IN THE COURT OF THE CIVIL JUDGE (JUNIOR
DIVISION):: BANAGANAPALLE
O.S. No: 170/2024
Ambapuram Venkata Reddy …… Plaintiff
-Versus-
1. Sandu Ravi
2. Gopisetty Manohar …… Defendants
WRITTEN STATEMENT FILED ON BEHALF OF THE DEFENDANT
No. 1 ON BEHALF OF DEFENDANT NO. 1 AND 2, UNDER ORD
8 RULE 1 C.P.C.
1. The Suit is not just and maintainable either in law or on
facts.
2. Except such of those allegations which the defendant
admits here in, he denies all other allegations in the plaint.
The plaintiff has to prove the same.
3. As seen it utterly false to say that the plaintiff is the
absolute owner and possessor of the plaint schedule property.
The plaint schedule situated in Survey number 152/2
measuring Ac. 1.74 cents situated in Yanakandla revenue
village of Banaganapalle mandal, belongs to the defendants as
it was obtained from Government assigned land to the
defendant No.2. the defendant N9o.2 herewith filing the
Jaganna Sampoorna Gruha Hakku patram for the kind perusal
of this Hon’ble court. As stated in the plaint the plaint
schedule property is originally belongdedd to the father of the
plaintiff by name Rosireddy gari Venkata Reddy allude Rami
Reddy, he purchased the plaint schedule property from one
Gulam Alli Saheb under registered sale deed document no.
319/1949 dated: 27.04.1949. since, then
the plaintiff has been in possession and enjoyment of the plaint
schedule land property as absolute owner thereof. Therefore,
the same has to be proved by the plaintiff and the burden of
proof lies upon the plaintiff. In support of plaintiff version the
plaintiff hasn’t submitted the genealogy plan with intent to
wrongful gain only.
4. In paragraph No.4 it is stated that the Pattadar Passbook
were misplaced while travelling in the bus. Which seems to be
ambiguity nature. Therefore the burden of proof lies on plaintiff
itself only.
5. Moreover, the cause of action stated on 15.08.2024, that
defendants the defendants along with their men they are
constructing a house illegaly in the plaint schedule property
high handedly by encroaching into the plaint schedule property
and til continuing the same is an evil idea for the purpose of
the suit only. The Mandal Revenue officer issued possession
certificate and the government of Andhra Pradesh issued
absolute ownership over the plaint schedule property to the
defendants. The defendants are high handed in nature and
they will take law and order into their hands and at any
moment put their evil idea into reality. Therefore, the plaintiff
constrained to file this suit for permanent injunction restraining
the defendants, their men, agents, legal heirs or anybody on
their behalf from interfering with peaceful possession and
enjoyment of the plaint schedule property is invented date
only for the purpose of suit. So, that the plaintiff chose to
cause great hardship to defendants
6. The cause of action is myth which is invented for the
purpose of this case. For the above reasons.
ADVOCATE FOR DEFENDANTS
NO.1 and 2
DEFENDANT NO.1 & 2
VERIFICATION
I do here by declare that the contents of the
above paras have been read over, explained and translated
to me in Telugu after I having admitted it to be true to the
best of my knowledge, signed here under on 14.07.2025 at
Banaganapalle.
DEFENDANT No.1
IN THE COURT OF THE CIVIL JUDGE (JUNIOR
DIVISION):: BANAGANAPALLE
O.S. No: 170/2024
Ambapuram Venkata Reddy …… Plaintiff
-Versus-
1. Sandu Ravi
2. Gopisetty Manohar …… Defendants
AFFIVIDAVIT OF DEFENDANT NO.1
I, Jaddu Venkata Ramana Reddy, S/o. J. Raja Gopal Reddy,
aged about 35 years, Hindu, Cultivation, R/o. Chinna Kopperla
Village and post Koilakuntla mandal, Nandyal district, do hereby
states as follows:
2. I had filed written statement today in the above case. The
contents of the written statement may be read as part and parcel
of this affidavit. I am making on oath. I am also representing
defendant no. 2, herein of this affidavit.
3. As the above suit is not maintainable one and the plaintiff
has to prove the title and possession over the plaint schedule and
genealogy of ancestors of plaintiff is not filed and to get wrongful
gain. So, the suit is liable to be dismiss with exemplary cost.
Otherwise, I would suffer loss and hard ship.
Deponent
Solemnly affirmed and signed before me on 14.07.2025, at
Banaganapalle.
Advocate
IN THE COURT OF THE CIVIL JUDGE (JUNIOR
DIVISION):: BANAGANAPALLE
I.A. NO. 997 /2024 O.S. No: 170/2024
Ambapuram Venkata Reddy …… Plaintiff
-Versus-
1. Sandu Ravi
2. Gopisetty Manohar …… Defendants
COUNTER FILED ON BEHALF OF RESPONDENTS
1. The petition is not just and maintainable either in law
or on facts.
2. Except such of those allegations which the
respondent admits here in, he denies all other
allegations in the petition, the petitioner has to prove
to same.
3. The petitioner never filed genealogy of petitioner’s
ancestors as they are claiming that the petition
schedule properties belong to his father. With intent
to gain wrongful fain only the petitioners filed the
petition as they are eyesore towards the
respondents.
4. The petitioner filed present petition praying the
Honourble Court restraining the respondents
interfering the petition. So, the present petition is
filed only to harass the respondent without proving
the allegations and obtaining ad-interim injunction.
So, the same has to be proved by the petitioner.
5. For the above reasons the petition may be dismissed
with exemplary costs.
ADVOCATE FOR RESPONDENTS.