IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE AT

BHIMAVARAM

Caveat Petition No. /2021

Between:

1.Smt. Gali Saraswathi,

2.Sri Madipatla Vamsi
3.Sri Nikhil Baheti,
4.Sri Srinivas Bandoju …Caveators
AND
Sri. Kanuri Madhusudhana Rao …Respondent

CAVEAT PETITION FILED UNDER SEC. 148 - A OF C.P.C.

Name and address of parties:

Caveators:

1.Smt. Gali Saraswathi, W/o. late Muddu Krishnam Nayudu, Hindu,

aged years, Managing Partner, M/s. Annapurna Saraswathi Ware
Housing Enterprises, Near Railway Station, Veeravasaram,
Veeravasaram Mandal, W.G.Dt.,

2.Sri Madipatla Vamsi, S/o. N.V.R. Prasad, Hindu, aged years,

Director, M/s. OSR Infra Private Limited, Plot NO. 105A, H.No. 8-2-
293/82/J/A/105, Near Syndicate Bank, Journalist Colony, Jubilee Hills,
Hyderabad – 500033, Telangana State.

3.Sri Nikhil Baheti, W/o. Madhavdas Beheti, Hindu, aged 31 years,

Chief Financial Officer, M/s. OSR Infra Private Limited, Plot NO. 105A,
H.No. 8-2-293/82/J/A/105, Near Syndicate Bank, Journalist Colony,
Jubilee Hills, Hyderabad – 500033, Telangana State.

4.Sri Srinivas Bandoju, S/o. Pentachari, Hindu, aged years,

Assistant Manager (Liasioning) M/s. OSR Infra Private Limited, Plot NO.
105A, H.No. 8-2-293/82/J/A/105, Near Syndicate Bank, Journalist
Colony, Jubilee Hills, Hyderabad – 500033, Telanagana State.

Respondent:

Sri. Kanuri Madhusudhana Rao, S/o. Narasimha Rao, Hindu, aged 44

years, Agricultural, R/o. D.No. 31-31, Veeravasam, Near Police Station,
Main Road, W.G.Dt.,

The addresses for service of notices etc., on the petitioners is as shown in

the long cause title and also that of their advocate Sri. D. KARUNAKAR RAJU,
B.N. RADHA KRISHNA YADAV & B. NAVEEN KUMAR Advocates,
Rajamahendravaram.
 The addresses for service of notices on the respondent to be served as
shown in the long cause title.

1. The petitioners submits that their office M/s. OSR Infra Private Limited,
situated at Plot NO. 105A, H.No. 8-2-293/82/J/A/105, Near
Syndicate Bank, Journalist Colony, Jubilee Hills, Hyderabad –
500033, Telangana State and also with M/s. Annapurna Kalpana
Warehousing Enterprises, a partnership firm, having its registered
office at H.No. 8-2-682/1, 5th Floor, Landmark Building, Road No.
12, Banjara Hills, Hyderabad – 500034.

2. The petitioners submits that the petitioners are doing various businesses
along with warehousing enterprises and towards the same to construct
Godowns for Warehouse purpose, had acquired the suit schedule property
since 2012 upto 2015 from various vendors and as it was an agricultural
lands, the petitioner herein had applied for conversion of land from
agricultural to non agricultural from the concerned revenue department of
Govt. of Andhra Pradesh from residential use to industrial use covered under
in Sy.No. 588 (P), 590 (P), 594, 593 (P), 595 (P), 596 (P), 598 (P), 1721 and
1722 (P) in the land admeasuring to an extent of Ac. 19.47 ¾ cents situated
at Veeravasaram (Village and Mandal), W.G.Dt., Andhra Pradesh, I further
submit that the petitioners herein had taken necessary permissions and
approval for construction of eleven Warehouse Godowns from the
concerned DTCP of Andhra Pradesh. The petitioners submits that the
petitioners had obtained necessary requisite permissions from the concerned
Fire Department for NOC, from Railway Department to lay tracks and also
Panchayat.

3. The petitioners submit the respondent herein who is holding an extent Ac.
0.82 cents of land in the R.S.No. 1719 of Veeravasaram Village and Mandal,
W.G.Dt., who is the petitioner neighbor on the northern side boundary along
with railway lands, it trying to interfere in my ongoing project works and
also blackmailing this petitioners/caveators by demanding huge sums apart
from creating all sort of hindrance and hurdles in their construction activity
of ware house godowns and also his actions is by sending false and frivolous
notice to the petitioners/caveators clearly goes to show that there is every
possibility, that he would file a false case against the petitioners/caveators
 and the respondent may obtain ex-parte restraining order from this Hon’ble
Court against the petitioners, to halt their ongoing project work.

4. Cause of action for the petitioner arose when the petitioners are doing
various businesses along with Warehousing Enterprises and towards the
same to construct Godowns for warehousing purpose had acquired the
schedule property and when petitioners had applied for conversion of plant
from Agriculture to non agriculture and taken necessary permission and
approval for construction of Eleven warehouse godowns and the respondents
who are having their property on the North side of Petitioner property is
trying to interfere with the petitioners ongoing project work and proclaiming
to file false cases against the petitioners and obtain ex-party orders and at
Veeravasam, W.G.Dt., where the notice schedule property is situated which
is within the jurisdiction of the Hon’ble Court.

5. A fixed court fee of Rs. /- is paid under rule 295 (5) of civil Rules of
Practice.

6. The petitioners had sent a copy of this petition to the respondent through
registered Post, and the receipts issued by the Postal Authorities is are
enclosed.

7. The petitioners therefore prays that the Hon’ble Court may be pleased to
pass orders:-
a. to lodge the caveat,
b. to issue notice to the petitioners in any proceedings initiated by the
respondent against the petitioners before passing any ex-parte orders or
injunction or otherwise
c. to grant other ancillary reliefs, that the Hon’ble Court deems fit and
proper under the circumstances of the case.
Be pleased to consider

Advocate for the petitioner Petitioner

The facts state above is all true and correct to the best of our knowledge and
belef.
Bhimavaram
Dt. -01-2021 Petitioner
List of Documents:
1. Postal Receipt
 IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE AT
BHIMAVARAM

Caveat Petition No. /2021

Between:

1.Smt. Gali Saraswathi,

2.Sri Madipatla Vamsi
3.Sri Nikhil Baheti,
4.Sri Srinivas Bandoju …Caveators
AND

Sri. Kanuri Madhusudhana Rao …Respondent

AFFIDAVIT OF THE PETITIONER

I, Sri Nikhil Baheti, W/o. Madhavdas Beheti, Hindu, aged 31

years, Chief Financial Officer, M/s. OSR Infra Private Limited, Plot NO.
105A, H.No. 8-2-293/82/J/A/105, Near Syndicate Bank, Jornalist
Colony, Jubilee Hills, Hyderabad – 500033, Telangana State, do hereby
solemnly affirm and state as follows:

1. I am the 3rd petitioner herein and I am well acquainted with the

facts. I am giving this affidavit on my behalf and on behalf of
petitioners 1, 2, & 4.
2. I am working as Chief Finance Officer in M/s. OSR Infra Private
Limited, situated at Plot NO. 105A, H.No. 8-2-293/82/J/A/105,
Near Syndicate Bank, Journalist Colony, Jubilee Hills, Hyderabad –
500033, Telangana State and also with M/s. Annapurna Kalpana
Warehousing Enterprises, a partnership firm, having its registered
office at H.No. 8-2-682/1, 5th Floor, Landmark Building, Road No.
12, Banjara Hills, Hyderabad – 500034.

3. That myself and other petitioners are doing various businesses

along with warehousing enterprises and towards the same to
construct Godowns for Warehouse purpose, had acquired the suit
schedule property since 2012 upto 2015 from various vendors and
as it was an agricultural lands, I herein had applied for conversion
of land from agricultural to non agricultural from the concerned
revenue department of Govt. of Andhra Pradesh from residential
use to industrial use covered under in Sy.No. 588 (P), 590 (P), 594,
593 (P), 595 (P), 596 (P), 598 (P), 1721 and 1722 (P) in the land
admeasuring to an extent of Ac. 19.47 ¾ cents situated at
Veeravasaram (Village and Mandal), W.G.Dt., Andhra Pradesh, I
 further submit that the petitioners herein had taken necessary
permissions and approval for construction of eleven Warehouse
Godowns from the concerned DTCP of Andhra Pradesh. The
petitioners submits that the petitioners had obtained necessary
requisite permissions from the concerned Fire Department for NOC,
from Railway Department to lay tracks and also Panchayat.

4. I submit the respondent herein who is holding an extent Ac. 0.82

cents of land in the R.S.No. 1719 of Veeravasaram Village and
Mandal, W.G.Dt., who is my neighbor on the northern side
boundary along with railway lands, it trying to interfere in my
ongoing project works and also blackmailing this
petitioners/caveators by demanding huge sums apart from creating
all sort of hindrance and hurdles in our construction activity of
ware house godowns and also his actions is by sending false and
frivolous notice to the petitioners/caveators clearly goes to show
that there is every possibility, that he would file a false case against
the petitioners/caveators and he may obtain ex-parte restraining
order from this Hon’ble Court against the petitioners, to halt their
ongoing project work.

5. I had sent a copy of this petition to the respondents through

registered Post, and the receipts issued by the Postal Authorities is
are enclosed.

6. I therefore prays that the Hon’ble Court may be pleased to pass

orders :
a. to lodge the caveat,
b. to issue notice to me in any proceedings initiated by the
respondents against me before passing any ex-parte orders or
injunction or otherwise
c. to grant other ancillary reliefs, that the Hon’ble Court deems fit and
proper under the circumstances of the case.
Be pleased to consider

Advocate for the petitioners Deponent

Solemnly affirmed and signed before on this 30 th day of
November, 2020 at Bhimavaram.
Advocate/Attesting Officer
 IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE AT
BHIMAVARAM

Caveat Petition No. /2021

Between:

1.Smt. Gali Saraswathi,

2.Sri Madipatla Vamsi
3.Sri Nikhil Baheti,
4.Sri Srinivas Bandoju …Caveators

AND
]
Sri. Kanuri Madhusudhana Rao …Respondent

PETITION SCHEDULE PROPERTY FILED BY THE PETITIONERS

West Godavari District, Veeravasaram sub-registry, Veeravaram

village, Veeravaram Mandal, all that site in R.S.No. 588 (P), 590 (P), 594,
593 (P), 595 (P), 596 (P), 598 (P), 1721 and 1722 (P) of warehouses
constructed by the Caveators in the land admeasuring to an extent of Ac.
19.47 ¾ cents bounded by

NORTH : Railway Property boundary along with property of

Kanumuri Madhusudhana to an extent of Ac. 0.82
cents.

SOUTH :Vacant land in R.S.No. 1722

EAST : Burial ground in R.S.No. 585 & 587, vacant lands in

R.S.No. 591, 593, 597, 595, 596& 1721 (residential
land use as per I.L.U.P.)

WEST : Existing 120” to 260” wide card tract (R.S.No. 585)

Be pleased to consider

Advocate for the petitioner Petitioner

The facts state above are all true and correct to the best of our
knowledge and belief.

Bhimavaram
Dt. -01-2021 Petitioner
 IN THE COURT OF THE
HON’BLE JUNIOR CIVIL
JUDGE AT BHIMAVARAM

Caveat Petition No.

/2021

Between:

1.Smt. Gali Saraswathi,

2.Sri Madipatla Vamsi
3.Sri Nikhil Baheti,
4.Sri Srinivas Bandoju
…
Caveators
AND
Sri. Kanuri Madhusudhana Rao
…
Respondent

CAVEAT PETITION FILED

UNDER SEC. 148 - A OF C.P.C.

Sri. D. KARUNAKAR RAJU,

Sri. B.N. RADHA KRISHNA
YADAV
Sri. B. NAVEEN KUMAR
Advocates
Rajamahendravaram