for valuable consideration, under the Registered Sale deed
dated 07-06-1962 (Doc.No.874/1962) which is filed for the kind
consideration of this Hon’ble Court. The said two purchasers had jointly
enjoyed the Suit Scheduled land during their lifetime and their names
were also mutated in the revenue records in respect of the Suit Schedule
land. After the demise of the said two purchasers, I, being one of the
successors had continued to enjoy the suit schedule land as per my
convenience and have got my name mutated in the revenue records. The
Revenue authorities have also issued Pattadhar Passbooks and Title deeds
in my favour, showing the respective portions of the suit schedule
property, mutated in my name. The xerox copies of the Pattadhar
Passbook and Title deeds (as the originals are required for the day-to-day
enjoyment of the Suit Schedule property) along with IB register Extracts,
and the Adangal Extracts have been filed for the kind consideration of this
Hon’ble Court. Ever since the date of their purchase, our Predecessors and
after their demise, I, along with other Plaintiffs, alone had been in peaceful
physical possession and enjoyment the Suit Schedule land openly, and to
the knowledge of the entire world includes the Defendants herein. As
such, the Defendants have no right, title, or possession of any nature over
the suit schedule land.
(3) Being so, due to the steep hike in the market value of the suit
schedule land, the Defendants had developed a concealed evil intention of
the knocking away the suit land from me, by taking advantage of my
innocence, and ignorance. With the said malafide intention, the
Defendants along with their highhanded henchmen had made a sudden
attempt to highhandedly trespass in to the suit schedule land, Yesterday,
i.e.., 08-11-2023, at about 10 am, when I was getting the land ploughed,
to make it ready for next sowing season. But however, with great
difficulty, I, along with the help of the persons gathered at that time, Boya
Linganna, S/O Boya Lodda Sunkanna and Kuruva Gouranna S/O Kuruva
Yellappa, could prevent the Defendants from proceeding further with
their forceful acts. However, even though the Defendants had temporarily
retreated from the schedule land, they had posted an open threat that
they would make fresh attempts with more muscle men, and with the
Political support and somehow dispossess me from the schedule land, and
that nobody on this earth could protect their possession over the schedule
land. I humbly submit that I being a poor and helpless senior citizen and
rustic villager, cannot protect my possession against the mighty
Defendants. Since the Defendants are bent upon, trespassing the Suit
Schedule property and dispossess me from the Suit Schedule land, I am
advised to file this suit, seeking declaration of their title over the suit
schedule land, also the consequential relief of Permanent Injunction
Hence this suit.
(4)The cause of action for this suit arose on 07-06-1962, the date of
purchase of the Suit Schedule land, by m predecessors, for valuable
consideration from its rightful owners, and on 08-11-2023, when the
Defendants herein, suddenly came upon the Suit Schedule land, along
with their highhanded henchmen, and attempted to forcibly trespass and
dispossess me therefrom, at ponnakallu village, Gudur mandal, Kurnool
district, within the territorial and pecuniary limits of this Hon’ble court,
and hence this Hon’ble court has got jurisdiction to entertain this suit.
(5) Since the Defendants are bent upon to repeat similar highhanded
attempts to trespass in to and interfere with the peaceful physical
possession of the Plaintiffs over the Suit Schedule land, even during the
pendency of the above suit, the Plaintiffs are advised to file a separate
petition seeking Interim Orders of Injunction against the Defendants.
It is therefore just and necessary that the Hon’ble court may be pleased to
grant the relief of Interim Injunction restraining the
Respondents/Defendants, their men, agents, successors, or
anybody on their behalf, from trespassing in to or in any way,
highhandedly interfering with my peaceful physical possession
and enjoyment over the Petition Schedule land, during the
pendency of the above suit. Else, I stand to suffer great loss and
hardship.,
Solemnly affirmed and signed herein
after the contents read over and
agreed to be true on this the day
of June, 2023 at Kurnool. DEPONENT
BEFORE ME,
ADVOCATE, KURNOOL
IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
I.A.No. /2023 IN O.S. No: /2023
(1) Smt. Muneeswaramma, W/O, Thalari Siddaiah, aged about 65 years,
Hindu, Agriculturist, resident of ponnakallu village, Gudur mandal, Kurnool
district
(2) Boya Gopal, S/O Chinna Venkanna, aged about 38 years, Hindu,
Agriculturist, resident of ponnakallu village, Gudur mandal, Kurnool district
(3) Boya Venkata Ramudu, S/O. Pedda Venkanna, aged about 40 years,
Hindu, Agriculturist, resident of ponnakallu village, Gudur mandal, Kurnool
district
(4) B. Ramudu, S/O. Thirupathaiah, aged about 43 years, Hindu,
Agriculturist, resident of ponnakallu village, Gudur mandal, Kurnool
district.
-- PETITIONER/PLAINTIFF
- Vs –
(1)Kuruva Chinna Ramudu, S/O Kuruva Thippanna (Late), aged about 45
years, Hindu, Agriculturist, resident of ponnakallu village, Gudur mandal,
Kurnool district.
(2) Kuruva Nadipi Ramudu, S/O Kuruva Thippanna (Late), aged about 47
years, Hindu, Agriculturist, resident of ponnakallu village, Gudur mandal,
Kurnool district.
(3) Kuruva Pedda Yellappa, S/O. Kuruva Thippanna (Late), aged about 70
years, Hindu, Agriculturist, resident of ponnakallu village, Gudur mandal,
Kurnool district.
- -RESPONDENTS/DEFENDANTS
PETITION FILED ON BEHALF OF THE PETITIONER/PLAINTIFF UNDER
ORDER XXXIX RULE 1 AND 2 AND SEC. 151 OF C.P.C.
For the reasons stated in the accompanying Affidavit the Petitioner/
Plaintiff prays that the Hon'ble Court may be pleased to grant the relief
of Interim Injunction restraining the Respondents/Defendants,
their men, agents, successors, or anybody on their behalf, from
trespassing in to or in any way, highhandedly interfering with my
peaceful physical possession and enjoyment over the Petition
Schedule land, during the pendency of the above suit, in the
interests of justice.
ADVOCATE FOR PETITIONER/
PLAINTIFF
SCHEDULE
The Agricultural land of an extent of Ac. 2-50 Cents out of Ac. 10-80 Cents
located in S. No. 151 of Ponnakallu village limits, Gudur Mandal, Kurnool
District, Gudur S.D. Kurnool R.D.,
Bounded on :
East – by the land of Kuruva Mallanna;
West – by Vanka;
North – by Vanka; and
South – by the Land of Kuruva Edanna.
ADVOCATE FOR PETITIONER/
PLAINTIFF
IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
I.A.No. /2023 IN O.S. No: /2023
1. Smt. Muneeswaramma
2. Boya Gopal
3. Boya Venkta Ramudu
4. B. Ramudu - -PETITIONER/PLAINTIFF
- Vs –
1. Kuruva Chinna Ramudu
2. Kuruva Nadipi Ramudu
3. Kuruva Pedda Yellappa - -RESPONDENTS/DEFENDANTS
PETITION FILED ON BEHALF OF THE PETITIONER/PLAINTIFF
UNDER RULE 57 OF THE A.P. CIVIL RULES OF PRACTICE
For the reasons stated in the accompanying Affidavit, the Petitioner/
Plaintiff prays that the Hon’ble court may be pleased to receive the
accompanying Suit and Petition Out of order and number the same, in the
interests of justice.
ADVOCATE FOR PETITIONER/
PLAINTIFF
IN THE COURT OF HON’BLE Junior Civil Judge, KURNOOL
I.A.No. /2023 IN O.S. No: /2023
1. Smt. Muneeswaramma
2. Boya Gopal
3. Boya Venkta Ramudu
4. B. Ramudu - -PETITIONER/PLAINTIFF
- Vs –
1. Kuruva Chinna Ramudu
2. Kuruva Nadipi Ramudu
Kuruva Pedda Yellappa - -RESPONDENTS/DEFENDANTS
VERIFIED SCHEDULE FILED ON BEHALF OF THE PLAINTIFF
SCHEDULE
The Agricultural land of an extent of Ac. 2-50 Cents out of Ac. 10-80 Cents
located in S. No. 151 of Ponnakallu village limits, Gudur Mandal, Kurnool
District, Gudur S.D. Kurnool R.D.,
Bounded on :
East – by the land of Kuruva Mallanna;
West – by Vanka;
North – by Vanka; and
South – by the Land of Kuruva Edanna.
ADVOCATE FOR PLAINTIFF PLAINTIFF
I, the Plaintiff above named, do hereby declare that what is stated
herein above is true to the best of my knowledge, information and belief,
and signed on this the day of June, 2023, at Kurnool.
PLAINTIFF
