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I.A. An Representation

The document is an injunction petition filed by Datla Surya Narayana Raju and Datla Bala Venkata Satyanarayana Raju against the State of Andhra Pradesh and others, seeking to prevent the 5th respondent from alienating certain agricultural lands pending the resolution of their ongoing legal disputes. The petitioners argue that their rights are being threatened by the actions of the 5th respondent, who is attempting to manipulate the situation to their detriment. They request the court to maintain the land in the dispute register until the conclusion of their writ petition and civil suit to avoid injustice.

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0% found this document useful (0 votes)
6 views10 pages

I.A. An Representation

The document is an injunction petition filed by Datla Surya Narayana Raju and Datla Bala Venkata Satyanarayana Raju against the State of Andhra Pradesh and others, seeking to prevent the 5th respondent from alienating certain agricultural lands pending the resolution of their ongoing legal disputes. The petitioners argue that their rights are being threatened by the actions of the 5th respondent, who is attempting to manipulate the situation to their detriment. They request the court to maintain the land in the dispute register until the conclusion of their writ petition and civil suit to avoid injustice.

Uploaded by

borinagaraju
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT

AMARAVATI

I.A.No. of 2025
in

W.P.No. 3164 of 2024


Between:
1) Datla Surya Narayana Raju s/o Datla
Satyanarayana Raju, aged about 76 years
Occ: Business.
2) Datla Bala Venkata Satyanarayana Raju,
s/o Surya Narayana Raju, aged about 54
years, occ: Business
Both are r/o Plot No.257, Road No.6, Kakatiya Hills,
Madhapur, Hyderabad. ..Petitioners
/Petitioners

and

1) The State of Andhra Pradesh, rep. by its


Principal Secretary, Revenue Department
Secretariat, Velagapudi, Amaravati.

2) The District Collector, Eluru District


At Eluru.

3) The Revenue Divisional Officer,


Pedavegi Revenue Division, Eluru District.

4) The Tahsildar, Pedavegi Mandal,


Eluru District.

5) Buddharaju Suryanarayana Raju s/o Late


Seeta Rama Raju, aged about 78 years
Occ: Retired Employee, r/o C-4,
Raj Enclave, Seethammadhara, Behind NRI
Hospital, Visakhapatnam.
..Respondents/Respondents

AFFIDAVIT
I, Datla Surya Narayana Raju s/o Datla Satyanarayana Raju,
aged about 76 years, Occ: Business r/o Plot No.257, Road No.6,
Kakatiya Hills, Madhapur, Hyderabad now having temporarily come
down to Amaravati, do hereby solemnly affirm and sincerely state
on oath as follows:-
-2-
1) I am the 1st petitioner herein and as such I am well acquainted
with the facts of the case. I am authorized to depose to this
affidavit on behalf of the 2nd petitioner herein who is none other than
my brother.

2) I submit that the above Writ Petition has been filed


questioning the action of the respondent authorities in mutating the
name of the 5th respondent in the revenue records as “Pattadar” in
respect of the land in Sy.No. 249-1 admeasuring Ac. 15.05 cents
situated at Munduru village, Pedavegi Mandal, Eluru District, inspite
of the reminder objections submitted by the petitioners dt. 9-9-2023
contrary to the amended provisions of pattadar pass Books Act Act
15 of 2022, as being illegal, arbitrary, unjust, unconstitutional and
violative of Articles 21 and 300-A of the Constitution of India.

3) It is submitted that this Hon’ble Court after hearing the


arguments was pleased to grant interim orders on 8-2-2024 in
I.A.No. 1 of 2024 as under:-

“The Tahsildar concerned is directed to put the subject


property i.e., to an extent of land Ac.15.05 cents in survey
No.249-1 situated at Munduru Village, Pedavegi Mandal, Eluru
District in the dispute register, pending further orders. Post
the matter after summer vacation”.

4) It is submitted that while so, on 7-5-2025 the above matter


was listed for hearing of the counter filed along with the vacate stay
petition but our counsel was not keeping good health, as such he
could not represent the said matter as a result of which the interim
order granted on 8-2-2024 is vacated. While so, we came to know
that the 5th respondent under the guise of the orers passed on 7-5-
2025 are pressurizing the respondent authorities to delete the
subject property from the dispute register and thereby to

-3-

alienate the same to the third parties. As stated above, the suit
O.S.No. 216 of 2017 and the above writ petition are still pending
adjudication and at this juncture if the 5 th responent herein succeeds
in his attempts, the pending legal proceedings will be defeated and
manifest injustice will be caused to us and the ends of justice too
would suffer.

5) Thereore, it is prayed that this Hon’ble Court may be pleased


to pass grant injunction restraining the 5 th responent from alienating
or creating any charge over the subject property i.e., agricultural
lands in Sy.No. 249-1 admeasuring Ac. 15.05 cents situated at
Munduru village, Pedavegi Mandal, Eluru District, pending disposal
of the W.P.No. 3164 of 2024 and the suit O.S.No. 216 of 2017 on the
file of the on the file of the Principal enior Civil Judge, Eluru, and to
pass such other order or orders as this Hon’ble Court deems fit and
proper in the circumstances of the case.
Sworn and signed before me on
this the day of June, 2025
at Amaravati. DEPONENT

Advocate/Hyderabad

VERIFICATION STATEMENT

I, Datla Surya Narayana Raju s/o Datla Satyanarayana Raju,


aged about 76 years, Occ: Business r/o Plot No.257, Road No.6,
Kakatiya Hills, Madhapur, Hyderabad, do hereby declare that what
has been stated in the above paras are true and correct to the best
of my knowledge and belief and also based on legal advice given to
me.
Verified at Amaravati on this the day of June, 2025.

ADVOCATE DEPONENT

Memorandum of Writ Petition Misc. Petition

(Under Order 39 Rules 1 & 2 of C.P.C.).

IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT


AMARAVATI

I.A.No. of 2025
in

W.P.No. 3164 of 2024


Between:
1) Datla Surya Narayana Raju s/o Datla
Satyanarayana Raju, aged about 76 years
Occ: Business.
2) Datla Bala Venkata Satyanarayana Raju,
s/o Surya Narayana Raju, aged about 54
years, occ: Business
Both are r/o Plot No.257, Road No.6, Kakatiya Hills,
Madhapur, Hyderabad. ..Petitioners
/Petitioners

and

1) The State of Andhra Pradesh, rep. by its


Principal Secretary, Revenue Department
Secretariat, Velagapudi, Amaravati.

2) The District Collector, Eluru District


At Eluru.

3) The Revenue Divisional Officer,


Pedavegi Revenue Division, Eluru District.

4) The Tahsildar, Pedavegi Mandal,


Eluru District.

5) Buddharaju Suryanarayana Raju s/o Late


Seeta Rama Raju, aged about 78 years
Occ: Retired Employee, r/o C-4,
Raj Enclave, Seethammadhara, Behind NRI
Hospital, Visakhapatnam.
..Respondents/Respondents

-2-

For the reasons stated in the accompanying affidavit, it is

prayed that this Hon’ble Court may be pleased to pass grant

injunction restraining the 5th responent from alienating or creating

any charge over the subject property i.e., agricultural lands in

Sy.No. 249-1 admeasuring Ac. 15.05 cents situated at Munduru

village, Pedavegi Mandal, Eluru District, pending disposal of the

W.P.No. 3164 of 2024 and the suit O.S.No. 216 of 2017 on the file of

the on the file of the Principal enior Civil Judge, Eluru, and to pass

such other order or orders as this Hon’ble Court deems fit and

proper in the circumstances of the case.

AMARAVATI
Dated: COUNSEL FOR
PETITIONERS
WEST GODAVARI DISTRICT

IN THE HIGH COURT FOR THE


STATE OF ANDHRA PRADESH AT
AMARAVATI

I.A.No. of 2025

in

W.P.No. 3164 of 2024

INJUNCTION PETITION
Filed by:

K.Shrikanth Reddy (18618)

Advocate

COUNSEL FOR THE


PETITIONERS

From: Dated: 29-5-2025

1) Datla Surya Narayana Raju s/o Datla


Satyanarayana Raju,

2) Datla Bala Venkata Satyanarayana Raju,


s/o Surya Narayana Raju,

Both are r/o Plot No.257, Road No.6, Kakatiya Hills,


Madhapur, Hyderabad.

To:

1) The District Collector,


Eluru District.

2) The District Registrar,


Registration & Stamps,
Eluru District.

3) The Sub-Registrar,
Narsapur, West Godavari District.

Respected Sirs

Sub:- Requesting to continue the land in Sy.No. 249-1


admeasuring Ac.
15.05 cents situated at Munduru village, Pedavegi
Mandal, Eluru
District in the dispute register in view of the pendency of
the
civil suit bearing O.S.No. 216 of 2017 on the file of the
Principal
Senior Civil Judge, Eluru – Regarding.

----

We, the undersigned submit the following few lines for your
kind consideration and favourble action.

We beg to state that we are the absolute owners and


possessors of the agricultural lands admeasuring Ac. 41.05 cents
situated at Munduru village, Pedavegi Mandal, Eluru District. The
land admeasuring ac. 35.42 cents is in R.S.No. 249/1 and an extent
of Ac. 5.63 cents is in R.S.No. 310 and total extent is Ac. 41.05 cents
wherein palmoil garden and paddy crops are

-2-

existing and the entire land admeasuring Ac. 41.05 cents is covered
with fencing. The revenue officials issued the pattadar pass books
and title deeds on the names of the petitioners and they are in
peaceful possession and enjoyment without any interruption or
interference from anybody else.

While that being so, one Buddharaju Suryanarayana Raju s/o


Late Seeta Rama Raju, created a false agreement in his name and
basing on the said fabricated and forged agreement filed suit
O.S.No. 112 of 2010 on the file of the Special Judge for Trial of Cses
undr SCs and STs (POA) Act,-cum-VII Addl. District Judge, Eluru,
W.G.District seeking the relief of Specific Performance of Agreement
of Sale against us by showing our wrong address and managed to
obtain exparte decree against us and basing on the said exparte
decree passed in O.S.No. 112 of 2010, he obtained the Sale Deed on
21-11-2016. Having come to know of the same, we have filed
necessary petitions and the same are pending for consideration.
We, state that when the said person aused interference with
our possession and enjoyment, we have filed suit O.S.No. 216 of
2017 on the file of the Principal Senior Civil Judge, Eluru, seeking the
relief of perpetual injunction, wherein ad-interim injunction orders
are granted in I.A.No. 1025 of 2017 till 27-11-2017. While that
being so, the above said persons basing on the sale deed by
influencing the authorities concerned succeeded to get his name
incorporated in the revenue records inspite of the objections filed by
us. Having no other alternative remedy, we moved the Hon’ble
High Court of A.P., by filing W.P.No. 3164 of 2024 wherein the
Hon’ble High Court granted interim oders on 8-2-2024 directing the
Tahsildar to put the subject property in the dispute register, but
later on 7-5-2025 the Hon’ble High Court of A.P., vacated the interim
order in our absence and posted the W.P.No.3164 of 2024 after
summer vacation.
-3-

Now we reliably learnt that the said person under the guise of
the orders dt. 7.5.2025 is trying to get the subject property deleted
from the dispute register by suppressing the factum of pendency of
the legal proceedings. As stated above, the suit O.S.No. 216 of
2017 on the file of the Principal Senior Civil Judge, Eluru, filed by us
for grant of perpetual injunction is pending and even the W.P.No.
3164 of 2024 wherein the interim orders vacated is also pending for
adjudication. At this juncture, if the subject property is deleted from
the dispute register, the purpose of the pending legal proceedings
would be defeated and multiplicity of litigation would arise.

In view of the above, we humbly request your kind authorities


not to delete the subject property i.e., agricultural lands
admeasuring Ac. 41.05 cents situated at Munduru village, Pedavegi
Mandal, Eluru District, from the dispute register till disposal of the
suit O.S.No. 216 of 2017 pending on the file of the Principal Senior
Civil Judge, Eluru and W.P.No. 3164 of 2024 on the file of the
Hon’ble High Court of A.P., to meet the ends of justice.

Thanking you Sirs,

Yours faithfully

(Datla Surya Narayana Raju)

(Datla Bala Venkata Satyanarayana


Raju)

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