IN THE COURT OF THE PRINCIPAL DISTRICT JUDGE
:: AT KHAMMAM
I.A No. 2 OF 2025
IN
O.S. No. OF 2025
Between:-
1. Dhandyala Ravi Kumar
2. Cherukuri Gayathri
… Plaintiff/Petitioners/Petitioners
And
Angirekula Ramadevi and 61 others
… Defendants/ Respondents
AFFIDAVIT
I, Dhandyala Ravi Kumar S/o Ramaiah (late), Age: 51 years, Occ: Business
R/o House No: 7-32/4, Back side of Sai Baba Temple, Sai Prabhath Nagar, Pedda
Thanda, Khammam Rural Mandal, Khammam District. 507003, 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 the Plaintiff/Petitioner No.1 & 2 are wife and husband. Both are
purchased an agriculture land from one Kalvala Dhrupadh Kumar S/o Ram
Kishan Rao through Reg. Sale Deed bearing Doc. No. 4387/2007 and Reg. Sale
Deed bearing Doc. No. 4388/2007 respectively On 23.08.2008. That the
Agriculture land situated in and out Survey No. 43/ఉ at Thanagampadu Revenue
Village, Khammam Rural Mandal, Khammam District. Kalvala Drupadh Kumar
acquired afore said property through his father late Ramkishan Rao through
succession. At the time of Selling the property Kalvala Drupadh Kumar is in
peaceful possession and enjoyment of the agriculture and an extent of Ac. 107.15
Gts, In and out Survey No. 43/ఉ at Thanagampadu Revenue Village, Khammam
Rural Mandal, Khammam District. That the I Purchased an extent of Ac. 27.00
Gts through Reg. Sale Deed bearing Doc. No. 4387/2007 and Plaintiff/Petitioner
No.2 Purchased an extent of Ac. 25.00 Gts through Reg. Sale Deed bearing Doc.
No. 4388/2007 On 23.08.2007, at Sub Registrar Kusumanchi. It may be read as
'Petition Schedule Property' for the sake of gravity and convenience. That we
submit that we are lawful purchasers, absolute owners, and persons in
juridical possession of the petition schedule agricultural land, having acquired
valid title through registered sale deeds, and have been continuously asserting
ownership since 23-08-2007.
2. That we approached Tahsildar, Khammam Rural Mandal and applied for
mutation of the petition schedule property on our names by submitting registered
sale deed documents. But the Tahsildar, Khammam Rural Mandal dodged the matter
one other pretext. I have Refractory Industry and other businesses i.e., Organ News
Daily. State Government selected me for best entrepreneur award for the state, and
facilitated me with the prestigious award. I am the law abided citizen, never
committed for malpractice or never tried to give bribe to anyone for executing my
works. Revenue authorities ignored our mutation applications. That the reason
known to them only. We had repeatedly applied for mutation since 2007. Despite of
repeated applications supported by registered title deeds, the Tahsildar willfully
failed to mutate our names, adopting evasive tactics and unlawful silence, thereby
abdicating statutory duties. I submit that such inaction is not inadvertent but
deliberate, amounting to misfeasance in public office.
3. I submit that, the Defendants/ respondents No. 1 to 58 are illegal trespassers and
illegal occupiers of Petition schedule property except Official respondents.
Defendants/ respondents No.1 to 58 are cultivating different crops in undivided
compact agriculture land an extent of Ac.107.00 Gts including suit schedule
property. After purchasing of Petition schedule property Petitioners demanded the
encroached Defendants /respondents to vacate the suit schedule property. But
illegal occupiers requested the Petitioners that, they will get loss in cultivation if they
immediately vacate the Petition Schedule properties. That the illegal occupiers
assured that they will vacate in the summer, after harvesting the crops. After the
consequences years they dragged the matter and not vacate the possession.
4. I further submit that the Petitioners approached the land seller i.e., Kalvala
Drupadha Kumar, and demanded to fix the boundaries of petition schedule property.
On the demand of Petitioners Land seller Kalvala Drupadh Kumar applied for land
survey to Tahsildar office on 29.04.2013 by paying challan. After receiving the Survey
Application of the land seller along with challan, The Tahsildar Khammam Rural sent
a request letter to The Assistant Director of Survey and Land Records in April 2013
vide Rc. No. C/252/2013, to fix the boundaries in Survey No. 43/ఉ, situated at
Thanagamapadu Revenue Village, Khammam Rural Mandal. But Assistant Director
of Survey and land did not conduct any type of survey to fix boundaries. As such the
mutation and fixing of boundaries process is pending. No survey was conducted till
date, clearly indicating administrative collusion and gross dereliction of duty.
5. I submit that, the Telangana Government introduced Sada Bainama scheme,
aimed at regularizing informal land sales on plain paper in May 2016, with free
registration for small/marginal farmers up to 5 acres and phased implementations
following through 2017. We applied for mutation through mee seva bearing
Transaction Id Numbers TTMU 021600870357, TTMU 021600870314 respectively
On 29.06.2016. But the Tahsildar again ignored our applications. By taking
Sadhabainama scheme as advantage political leaders entered into this petition
schedule property to gain illegally. Political leaders provoke the Occupiers to apply for
pattadhar pass books by submitting forged documents. As such overnight illegal
occupiers and Political leaders created forged documents in conspiracy manner.
Political leaders colluded with grass root level revenue officers and applied for
pattadhar pass books by the way of submitting the forged and fabricated documents.
That the Tahsildar did not issue any type of notice to patta dhar (i.e., Kalvala
Drupadh Kumar) or us prior to issuing of the Pattadhar pass books to encroachers.
Revenue officers have sufficient knowledge on pending mutation of petition schedule
property, but on the insisting of political leaders, Tahsildar issued Pattadhar pass
books to the encroachers. That, We finally approached illegal occupiers in 2017 and
demanded to vacate the petition schedule properties. That the illegal occupiers
collectively replied that they are not encroachers, they are the owners of the Petition
schedule properties. Subsequently they show the e-Pattadhar pass books issued by
Tahsildar, Khammam Rural.
. That, we came to know that the conspiracy plan was hatched by political leaders to
grab property illegally.
Submitting forged applications
Fabricating signatures of the original pattadar
Suppressing pending mutation records
Issuing Pattadar Pass Books without notice, without enquiry, and without
jurisdiction. The entire exercise is void ab initio, illegal, unconstitutional, and
non-est in law.
6. I further submit that we approached Tahsildar, Khammam rural and inquired
about illegal mutation. But the Tahsildar replied in negligent manner. As such we
applied for certified copies of Sadhabainama applications, and adangal Pahanies
through RTI – 2005 act. PIO of Tahsildar of office issued the same documents under
RTI Act 2005, On 13.03.2020. After receiving of the documents, we perused the
signatures on the applications. That the signatures of Pattadhar (i.e., Kalvala
Dhrupadha Kumar), on the Sadhabainama applications are forged signatures and
not tallied with original signature. Again we approached Tahsildar and informed
about the illegal land transaction by showing forged signature and original
signature. Some unauthorized persons executed registrations as impersonated
without any lawful title. Tahsildar, Khammam Rural replied that the cancellation of
the Pattadhar Pass books is not in my hand without Hon’ble court order and
suggested us to approach Hon’ble court for better relief. After knowing the our
efforts encroached Defendants/ Respondents tried to sell out the petition schedule