IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE
:: AT KHAMMAM
I.A No. of 2026
IN
O.S. No. OF 2026
Between:-
Mettu Rajesh … Petitioner/Plaintiff
And
1. Mettu Nagamma
2. The Tahsildar, Tirumalayapalem Mandal, …Respondents/Defendants
AFFIDAVIT
I, Mettu Rajesh, S/o. Saidulu, Age: 42 years, Occu: Agril, R/o. Sublaid village,
Tirumalayapalem Mandal, Khammam District, and representing the same, do hereby
solemnly and sincerely affirm and state on oath as under
1. I am the Petitioner herein and Petitioner/Plaintiff/Petitioner in the Petition and as
such I am well acquainted with the facts of the case.
2. I submit that, I am the only son of Respondent No.1/Defendant No.1 and late
Saidulu. Respondent No.2/Defendant No.2 is the Tahsildar cum joint sub Registrar
of Tirumalayapalem Mandal, Khammam District.
3. I submit that, I have an agriculture land an extent of Ac. 0.34 Gts. Situated at
Sublaid Revenue Village, Thirumalayapalem Mandal, Khammam District in and out
survey No. 488/అ3. That the property is acquired from my Grand Father Late
Veeramallu through oral Partition. That, late Veeramallu purchased an extent of
Ac.1.28 Gts, From one Maramraju Seetharama Rao, through sadhabynama. Since
then late Veeramallu is in peaceful possession and enjoyment of the property i.e.,
1978. Since the date of purchase, the grandfather of me, Veeramallu have been in
peaceful possession and enjoyment of the said Property.
4. I submit that, the family disputes arise in late Veeramallu elder son by name
Saidulu family (i.e., father of Petitioner/Plaintiff). Late Saidulu and his wife Nagamma
departed each other with family disputes. During the life time of late Veeramallu and
Village elders tried to settle the issue. But in vein. Late Veeramallu vexed with the
attitude of elder son attitude and his wife respondent No.1/defendant No.1 herein.
Late Veeramallu suffered from old age ailments. As such he would like to partition
his property. Late Veeramallu having two sons and one daughter. Late Mettu
Veeramallu having two sons by name Saidulu and Madhar. Late Veeramallu
partitioned afore said land to Me and Younger son Madhar equally an extent of Ac.
0.34 each in the year 2000. As My share is an extent of Ac. 0.34 Gts. It may be read
as 'Petition Schedule Property' for the sake of gravity and convenience. Late Mettu
Veeramallu died on 26-11-2002. Accordingly, my name also entered into the revenue
records as possessor of the schedule property in the year 2005. Since then I am in
peaceful and uninterrupted lawful possession and enjoyment of the property.
5. I submit that the Respondent No.1/Defendant No.1 demanded to give the
share in petition schedule property as she is the wife of late Saidulu, as such she
demanded for share in the petition schedule property. But I and village elders
informed her that the late Veeramallu affect the partition to Me and his elder son
Madhar as his will and wish of his self acquired property.
6. I submit that, I am reflecting in all relevant Revenue records since 2005. I
approached Tahsildar, Respondent No.2/Defendant No.2 herein, to issue pattadhar
pass book and title deed on my name. But Revenue officials ignored my application.
7. I submit that, the Telangana Government introduced Sada Bainama
scheme, registration for small/marginal farmers up to 5 acres and phased
implementations or mutations following through 2017. I applied for mutation
through mee seva. Revenue authorities conducted survey and panchanama. By
taking this as an advantage Respondent No.1/Defendant No.1 file a complaint before
Respondent No.2/Defendant No.2 that she is one of the share holder of petition
schedule property. I and village elders tried to explain the mutation process to
Respondent No.2/Defendant No.2, But the Respondent No.2/Defendant No.2
ignored on the applications of Me.
8. I submit that, Respondent No.1/Defendant No.1 developed greedy eye over the
Petition schedule property. She started the canvases that she has equal share in the
petition schedule property. Respondent No.1/Defendant No.1 kept several efforts to
gain wrongfully.
9. I submit that, I held a panchayath before village elders and caste elders. I
shows my partition agreement and revenue entries on my name. Village elders asked
Respondent No.1/Defendant No.1 to show any documents or any other proof.
Respondent No.1/Defendant No.1 did not show any document. Respondent
No.1/Defendant No.1 tried grabbing the property illegally by the way of blackmailing.
Village elders advised Respondent No.1/Defendant No.1 not to demand share in
petition schedule property.
10. I respectfully submit that the petition schedule property forms part of the self-
acquired property of late Sri Mettu Veeramallu, who had been in lawful possession
and enjoyment thereof since the year 1978 pursuant to a Sada Bainama transaction.
During his lifetime, late Sri Mettu Veeramallu affected an oral family partition in the
year 2000 and allotted the petition schedule property admeasuring Ac.0.34 guntas in
Survey No.488/A3 of Sublaid Revenue Village, Thirumalayapalem Mandal,
Khammam District, exclusively in favour of me. Ever since such allotment, I have
been in open, peaceful, continuous, exclusive and uninterrupted possession and
enjoyment of the petition schedule property as its absolute owner.
11. I further submit that consequent upon the said partition, My name was duly
entered in the revenue records in the year 2005 and has continuously been reflected
therein. I have been cultivating and enjoying the property on my own right without
interruption from any person whatsoever. The revenue entries, possession records,
pahanies and other connected revenue documents unequivocally establish my lawful
possession and enjoyment of the petition schedule property.
12. The Respondent No.1/Defendant No.1 has neither title nor possession over the
petition schedule property and has never been recognized as owner or pattadar
thereof in any revenue record. The claim now being advanced by RespondentNo.1/
Defendant No.1 is wholly baseless, untenable and contrary to the long-standing
revenue records and settled possession of me.
13. I submit that, I am the absolute owner and lawful possessor of the petition
schedule property and is consequently entitled to all proprietary rights, including
issuance of Pattadar Pass Book and Title Deed on my favour. However, owing to
the frivolous and untenable objections raised by Respondent No.1/Defendant
No.1, the revenue authorities have failed to consider and dispose of my
application for mutation and issuance of Pattadar Pass Book.
14. The false claim set up by Respondent No.1/Defendant No.1 has created a cloud
over My lawful title, thereby necessitating the institution of the present petition.
Unless the title and ownership of me is declared by this Hon'ble Court, I will
suffer irreparable loss, hardship and prejudice. Hence, I am constrained to seek a
declaration that I am the absolute owner and title holder of the petition schedule
property and consequential directions to Respondent No.2/Defendant No.2 for
issuance of Pattadar Pass Book and Title Deed in my favour.
15. I respectfully submit that I, being the absolute owner and lawful possessor of
the petition schedule property, made a final representation to Respondent
No.2/Defendant No.2 on 29.09.2025 seeking issuance of Pattadar Pass Book and
Title Deed in my favour. Despite submission of all relevant records and despite
the my repeated requests, Respondent No.2/Defendant No.2 has failed to take
any action or pass any orders on my application. The inaction of Respondent
No.2/Defendant No.2, coupled with the untenable claim set up by Respondent
No.1/Defendant No.1, has cast a cloud over my lawful title and ownership of the
petition schedule property. Consequently, I have been deprived of the revenue
benefits and recognition to which I legally entitled. Having no other efficacious or
alternative remedy available under law, I constrained to approach this Hon'ble
Court seeking a declaration that I am the absolute owner and title holder of the
petition schedule property bearing Survey No.488/A3, situated at Sublaid
Revenue Village, Thirumalayapalem Mandal, Khammam District, together with a
consequential direction to Respondent No.2/Defendant No.2 to issue Pattadar
Pass Book and Title Deed in my favour. Hence, the present suit.
16. I submit that, Prima facie case and balance of convenience are in my
favour and pending disposal of the main Petition. If the ad-interim injunction
is not granted, I would be put to grave and irreparable loss and injury and on
the other hand no prejudice would be caused to Respondents herein.
It is, therefore, prayed that this Hon’ble Court may be pleased to issue ad-
interim injunction in favour of me by restraining the Respondent No.1/Defendants
No.1/ from interfere into the Petition Schedule Property in any manner, till
disposal of the Petition in the interest of justice and equity.
Place: Khammam,
Date: -06-2026. DEPONENT
Attestation: The deponent herein sworn and signed before me, after admitting the
contents of the affidavit are to be true and correct. Hence Attested.
Place: Khammam,
Date: -06-2026. ATTESTOR/ADVOCATE.
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE
:: AT KHAMMAM.
I.A No. of 2026
IN
O.S. No. OF 2026
Between:-
Mettu Rajesh, S/o. Saidulu, Age: 42 years, Occu: Agril, R/o. Sublaid village,
Tirumalayapalem Mandal, Khammam District Mettu Rajesh, S/o. Saidulu, Age: 42
years, Occu: Agril, R/o. Sublaid village, Tirumalayapalem Mandal, Khammam
District … Petitioner/Plaintiff
And
1. Mettu Nagamma W/o. Saidulu late Age: 49 years, Occu: Agril, R/o. Sublaid village,
Tirumalayapalem Mandal, Khammam District.
2. The Tahsildar, Tirumalayapalem Mandal, Khammam District.
……Respondents/Defendants
PETITION FILED UNDER ORDER - 39, RULE-1 & 2,
R/[Link].151 OF C.P.C.
For the reasons set forth in the accompanying Affidavit, it is prayed to the
Hon’ble court may be pleased to issue ad-interim injunction in favour of
Petitioners/Plaintiffs by restraining the Respondent No.1/Defendant No. 1 from
interfere into the Petition Schedule Property in any manner, till disposal of the
Petition in the interest of justice and equity.
Place: Khammam,
Date: -06-2026. Petitioner
Advocate for the Petitioner/Plaintiff
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE
:: AT KHAMMAM
I.A No. of 2026
IN
O.S. No. OF 2026
Between:-
Mettu Rajesh … Petitioner/Plaintiff
And
1. Mettu Nagamma
2. The Tahsildar, Tirumalayapalem Mandal, …Respondents/Defendants
PETITION SCHEDULE PROPERTY
All that the suit scheduled property is Agriculture land an extent of Ac.0.34 Gts in
Survey No.448/అ3,.Situated At Sublaid Village, Thirumalayapalem Mandal,
Khammam District. Which is bounded by Petitioner/Plaintiff:-
East: Land of Gandamalla Narsaiah
West: Land of Kaveti Somaiah
North: Land of Mettu Thirapaiah
South: Land of Gandamalla Radhamma
Place: Khammam,
Date: .06.2026. Petitioner/Plaintiff
VERIFICATION:- I, the Petitioner/Plaintiff herein declare that the above mentioned
contents are true and correct to the best of my knowledge and belief. Hence verified.
Place: Khammam,
Date: .06.2026 . Petitioner/Plaintiff
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE
:: AT KHAMMAM
I.A No. of 2026
IN
O.S. No. OF 2026
Between:-
Mettu Rajesh … Petitioner/Plaintiff
And
1. Mettu Nagamma
2. The Tahsildar, Tirumalayapalem Mandal, …Respondents/Defendants
THIRD PARTY AFFIDAVIT
I, Mettu Anjaneyulu, S/[Link], Age: 52 years, Occ: Pvt. employee, R/o.
Sublaid Village, Thirumalayapalem Mandal, Khammam District., do hereby solemnly
affirm and state on oath as follows:
1. That I am the deponent herein and third party to the above Petition proceedings. I am
the close relative to the family of Respondent No.1 /Defendant No.1 and
petitioner/plaintiff, and I know both the Petitioner/Plaintiff and Respondent
No.1/Defendant No.1 as well as Petition Schedule Property; as such I know the
contents of this affidavit.
2. That, as a part of their conspiracy the Respondent No.1/Defendant No.1 attempted to
disposes the Petitioner/Plaintiff from the Petition Schedule Property on 09.05.2026,
that on the same day myself and other surrounding people asked Respondent
No.1/Defendant No.1 to show the valid documents, but she could not show. I along
with 3 others sent her back, while leaving the place she warned the
Petitioner/Plaintiff, that she will come again and will disposes them either on one day
or other.
3. That, it is clear that the Respondent No.1/Defendant No.1 is trying to interfere into
the Petition Schedule Property.
That the above stated facts are true and correct
Place: Khammam,
Date: -06-2026. Deponent
ATTESTATION: The deponent solemnly sworn and signed before me after admitting
the facts are true and correct. Hence attested.
Place: Khammam,
Date: -06-2026. Attester /Advocate
IN THE COURT OF THE PRINCIPAL
JUNIOR CIVIL JUDGE
:: AT KHAMMAM
I.A No. OF 2026
IN
O.S. No. OF 2026
Between:-
Mettu Rajesh
…Petitioner/Plaintiff
And
1. Mettu Nagamma
2. The Tahsildar, Tirumalayapalem
Mandal,
…Respondents/Defendants
PETITION FILED UNDER ORDER
-39, RULE-1 & 2, R/[Link].151
OF C.P.C.
Filed On: .06.2026.
Filed by :
****************************************
AITAGANI JANARDHAN
ADVOCATE,
KHAMMAM,
Mobile – 9705005658.