1

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal
MP No: of 2025
Crl. [Link]: of 2025

Between
M/s ICICI Bank Limited
and represented by its authorised signatory Petitioner

AND

Sri Vidhya Sharma Rallabhandi & another Respondents

ICICI Bank Limited having it’s in the state of Telangana by the

authorisation letter and Board resolution passed by the board in favour
of K. Papa Rao S/o Babu Rao Dt 03/07/2024 In the above appeal
petition do hereby appoint and retain.

NEESHMA
Solitaire Heights
B Block, Ameerpet, Hyderabad, Telangana – 500073

Advocate/s for the High court to appear for me./us in the above
appeal/ petition and to conduct and prosecuted (or defend) the same
and all proceedings that may be taken respect to any application
connected with the same or any decree or order passed therein
including all application for return documents or the receipt of any
money that may be payable to me /us in the said appeal /petition and
also appeal in all application under Clause XV of the Letters Pattern
and in all application for review and for leave to the Supreme Court of
India and in all application review of Judgement.

I Certify that the contents of this Vakalat were read out and explained
in (……) in any presence to the executant or executants who appeared
perfectly to undersigned same and made his/her /their signature in my
presence.
Executed before me this …… day of................2025
Advocate/ Hyderabad
2

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

VAKALAT ACCEPTED

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]
 3

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal

MP No : of 2025
Crl. [Link]: of 2025
Between

M/s ICICI Bank Limited

and represented by its authorised signatory …Petitioner

AND

Vidhya Sharma Rallabhandi & another …Respondents

LIST OF DOCUMENTS

[Link] Date of Description of the document Page

the Numbers
document
1 Letter of Authority 1
2 05/11/24 NPA Certificate 2
3 02/01/25 Demand 13(2) notice to borrower ,co- 3-8
borrower & guarantor
4 08/01/25 Dispatch proof 9-10
5 11/01/25 Delivery proof 11-21
6 06/06/25 Symbolic possession & Photo 22-23
7 05/03/25 Paper publication -13(4) English – 24
The Indian Express.
8 05/03/25 Paper publication -13(4)- Telugu- Nav 25
Telangana
9 22/11/19 Sanction letter 26-29
9.1 14/08/20 Sanction letter 30-33
10 25/11/19 Loan agreement 34-44
10.1 04/02/21 Loan agreement 45-57
11 28/11/19 Sale deed-6354/19 58-69
12 19/12/19 MODT 70-73
4

13 13/08/20 MODT 74-82

14 24/09/21 MODT 83-86
13 10/7/25 Statement of accounts 87-89
13.1 10/7/25 Statement of accounts 90-99
13.2 17/7/25 Statement of accounts 100-102

Medchal Petitioner
Counsel for Petitioner
5

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

LIST OF DOCUMENTS

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]
6

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal

MP No : of 2025
Crl. [Link]: of 2025
Between
M/s ICICI Bank Limited was originally promoted by
ICICI Limited in 1994 as wholly owned subsidiary
having its registered office at Race Course Circle
Vadodara -390007 and having branches among other
places at Hyderabad District Telangana and
represented by its authorised signatory K. Papa Rao
S/o Babu Rao

…Petitioner

AND
1. Srividhya Sharma Rallabhandi, D/o
Lalithamathi Desh, 1-20-291 Road No 9
Near Hanuman Temple, West
Venkatapuram, Tirumalagiri, Hyderabad
500015, Telangana.

And Also:
503 5th floor Aman Teja Peral Plot no 21
and 22, Ward No 1 Block No 5 Old Alwal
Village Ghmc, Alwal Circle, Alwal
Mandal Medchal Malkajgiri Dist22 23,
Telangana, Hyderabad -500010

And Also:
SBTS INDIA,
7-4-85 Madhava Nagar Balanagar,
Telangana, Hyderabad -500037

2. Rallabandi shashidhara sharma, 1-20-291

Road No 9 Near Hanuman Temple, West
Venkatapuram, Tirumalagiri, Hyderabad
500015, Telangana
7

And Also:
503 5th floor Aman Teja Peral Plot no 21
and 22, Ward No 1 Block No 5 Old Alwal
Village Ghmc, Alwal Circle, Alwal
Mandal Medchal Malkajgiri Dist22 23,
Telangana, Hyderabad -500010
…Respondents
U/s14(2) OF SARFAESI ACT 2002.
The address of the petitioner for the purpose of the service of summons
notices etc., is the same mentioned above in the cause title and that of its
counsel Mrs. NEESHMA (Advocate), # Solitaire Heights - B Block,
Ameerpet, Hyderabad, Telangana – 500073. Ph. No-9704112233.
neeshuz@[Link]

FACTS OF THE CASE:

1. It is respectfully submitted that the Petitioner is a private sector
bank and a secured creditor within the definition of Section 2 (zd)
of the Securitization and reconstruction of financial assets and
enforcement of security interest act 2002 and having branches all
over the country and presently this petition is filed in the state of
Telangana by the authorisation letter and Board resolution passed
by the board in favour of K. Papa Rao S/o Babu Rao Dt
03/07/2024.

2. The Petitioner further submits that the borrower No-2 acquired

title by virtue of Sale deed executed in favour of the Borrower No-
2 vide Doc-6354/19 Dt 28/11/2019 SRO VALLABHNAGAR in
All that the Semi-finished Flat Bearing No.503, in the 5 th Floor, of
Plinth area 1150 [Link]., (including common areas and one car
parking) with Undivided Share of land admeasuring 49.2 Square
yards or 41.13 Square Meters, (out of 738 [Link]), in Building
Name Known as “AMAN TEJA PERAL", Constructed on Plot
8

Bearing Nos. 21 part & 22, in Survey Nos. 22 & 23, covered under
ward No.1 and Block No.5, situated at OLD ALWAL, ALWAL
VILLAGE, under Greater Hyderabad Municipal Corporation,
Alwal Circle, Newly formed as Alwal Mandal. Medchal-
Malkajgiri District, the value of the Property mentioned in the sale
deed is Rs 22,00,000/-.

3. The Petitioner respectfully submits that the respondents initially

approached the bank for a loan of Rs 24,00,000/-, which was
sanctioned as a Loan Against Property on 22/11/2019.
Subsequently, on 14/08/2020, the respondents approach for a top-
up loan, and an amount of Rs 2,39,947/- was sanctioned. Further,
on 03/02/2021, another top-up loan was sanctioned for an amount
of Rs 7,45,000/-.
4. The bank had followed all procedures while sanctioning of loan
and also allotted a loan account numbers LBHYD00005174012 for
Rs. 24,00,000/- on an EMI of Rs 20160 for a tenure of 226M
LBHYD00005327710, for Rs. 2,39,947/- on an EMI of Rs 2130
for a tenure of 222M & LBHYD00005511950 for Rs 7,24,000 on
an EMI of Rs 6605 for a tenure of 227M.

5. The Due date of payment of the EMI for the loan mentioned is 30
Days, As the interest was revised so also the tenure, but in the
present Lan No the tenures was 226M, 222M & 227M. The
respondent had taken ECS facility to facilitate payment vide ECS.
The ECS remained unpaid as per SOA from 02/01/25.
6. The Bank declared NPA in the Loan Account Number on 05/11/24
of the borrower.
7. As the respondent has failed to pay the loan amount, thus the
petitioner was constrained to issued notice under section 13(2) of
9

the act directing the respondent / borrower / Co-borrower to pay

the amount due as on the date of issuance of the notice 02/1/25
directing the respondent to pay Rs 28,85,830.26 apart from plus
future interest. Schedule of Property as mentioned in the sale deed,
EC, & Loan Document – All that the Semi-finished Flat Bearing
No.503, in the 5th Floor, of Plinth area 1150 [Link]., (including
common areas and one car parking) with Undivided Share of land
admeasuring 49.2 Square yards or 41.13 Square Meters, (out of
738 [Link]), in Building Name Known as “AMAN TEJA
PERAL", Constructed on Plot Bearing Nos. 21 part & 22, in
Survey Nos. 22 & 23, covered under ward No.1 and Block No.5,
situated at OLD ALWAL, ALWAL VILLAGE, under Greater
Hyderabad Municipal Corporation, Alwal Circle, Newly formed as
Alwal Mandal. Medchal-Malkajgiri District, Bounded by:

North by: Corridor & Staircase.

South by: Open to Sky.
East by: Open to Sky.
West by: Open to Sky.

Rule 3- Main statement

Plot Bearing Nos. 21 part & 22, in Survey Nos. 22 & 23, covered
under ward No.1 and Block No.5 has extent 1150 sq yards, has per
sq yard Rs 1913.04 respectively and total value as Rs 22,000,00/-
situated at OLD ALWAL, ALWAL VILLAGE, under Greater
Hyderabad Municipal Corporation, Alwal Circle, Newly formed as
Alwal Mandal. Medchal-Malkajgiri District.
10

Due as per 13(2).

Lan No Amount Amount
Disbursed Outstanding as per
30/9/22 13(2) 21/1/25
LBHYD00005174012 Rs 24,00,000
LBHYD00005327710 Rs 2,39,947
Rs 28,85,830.26
LBHYD00005511950 Rs 7,45,000

8. As the notice issued U/s 13(2) on 02/1/25 by dispatching proof on

08/1/25 the loan account is served on the address as the notices
were Delivered. As the notices were delivered paper publication
was published in the 2 local Newspaper one in English (The Indian
Express) and the other in the local Language (Nav telangana) in
Telugu on 05/3/25.

9. Thus the borrower had the opportunity as contemplated by the

Judgement of the Hon’ble Supreme Court Under section 13 (3- A)
– which is an opportunity given to the borrower right to raise
objections as mentioned in the notice by filing the same within the 60
days’ period as per 13(2).

10. As the notices were served on the borrower and co-borrower and
guarantor but even then the borrower had the opportunity to file
objections under section13(3- A). As per Section 13(3-A) If, on
receipt of the notice under sub-section (2), the borrower makes any
representation or raises any objection, the secured creditor shall
consider such representation or objection and if the secured
creditor comes to the conclusion that such representation or
objection is not acceptable or tenable, he shall communicate
within
11

one week of receipt of such representation or objection the reasons

for non-acceptance of the representation or objection to the
borrower:

11. Then the petitioner bank issued notice U/s 13(4) for symbolic
possession to be taken up on 6/6/25 and in forming the
neighbourhood about the possession being taken over by the bank
Schedule of Property as per loan agreement is also mentioned
Paper publication is issued U/s 13(4) in the 2 local Newspaper one
in English (The Indian Express) and the other in the local
Language (Nav telangana) in Telugu on 05/3/25 informing the
general public that the bank has taken over the property and will
approach the Court for taking over the possession of the property
by due process of law.

12. As per the statement of account the outstanding Dt 02/1/25

Rs 28,85,830.26
Lan No Amount O/s as Amount due as per
on 2/1/25 SOA
LBHYD00005174012 Rs 18,91,116.00
LBHYD00005327710 Rs 28,85,830.26 Rs 1,94,896.00
LBHYD00005511950 Rs 6,41,863.00

13. Thus, it is prayed that the court may appoint an advocate

commissioner to inspect the schedule property and deliver
possession to the secured creditor as contemplated in the act.

14. The cause of action arose to the petitioner on 13/11/19 when the
respondent No-1&2 approached the bank for a Loan against
Property Rs 22,00,000/- had sanctioned housing loan of Rs
24,00,000/- on 22/11/19, Top up Loan of Rs. 2,39,947/- on 14/8/20
12

& again Top up Loan of Rs. 7,45,000/- on 03/2/21. The loan was
sanctioned toward the Loan against property Schedule Property
and deposited title deeds on 28/11/19 on subsequently Facility
agreement dated for LBHYD00005174012 on 02/11/19, Facility
agreement dated for LBHYD00005327710 on 04/02/20, Facility
agreement dated for LBHYD00005511950 was signed and loan
account was declared NPA on 05/11/24 and subsequently notice
U/s 13(2) was issued 02/1/25 and the said Notice were not
delivered and symbolic possession notice Dt 6/6/25 on possession
to be taken was delivered “As is where is” and later on 13(4)
paper notice dated 05/3/25 and is still continuing ..........

15. It is prayed that the Hon’ble court has got pecuniary & territorial
jurisdiction to entertain the petition as the property of the borrower
is within the jurisdiction of the court.

PRAYER
1. It is prayed that the Hon’ble court may be pleased to deliver the
physical possession of the suit property “AS IS WHERE IS”
from the borrower to the bank under section 14 of the SARFA ESI
Act 2002.
2. The court may appoint an advocate-commissioner and direct him
to take possession of the immovable property described in the
schedule herein and take inventory of the articles in the schedule
property by conducting Panchanama and be pleased to handover
the possession thereof to the petitioner.
3. To direct the advocate commissioner to break open the lock in
case the schedule property is found under lock.
13

4. To give suitable directions to the SHO of the concerned Police

Station ………………to assist to evict the occupants of the
schedule property and if so required break open the lock of
schedule property and to deliver he possession of the schedule
property to the petitioner.
5. To pass such orders as this Hon’ble court deem fit and proper in
the circumstances of the case. In the interest of Justice.

Place Hyderabad
Dated …….2025 Petitioner

Counsel for Petitioner

VERIFICAT ION

I [Link] Rao S/o Babu Rao authorised signatory of ICICI Bank

Limited, do hereby declare that whatever is stated in the above
paragraph is true and correct to the best of my knowledge belief
and legal advice .Hence verified to the true and is signed on this
day of 2025 At : Hyderabad

Petitioner
COUNSEL FOR PETITONER
14

SCHEDULE OF PROPERTY

All that the Semi-finished Flat Bearing No.503, in the 5 th Floor,

of Plinth area 1150 [Link]., (including common areas and one car
parking) with Undivided Share of land admeasuring 49.2 Square
yards or 41.13 Square Meters, (out of 738 [Link]), in Building
Name Known as “AMAN TEJA PERAL", Constructed on Plot
Bearing Nos. 21 part & 22, in Survey Nos. 22 & 23, covered under
ward No.1 and Block No.5, situated at OLD ALWAL, ALWAL
VILLAGE, under Greater Hyderabad Municipal Corporation,
Alwal Circle, Newly formed as Alwal Mandal. Medchal-
Malkajgiri District, Bounded by:

North by: Corridor & Staircase.

South by: Open to Sky.
East by: Open to Sky.
West by: Open to Sky.

VERIFICAT ION

I [Link] Rao S/o Babu Rao authorised signatory of ICICI Bank

Limited, do hereby declare that whatever is stated in the above
paragraph is true and correct to the best of my knowledge belief
and legal advice .Hence verified to the true and is signed on this
day of 2025 At : Hyderabad

Hyderabad Petitioner
15

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

U/S 14(1&2) SARFAESI

ACT

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]
 16

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal

MP No : of 2025
Crl. [Link]: of 2025
Between

M/s ICICI Bank Limited

and represented by its authorised signatory …Petitioner

AND

Vidhya Sharma Rallabhandi & another …Respondents

VERIFIED AFFIDAVIT

I [Link] Rao S/o Babu Rao aged : 50 .years Occ: Authorized officer
of ICICI Bank Limited Hyderabad Branch and District do hereby
solemnly affirm and state on oath as follows :-
That I am the deponent herein and authorized to represent and able to
depose as under:

1. It is respectfully submitted that the Petitioner is a private sector

bank and a secured creditor within the definition of Section 2 (zd)
of the Securitization and reconstruction of financial assets and
enforcement of security interest act 2002 and having branches all
over the country and presently this petition is filed in the state of
Telangana by the authorisation letter and Board resolution passed
by the board in favour of K. Papa Rao S/o Babu Rao Dt
03/07/2024.

2. The Petitioner further submits that the borrower No-2 acquired

title by virtue of Sale deed executed in favour of the Borrower No-
2 vide Doc-6354/19 Dt 28/11/2019 SRO VALLABHNAGAR in
17

All that Piece and Parcel of that the Land admeasuring 501 Square
Yards, in Survey Nos.415/1, Situated at MAHADEVI COLONY,
under Old Safilguda, Malkajgiri Municipality, now under Greater
Hyderabad Municipal Corporation Malkajgiri Circle and Mandal.
The value of the Property mentioned in the sale deed is Rs
22,00,000/-.
3. The Petitioner respectfully submits that the respondents initially
approached the bank for a loan of Rs 24,00,000/-, which was
sanctioned as a Loan Against Property on 22/11/2019.
Subsequently, on 14/08/2020, the respondents approach for a top-
up loan, and an amount of Rs 2,39,947/- was sanctioned. Further,
on 03/02/2021, another top-up loan was sanctioned for an amount
of Rs 7,45,000/-.
4. The bank had followed all procedures while sanctioning of loan
and also allotted a loan account numbers LBHYD00005174012 for
Rs. 24,00,000/- on an EMI of Rs 20160 for a tenure of 226M
LBHYD00005327710, for Rs. 2,39,947/- on an EMI of Rs 2130
for a tenure of 222M & LBHYD00005511950 for Rs 7,24,000 on
an EMI of Rs 6605 for a tenure of 227M.

5. The Due date of payment of the EMI for the loan mentioned is
30Days As the interest was revised so also the tenure, but in the
present Lan No the tenures was 226M, 222M & 227M. The
respondent had taken ECS facility to facilitate payment vide ECS.
The ECS remained unpaid as per SOA from 02/01/25.
6. The Bank declared NPA in the Loan Account Number on 05/11/24
of the borrower.
7. As the respondent has failed to pay the loan amount, thus the
petitioner was constrained to issued notice under section 13(2) of
18

the act directing the respondent / borrower / Co-borrower to pay

the amount due as on the date of issuance of the notice 02/1/25
directing the respondent to pay Rs 28,85,830.26 apart from plus
future interest. Schedule of Property as mentioned in the sale deed,
EC, & Loan Document – All that the Semi-finished Flat Bearing
No.503, in the 5th Floor, of Plinth area 1150 [Link]., (including
common areas and one car parking) with Undivided Share of land
admeasuring 49.2 Square yards or 41.13 Square Meters, (out of
738 [Link]), in Building Name Known as “AMAN TEJA
PERAL", Constructed on Plot Bearing Nos. 21 part & 22, in
Survey Nos. 22 & 23, covered under ward No.1 and Block No.5,
situated at OLD ALWAL, ALWAL VILLAGE, under Greater
Hyderabad Municipal Corporation, Alwal Circle, Newly formed as
Alwal Mandal. Medchal-Malkajgiri District, Bounded by:

North by: Corridor & Staircase.

South by: Open to Sky.
East by: Open to Sky.
West by: Open to Sky.

Rule 3- Main statement

Plot Bearing Nos. 21 part & 22, in Survey Nos. 22 & 23, covered
under ward No.1 and Block No.5 has extent 1150 sq yards, has per
sq yard Rs 1913.04 respectively and total value as Rs 22,00,000/-
situated at OLD ALWAL, ALWAL VILLAGE, under Greater
Hyderabad Municipal Corporation, Alwal Circle, Newly formed as
Alwal Mandal. Medchal-Malkajgiri District.
19

Due as per 13(2).

Lan No Amount Amount
Disbursed Outstanding as
30/9/22 per 13(2)
21/1/25
LBHYD00005174012 Rs 24,00,000

LBHYD00005327710 Rs 2,39,947 Rs 28,85,830.26

LBHYD00005511950 Rs 7,45,000

8. As the notice issued U/s 13(2) on 02/1/25 by dispatching proof on

08/1/25 the loan account is served on the address as the notices
were Delivered. As the notices were delivered paper publication
was published in the 2 local Newspaper one in English (The Indian
Express) and the other in the local Language (Nav telangana) in
Telugu on 05/3/25.

9. Thus the borrower had the opportunity as contemplated by the

Judgement of the Hon’ble Supreme Court Under section 13 (3- A)
– which is an opportunity given to the borrower right to raise
objections as mentioned in the notice by filing the same within the 60
days’ period as per 13(2).

10. As the notices were served on the borrower and co-borrower and
guarantor but even then the borrower had the opportunity to file
objections under section13(3- A). As per Section 13(3-A) If, on
receipt of the notice under sub-section (2), the borrower makes any
representation or raises any objection, the secured creditor shall
consider such representation or objection and if the secured
creditor comes to the conclusion that such representation or
20

objection is not acceptable or tenable, he shall communicate

within one week of receipt of such representation or objection the
reasons for non-acceptance of the representation or objection to
the borrower:

11. Then the petitioner bank issued notice U/s 13(4) for symbolic
possession to be taken up on 6/6/25 and in forming the
neighbourhood about the possession being taken over by the bank
Schedule of Property as per loan agreement is also mentioned
Paper publication is issued U/s 13(4) in the 2 local Newspaper one
in English (The Indian Express) and the other in the local
Language (Nav telangana) in Telugu on 05/3/25 informing the
general public that the bank has taken over the property and will
approach the Court for taking over the possession of the property
by due process of law.

12. As per the statement of account the outstanding Dt 02/1/25

Rs 28,85,830.26
Lan No Amount O/s as Amount due as per
on 2/1/25 SOA
LBHYD00005174012 Rs 18,91,116.00
LBHYD00005327710 Rs 28,85,830.26 Rs 1,94,896.00
LBHYD00005511950 Rs 6,41,863.00

13. Thus, it is prayed that the court may appoint an advocate

commissioner to inspect the schedule property and deliver
possession to the secured creditor as contemplated in the act.

14. The cause of action arose to the petitioner on 13/11/19 when the
respondent No-1&2 approached the bank for a Loan against
Property Rs 22,00,000/- had sanctioned housing loan of Rs
24,00,000/- on 22/11/19, Top up Loan of Rs. 2,39,947/- on
21

14/8/20 & again Top up Loan of Rs. 7,45,000/- on 03/2/21. The

loan was sanctioned toward the Loan against property Schedule
Property and deposited title deeds on 28/11/19 on subsequently
Facility agreement dated for LBHYD00005174012 on 02/11/19,
Facility agreement dated for LBHYD00005327710 on 04/02/20,
Facility agreement dated for LBHYD00005511950 was signed
and loan account was declared NPA on 05/11/24 and subsequently
notice U/s 13(2) was issued 02/1/25 and the said Notice were not
delivered and symbolic possession notice Dt 6/6/25 on possession
to be taken was delivered “As is where is” and later on 13(4)
paper notice dated 05/3/25 and is still continuing ..........
[Link] is prayed that the Hon’ble court has got pecuniary & territorial
jurisdiction to entertain the petition as the property of the borrower
is within the jurisdiction of the court.

PRAYER

1. It is prayed that the Hon’ble court may be pleased to deliver the

physical possession of the suit property “AS IS WHERE IS”
from the borrower to the bank under section 14 of the SARFA ESI
Act 2002.
2. The court may appoint an advocate-commissioner and direct him
to take possession of the immovable property described in the
schedule herein and take inventory of the articles in the schedule
property by conducting Panchanama and be pleased to handover the
possession thereof to the petitioner.
3. To direct the advocate commissioner to break open the lock in
case the schedule property is found under lock.
22

4. To give suitable directions to the SHO of the concerned Police

Station ………………to assist to evict the occupants of the
schedule property and if so required break open the lock of schedule
property and to deliver he possession of the schedule property to
the petitioner.
5. To pass such orders as this Hon’ble court deem fit and proper in
the circumstances of the case. In the interest of Justice.
Place: Hyderabad

Dated ……..2025 Petitioner

Counsel for Petitioner

23

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

VERIFIED AFFIDAVIT

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]
 24

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal

MP No : of 2025
Crl. [Link]: of 2025
Between

M/s ICICI Bank Limited

and represented by its authorised signatory …Petitioner

AND

Vidhya Sharma Rallabhandi & another …Respondents

NO STAY AFFIDAVIT

I [Link] Rao S/o Babu Rao aged : 50 .years Occ: Authorized officer
of ICICI Bank Limited Hyderabad Branch and District do hereby
solemnly affirm and state on oath as follows :-
That I am the deponent herein and authorized to represent and able to
depose as under:

1. It is respectfully submitted that the Petitioner is a private sector

bank and a secured creditor within the definition of Section 2 (zd)
of the Securitization and reconstruction of financial assets and
enforcement of security interest act 2002 and having branches all
over the country and presently this petition is filed in the state of
Telangana by the authorisation letter and Board resolution passed
by the board in favour of K. Papa Rao S/o Babu Rao Dt
03/07/2024.

2. The Petitioner further submits that the borrower No-2 acquired

title by virtue of Sale deed executed in favour of the Borrower No-
2 vide Doc-6354/19 Dt 28/11/2019 SRO VALLABHNAGAR in
25

All that Piece and Parcel of that the Land admeasuring 501 Square
Yards, in Survey Nos.415/1, Situated at MAHADEVI COLONY,
under Old Safilguda, Malkajgiri Municipality, now under Greater
Hyderabad Municipal Corporation Malkajgiri Circle and Mandal.
The value of the Property mentioned in the sale deed is Rs
22,00,000/-.
3. The Petitioner respectfully submits that the respondents initially
approached the bank for a loan of Rs 24,00,000/-, which was
sanctioned as a Loan Against Property on 22/11/2019.
Subsequently, on 14/08/2020, the respondents approach for a top-
up loan, and an amount of Rs 2,39,947/- was sanctioned. Further,
on 03/02/2021, another top-up loan was sanctioned for an amount
of Rs 7,45,000/-.
4. The bank had followed all procedures while sanctioning of loan
and also allotted a loan account numbers LBHYD00005174012 for
Rs. 24,00,000/- on an EMI of Rs 20160 for a tenure of 226M
LBHYD00005327710, for Rs. 2,39,947/- on an EMI of Rs 2130
for a tenure of 222M & LBHYD00005511950 for Rs 7,24,000 on
an EMI of Rs 6605 for a tenure of 227M.
5. No Stay of any proceedings against the petitioner from filing the
present petition before this court.

Hence this affidavit

Sworn & signed Deponent

Before me on this…. Day of

2025 at: Hyderabad Adv/Hyd

26

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

NO STAY ADDIFAVIT

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]
 27

In the court of the Addl. Senior Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At: Medchal

MP No : of 2025
Crl. [Link]: of 2025
Between

M/s ICICI Bank Limited

and represented by its authorised signatory …Petitioner

AND

Vidhya Sharma Rallabhandi & another …Respondents

SCHEDULE OF PROPERTY

All that the Semi-finished Flat Bearing No.503, in the 5 th

Floor, of Plinth area 1150 [Link]., (including common areas and
one car parking) with Undivided Share of land admeasuring 49.2
Square yards or 41.13 Square Meters, (out of 738 [Link]), in
Building Name Known as “AMAN TEJA PERAL", Constructed
on Plot Bearing Nos. 21 part & 22, in Survey Nos. 22 & 23,
covered under ward No.1 and Block No.5, situated at OLD
ALWAL, ALWAL VILLAGE, under Greater Hyderabad
Municipal Corporation, Alwal Circle, Newly formed as Alwal
Mandal. Medchal-Malkajgiri District, Bounded by:

North by: Corridor & Staircase.

South by: Open to Sky.
East by: Open to Sky.
West by: Open to Sky.

At : Hyderabad
Dated : ……...2025 Petitioner

Counsel for Petitioner

28

In the court of the Addl. Senior

Civil Judge - Cum – Addl. Chief
Judicial Magistrate Judge At:
Medchal

MP No: of 2025
Crl. [Link]: of 2025

Between

M/s ICICI Bank Limited

…Petitioner
AND

Vidhya Sharma Rallabhandi &

another …
Respondent/Borrower/
Co-borrower

SCHEDULE OF
PROPERTY

Filed on:

Filed by:

NEESHMA
(Advocate)
9704112233
Address: Solitaire Heights
B Block, Ameerpet,
Hyderabad, Telangana –
500073
neeshuz@[Link]