IN THE COURT OF HON’BLE JUNIOR CIVIL JUDGE

RANGA REDDY DISTRICT : AT AMANGAL

O.S No 291 of 2023

Between:

Veldanda Peddi Reddy and others …

Plaintiffs
AND
Veldanda Raghavamma …Defendant

WRITTEN STATEMENT FILED BY THE DEFENDANT

In the above-mentioned case, the Defendant herein submits the

following Written Statement: -

1. That the Defendant herein submits that, without any prejudice to

the rights and pleas set out hereinafter, the Defendant herein denies
all the adverse allegations made therein except for those which are
specifically traversed hereunder.

2. That the Defendant submits that, the Plaintiffs have no locus

standi to file the present suit and as such the same is neither
maintainable in law nor on facts and as such the same is fit to be
dismissed in limini.

3. That the Defendant submits that, the Plaintiffs have come to this
Hon’ble Court with unclean hands and by suppressing all the real facts,
even though they are not entitled for any relief(s) filed the present
false and fictitious suit for Suit for Declaration title and recovery of
possession in respect of suit schedule property, and as such suit of the
Plaintiffs is not maintainable and the same thus deserves to be
dismissed.
4. That in reply to Paras No. I and II, It is submitted that the
contents relating to the description of the parties, the same are same
is formal in nature and does not require any specific reply.
 ::2 ::
5. That in reply to other contents (brief facts of case) of the Plaint, it
true that the life time of Naraiah @ Narayan Reddy, the then
Government of Andhra Pradesh (undivided State of Andhra Pradesh)
represented by Tahsildar of Kalwakurthy issued Lavoni Patta for an
extent of 6 acres in Survey No. 391 of Kalakonda (Village), Kalwakurthy
(Taluq), in favour of Veldanda Naraiah S/o Ramaiah vide. Proceeding of
Tahsildar Kalwakurthy in R.C. A5/7064 dated 16/04/1963, and delivered
the peaceful possession of the said property to Late Veldanda Naraiah
accordingly the Pattadar Pass Book was issued in favour of Veldanda
Naraiah.

But other contents mentioned in the (brief facts of case) are

incorrect, concocted and fabricated for the purpose of filing the
present suit and as such the Defendant herein categorically denies the
correctness of the same and the Plaintiff is put to strict proof of the
same. Veldanda Naraiah died leaving behind his sons and that aftert
death of Veldanda Naraiah the Plaintiffs made an application to Mandal
Revenue Officer (MRO), Madgul for Mutation of records deleting the
name of Veldanda Naraiah and to incorporate the names of Plaintiffs as
successors / Legal representatives and accordingly the Panchanama
was conducted on 16-11-2006 by additional Mandal Revenue Inspector
and that on enquiry of the revenue officials and satisfied that plaintiffs
alone were the successors of the suit property on the death of
Veldanda Naraiah, MRO (Mandal Revenue Officer) issued proceedings
in A/5527/2006 dated 11-12-2006 incorporating the names of plaintiffs
as successors and Pattadars of suit schedule property n which each of
the Plaintiff has got 2 acres as per the proceedings of MRO (Mandal
Revenue Officer), Madgul and that the Plaintiffs have been in
possession of suit property by raising crops and their names are also
recorded in Adangal / Pahani and that In June 2016, in the temporary
absence of plaintiff form the village the defendant without any
semblance of right entered into plaint schedule property and that the
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plaintiff found defendant in un-authorized possession of suit property
and that the defendant is influential person working in Police
department and colluded with Revenue Officials in August 2016, the
Plaintiffs along with the witness requested the defendant to vacate
from the suit property and that the Defendant having influential
contacts with both revenue officials and Police officials, she did not
listen to the good advice of Plaintiffs and the elders and that the
laintiffs have been approaching the defendant every year and for the
last time in 2nd week of August 2023 and requested the defendant to
vacate from suit schedule property defendant bluntly refused to vacate
from the suit land and to keep the plaintiff in peaceful possession and
challenged the plaintiff to do whatever they like to and that the
Defendant also threatened to register a false criminal case against the
plaintiffs and that the plaintiffs are weak persons and law abiding
citizens and have approached this Hon'ble Court for redressal of the
grievance and that recently the plaintiff came to know that the
defendant is in arm expert in fabricating the records and that the
Since the property was given to Veldanda Naraiah as Lavoni Patta,
such land can't be sold either by Veldanda Naraiah during his life time
nor by his legal representative and that alienation of Lavoni patta land
can't be sold and even if sold it is an in-valid alienation and that the
defendant by no stretch of imagination becomes Legal representative
of the deceased Veldanda Naraiah and that the entry could have been
made by revenue officials only on the pressure and un-due influence by
the defendant on the revenue officials and with the help of her higher
possession police officials on the revenue department are incorrect and
as such the Defendant herein categorically denies the correctness of
the same and the Plaintiff is put to strict proof of the same.
The Defendant submits the real facts as under

a. That admittedly the father Plaintiffs namely Naraiah @ Narayan

Reddy was the absolute owner and possessor of land admeasuring
 ::4 ::
Ac.6-00gts in Survey No. 391 of Kalakonda (Village), Kalwakurthy
(Taluq) and same has been acquired through Proceeding of
Tahsildar Kalwakurthy in R.C. A5/7064 dated 16/04/1963.

b. That said Naraiah @ Narayan Reddy in view of their family

necessities he and his family members i.e. Plaintiffs herein offered
to sell the said land and accordingly the Defendant herein
purchased the same for valuable sale consideration and in this
regard said Naraiah @ Narayan Reddy with the consent of his sons
i.e. Plaintiffs executed a sale note dated 13-12-1998 in favour of the
Defendant herein and handed over the peaceful physical possession
of the same in favour of the Defendant. Since then the Defendant
herein is in possession and enjoyment over the above said lands.
That the Plaintiff are the attesting witness of sale note executed by
their father in favour of the Defendant herein

c. That basing on purchase of above said land by the Defendant, he

name was mutated in the revenue record and resultant of such
mutation, the revenue officials also got issued pattedar pass book
Khata No. 2018 in favour of the Defendant herein and while
purification of revenue record under Dharani Portal the Government
of telangana by also issued new pattedar pass book No.
T05150072423 Khata No. 2018 in favour of the Defendant herein
and the Plaintiffs also well aware of all the above said fact.

d. That recently in view of hike of lands prices in the locality the

Plaintiffs taking advantage of old recorded with a malafide intention
got obtained a false and fabricated proceedings and pattedar pass
books in respect of above said lands by managing the revenue
officials in respect of above said lands and illegally trying to claim
rights over the land purchased by the Defendant herein and illegally
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interfering with the possession and enjoyment of the Defendant
over above said land

e. But as a matter of fact the Plaintiffs herein who is nothing to do with

the lands purchased by the Defendant herein from the father of
Plaintiff with their consent and inspite of the same, the Plaintiffs by
falsely denying the alienation of their father, claiming the rights over
the land and in said process the Plaintiffs by obtained false and
fabricated documents and basing on the same the Plaintiffs got filed
the present suit with all sorts of false allegations.

f. Further admittedly the Plaintiffs is not on possession and over the

suit schedule property at any point of time as such question of
declaration to declare them as owners and recovery of possession
respect of suit schedule property does not arise.

g. The Plaintiff by knowing all the said facts, got filed the present suit
on false and baseless documents with all sorts of false allegations as
such suit of the Plaintiffs is tenable in any angel and not
maintainable in law nor on facts and liable to be dismissed.
OTHER PLEAS
i. That without prejudice to the pleas taken by the herein,
that without any cause of action, the Plaintiffs have filed the
present false suit and as such the Defendant are entitled for
compensatory costs of Rs 2,00,000/- each from the Plaintiffs
herein.

ii. That without prejudice to the pleas taken by the, the

Plaintiffs have approached this Hon’ble Court with unclean hands
and also by suppressing all the real facts and as such the Plaintiff
is not entitled for any relief.
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iii. That without prejudice to the pleas taken by the Defendant
herein, the Defendant are reserving his right to prosecute the
Plaintiff for misrepresentation of facts and also playing fraud on
this Hon'ble Court.

6. That in reply to the Para of cause of action, it is submitted that,

the facts mentioned therein are incorrect, concocted and fabricated for
the purpose of filing the present suit under reply and as such the
Defendant herein denies the correctness of the same. At no point of
time and place, such cause of action has arisen for filing the present
suit and the cause of action shown therein is the result of the fertile
imagination of the Plaintiffs and as such the present suit under reply is
liable to be dismissed.

7. That in reply to Para of Jurisdiction of the Plaint, it is submitted

that the facts mentioned therein are formal in nature and as such no
such specific reply is required.

8. That in reply to Para No VI Court fee, it is submitted that, the

Plaintiff is grossly undervalued the suit reliefs and wrongly mentioned
the suit relief and paid most insufficient court fee and as such the suit
of the Plaintiff is not maintainable in law.

9. That in reply to Paras No VII the Plaint, it is submitted that the

facts mentioned therein are formal in nature and as such no such
specific reply is required.

That in view of the facts and circumstances enumerated in the

foregoing paragraphs of the Written Statement, the Defendant humbly
submits that, the Plaintiffs are no way concerned with lands purchased
by the Defendant herein as they are well known that the Defendant has
purchased suit schedule property form their father and the Plaintiffs
also singed as witnesses to the said sale transaction and inspite of the
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same by taking advantage of false and fabricated documents the
Plaintiffs got filed the present suit with all sorts of false allegations and
as such the Plaintiffs is not entitled for any relief(s) and as such the suit
of the Plaintiff is liable to be dismissed.

Therefore, it is prayed that this Hon’ble court may be pleased to

dismiss the suit of the Plaintiff by awarding the compensatory costs in
the interest of Justice.

Place: Amangal,
Date: -08-2024. Defendant

Counsel for the Defendant

VERIFICATION

I, Veldanda Raghavamma W/o. Janga Reddy, Age 48 years, Occ:

Head Constable, R/o. Chandrayanaplly Village, Madgul Mandal, Ranga
Reddy District, the Defendant No. 1 herein, do hereby declare that
what all has been stated in the above said paras of the Written
Statement are true and stand correct to the best of my knowledge and
belief. Hence, verified.

Place: Amangal,
Date: -08-2024. Defendant
::8 ::
IN THE COURT OF HON’BLE
JUNIOR CIVIL JUDGE
RANGA REDDY DISTRICT
AT AMANGAL
O.S No 291 of 2023

Between:

Veldanda Peddi Reddy and others

…Plaintiffs
AND
Veldanda Raghavamma
…
Defendant

WRITTEN STATEMENT FILED BY

THE DEFENDANT

Filed On: -08-2024

Filed By:

Counsel for the Defendant

M/S. A. SEKHAR
Advocate
Amangal, Ranga Reddy District
Cell : 9908344816