Pavan Kumar Kasu Injuction at Mancherial

IN THE COURT OF THE HON’BLE PRINICIPAL JUNIOR CIVIL
JUDGE, MANCHERIAL DISTRICT

AT: MANCHERIAL
O.S.No. of 2024
Between:
Sri kasu Pavan Kumar ,S/o Late K Surender Raju ,
aged 45 years, Occu: Business,
R/o. Flat No 503, Vaishanvi Estates,
Near Canara Bank , Street no 2,
Gandhi Nagar. Hyderabad 500060
..Plaintiff
AND
1) Sri Madugula Peeraiah , S/o Not known, Aged about: 60 years,
Cast : Scheduled Cast, Occu: private Service, R/o. SC colony,
Mandal: Naspur , District : Mancherial
2) Sri Madugula Swamy Das, S/o Not known, Aged About 40

years, Cast : Scheduled Cast, Occu: Private Service, R/o.SC
Colony, Mandal : Naspur, District : Mancherial
….Defendants 1&2
PLAINT FILED UNDER ORDER 7 RULE 1

R/w SECTION 26 OF C.P.C
1. DISCRIPTION OF THE PLAINTIFF;
The address for service of summonses notices processes etc., on the

plaintiff is that of her counsel Sri. Sampath Kumar & B.Nachiketh
Advocate TS/1755/2006, R/o.1-2-593/3/1, A-4, Raghavendra
Kruapa apartments , Adjacent to the Sri Ram Chandra mission ,
Domalguda, Hyderabad.
2. DISCRIPTION OF THE DEFENDANT;
The address for the service of summonses, notices processes etc., on

the defendants is same as that shown in the above cause title.
3. BRIEF FACTS OF THE CASE;
It is submitted that the Plaintiff father acquired the house property

father Sri Late K Surender Raju (Vendee) purchased Kushki (Dry
Land ) Residential Plot from Sri Adloori Narasimha raju S/o Rama
raju and Sri Guruduri Madhusudahan Raju , S/o Naryana Raju are
Vendors in the date & year 31.03.1986 by registered sale deed
No 1191 in Survey No. 112 admeasuring 191.28 Sq. yds Equallnet
to 229 Sq Yds situated at Registration District :Adilabad; Sub
District: Mancherial , Jilla Parishath & District Adilabad block
Samithi : Mandal : Laskhtipet , Mandal : Mancherial , Gram
Panchayath: Naspur Code no 82 village limits , vide a Sale deed in
Doc No.1191/1986, Registered on the file of Sub-Registrar Mancherial
now this Suit Scheduled Property situated at Mandal : Naspur,
District: Mancherial adjacent to the Naspur Police Station ,
Mancherial Main road and this suit scheduled property comes under
Hon’ble PDJ courts Mancherial. The above mentioned open plot fully
described in the schedule of property, which is appended hereunto.
4. It is humbly submitted that the plaintiff’s father (Vendee) has

purchased the Suit Schedule Property by Registered Sale Deed Sale
in the year 1986 i.e, on 31-03-1986 and entire sale consideration
amount Rs. 2000 and since then 31.3.1986 this land is Vacant
house plot no 24 as shown in Plot Map and not alienated to any one
as per the Encumbrance Certificate which was duly issued by the sub
registrar office Mancherial is showing “Nil Occupancy” as not
transferred to anyone & Clear Title on Plaintiff father name Late Kasu
Surrender Raju and till date Nil Occupancy except Defendants 1 and
2 henchmen trespass and blackmailing with false cases and other
tactics, hence on these circumstances this situation amicably solving
time to time to safe guard the Suit scheduled property from the
clutches of miscreants .
5. It is humbly submitted that the suit schedule property is hard
earned property of plaintiff father in his life time Sri Late Kasu
Surender Raju. This property is purchased in a Group of plots all
together as the suit scheduled property under Gram Panchyath lay
out .
It is humbly submit that the present plot is still vacant position since
1986 to till date & These plots shown in Lay out Map and Layout copy
as enclosed with list of documents. As this property not transfer to
any one as sale , mortigage, or anyother fianciaila transactions and
this property or land is not belongs to A.P (P.O.T) act 9 of 1977 as
shown in Asign lands, this property is clear title .
6. It is humbly submitted that the defendants 1 and 2 with henchmen

now and then quarreling with Plaintiff not to construct in suit
scheduled property and same time to time solving this issue with
discussion with elderly people not to interfere peaceful atmosphere
but all efforts of mediators & Elderly people are in Vain and more ever
threatening dire consequences with false cases and with the help of
false documents.
7. It is humbly submitted that Plaintiff wants to take help of this

Hon’ble court and take necessary directions to hassle free to construct
the house in Suit scheduled property. The Defendants are interfering
plaintiff with dire consequences not to construct the house in the suit
scheduled property because of heavy demand in Real Estate business
in Telangana State as district Reorganization procedure.
8. It is humbly submitted that defendants have changed their mind

and are trying to blackmail the plaintiff with forgery documents to
occupy the suit Scheduled property to taking advantage of fact that
the plaintiff resides at Hyderabad & said property only left in this area
which is a clear picture to occupy.
9. It is humbly submitted that Defendants 1 and 2 with their
henchmen are utter strangers to the suit schedule property. They
have no right, title or interest and even possession over any portion of
the suit schedule property and taking advantage of the fact that the
plaintiff has maintained vacant space suit schedule property.
On 15.01.2024 at morning 9.30 am, the defendants with

their henchmen came to plot no 24 suit schedule property and not to
go ahead of house construction & threatening the site workers not to
proceed the construction work and also tried to trespass into the suit
schedule property in the presence of Plaintiff.
In view of the above circumstances its time to

approach this Hon’ble court for permanent solution and protection
form this Hon’ble court and filing this petition .
The Plaintiff do hereby declare that except the present suit,

he did not file any other suit or applications against the Defendants
herein for similar reliefs in any other Court of Law, including Hon’ble
High Court of Telangana state.
7. CAUSE OF ACTION:
Cause of action for the suit arose on 15.1.2024 when the defendants’
1& 2 their henchmen at morning 9.30 am, the defendants with their
henchmen came near the suit schedule property not to construct the
house and stopped the construction material and also tried to
trespass into the suit schedule property and threatening Dire
consequences . The plaintiff resisted the illegal acts of the defendants.
Cause of action arose on 15-1-2024, when the defendants have
entered with the physical possession of the suit schedule property of
the plaintiff and also misbehaved with the plaintiff & family members
with dire consequences.
8. JURISDICTION & DECLARATION:
Suit Schedule Properties are Survey No. 112 admeasuring 191.28 Sq.
yds Equallnet to 229 Sq Yds situated at Registration
District :Adilabad; Sub District: Mancherial , Jilla Parishath &
District Adilabad block Samithi : Mandal : Laskhtipet , Mandal :
Mancherial , Gram Panchayath: Naspur Code no 82 village limits ,
vide a Sale deed in Doc No.1191/1986, Registered on the file of Sub-
Registrar Mancherial now this Suit Scheduled Property situated at
Mandal : Naspur, District: Mancherial adjacent to the Naspur Police
Station , Mancherial Main road which falls within the territorial
jurisdiction of this Hon’ble Court, as such Hon’ble Court have
Jurisdiction to entertain the Suit.
The Plaintiff do hereby declare that except the present suit, he did not
file any other suit or applications against the Defendants herein for
similar reliefs in any other Court of Law, including Hon’ble High Court
of Telangana state.
9. LIMITATION:
The suit is filed within the period of Limitation.
10. VALUATION:
The suit is valued at Rs.10, 000(Rupees Ten Thousands only) being a

suit for injunction. Hence a Court Fee of Rs.786/- is paid under
section 26 of A.P.C.F. & S.V.Act, which is sufficient.
PRAYER
It is, therefore, prayed that this Hon’ble Court may be pleased to pass
a decree and judgment in favour of plaintiff and against the
defendants for the following reliefs:
1. To grant permanent injunction infavour of plaintiff and against
defendants 1& 2 their henchmen, agents and all persons
working through them sell, mortgage alienate, transfer, gift or
trespass try to dispose of the suit schedule property in any
manner.
2. And to award costs.
And pass such other order or orders as may be deemed fit and proper
in the interest of justice.
Date
Place Counsel for the Plaintiff
VERIFICATION
I, Sri kasu Pavan Kumar ,S/o Late K Surender Raju , aged 45 years,
Occu: Business, R/o. Flat No 503, Vaishanvi Estates, Near Canara Bank ,
Street no 2, Gandhi Nagar. Hyderabad 500060 do hereby solemnly and
sincerely affirm on oath ad state that the averments mentioned in the
Plaint are true and correct and they are based on documentary evidence.
Hence I believe them to be correct.
Hence verified at Hyderabad on this the day of January 2024.
Place Hyderabad
Date Plaintiff
SUIT SCHEDULE PROPERTY
All that part of the Plot No 24 in survey No.398 admeasuring area

191.28 Sq. yds, Equallnet to 229 Sq Yds situated at Registration
District Adilabad Sub District Mancherial , Jilla Parishath & District:
Adilabad block Samithi: Laskhtipet; Mandal: Mancherial,
Gram Panchayath: Naspur Code no 82 village limits , vide a Sale
deed in Doc No.1191/1986, Registered on the file of Sub-Registrar
Mancherial situated and District: Mancherial & bounded as follows:
North: Mr. Nagender sing Land

South: Plot No.23
East: Road
West : Plot No 49
Date
Place
Counsel for the Plaintiff
VERIIFICATION
Occu: Business, R/o. Flat No 503, Vaishanvi Estates, Near Canara
Bank , Street no 2, Gandhi Nagar. Hyderabad 500060 do hereby
solemnly and sincerely affirm on oath ad state that the averments
mentioned in the Plaint are true and correct and they are based on
documentary evidence. Hence I believe them to be correct.
Hence verified at Hyderabad on this the day of January 2024.
Place
Date
Plaintiff
LIST OF DOCUMENTS
1. Certified copy of the Sale Deed number: 1191

2. Certified copy encumbrance Certificate
3. English True Translation of Sale Deed Document No: 1191
4. Suit Scheduled Property Map
5. Death Certificate of Late Sri Surender Raju Plaintiff father
6. Adhaar Card of Plaintiff
Date
Place
Counsel for the Plaintiff
IN THE COURTOF HON’BLE
PRINCIPAL JUNIOR CIVIL
JUDGE,
MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
Sri kasu Pavan Kumar
..Plaintiff
AND
Sri Madgula Peeraiah and others
….Defendants 1&2
PLAINT FILED UNDER

ORDER 7 RULE 1
R/w SECTION 26 OF C.P.C
Filed on: -1-2024
Filed by: Counsel for Plaintiff
M/s Sri Smapath Kumar,

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
AT: MANCHERIAL
O.S.No. of 2024
Between:
..Plaintiff
AND

….Defendants 1&2
AFFIDAVIT
solemnly and sincerely affirm on oath and state as follows:
1. I submit that I am the petitioner herein and as such I am well

acquainted with the facts of the case.
2. It is submitted that the Plaintiff father acquired the house property



out .
6. It is humbly submit that The present plot is still
vacant position since 1986 to till date & These plots shown in Lay out
Map and Layout copy as enclosed with list of documents. As this
property not transfer to any one as sale , mortgage, or any other
financial transactions and this property or land is not belongs to A.P
(P.O.T) act 9 of 1977 as shown in Asign lands, this property is clear
title .

false documents.


plaintiff has maintained vacant space suit schedule property.
On 15.01.2024 at morning 9.30 am, the defendants with their

henchmen came to plot no 24 suit schedule property and not to go
ahead of house construction & threatening the site workers not to
precede the construction work and also tried to trespass into the suit
schedule property in the presence of Plaintiff.
In view of the above circumstances its time to approach this Hon’ble

court for permanent solution and protection form this Hon’ble court
and filing this petition . The Plaintiff do hereby declare that except the
present suit, he did not file any other suit or applications against the
Defendants herein for similar reliefs in any other Court of Law,
including Hon’ble High Court of Telangana state.
I, therefore pray that this Hon’ble Court may be pleased to

pass Ad-Interim Ex-parte injunction against the 1 and 2 their
henchmen and pass such other order or orders as may be deem fit ad
proper in the interest of jutice.
Sworn and signed before me

On this the day of Jan 2024,
At: Hyderabad Deponent
//Advocate/Hyderabad //
JUDGE,
MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
Sri Madugula Peeraiah and others
….Defendants 1&2
PETITION FILED UNDER

ORDER 39 RULE 1&2 OFC.P.C
Filed on: -1-2024
M/s Sri Smapath Kumar

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
AT: MANCHERIAL
IA.NO. /2024
IN
O.S.No. of 2024
Between:
..Plaintiff
AND
1) Sri Madgula Peeraiah , S/o Not known, Aged about: 45 years,
2) Sri Madgula Swamy Das, S/o Not known, Aged About 40

….Defendants 1&2
PETITION FILED UNDER ORDER 39 RULE 1&2 OFC.P.C
For the reasons stated in the accompanying affidavit it is, therefore

prayed that this this Hon’ble Court may be pleased to pass Ad-Interim
Ex-parte injunction against Ad-Interim Ex-parte injunction against
the 1 and 2 their henchmen and pass such other order or orders as
may be deem fit ad proper in the interest of justice.
Date
Place
Counsel for the Petitioner
PETITION SCHEDULE PROPERTY
All that part of the Document No 1191, Plot No 24 in Survey No. 112
admeasuring 191.28 Sq. yds Equallnet to 229 Sq Yds situated at
Registration District Adilabad Sub District Mancherial , Jilla
Parishath & District Adilabad block Samithi Laskhtipet mandal
Mancherial Gram Panchayath Naspur Code no 82 village limits , vide
a Sale deed in Doc No.1191/1986, Plot No 24 as shown in Plot Map &
Registered on the file of Sub-Registrar Mancherial District and
bounded as follows:
North: Mr Nagender sing Land

South: Plot No.23
East: Road
West: Plot No 49
Date: Counsel for the Petitioner

IN THE HONOURABLE
COURTOF HON’BLE
JUDGE,
MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2

ORDER 39 RULE 1&2 OFC.P.C
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
AT: MANCHERIAL
IA.NO. /2024
IN
O.S.No. of 2024
Between:
..Plaintiff
AND

….Defendants 1&2
VERIFICATION AFFIDAVIT




out .
It is humbly submit that The present plot is still vacant position since
any one as sale , mortgage, or any other financial transactions and

false documents.



plaintiff has maintained vacant space suit schedule property. On
15.01.2024 at morning 9.30 am, the defendants with their henchmen
came to plot no 24 suit schedule property and not to go ahead of
house construction & threatening the site workers not to proceed the
construction work and also tried to trespass into the suit schedule
property in the presence of Plaintiff.

and filing this petition . The Plaintiff do hereby declare that except the
present suit, she did not file any other suit or applications against the
I submit that the averments and contents mentioned in the affidavit

are true and correct and nothing is false. Hence, I verified this
affidavit on this the day of January 2024, at Hyderabad. Hence
this affidavit.

On this the day of Jan 2024
At: Mancherial Deponent
IN THE COURT OF HON’BLE
JUDGE, MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
VERIFICATION AFFIDAVIT
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
AT: MANCHERIAL
IA.NO. /2024
IN
O.S.No. of 2024
Between:
..Plaintiff
AND

….Defendants 1&2
AFFIDAVIT




out.
It is humbly submit that The present plot is still vacant position since
any one as sale , mortigage, or anyother fianciaila transactions and

false documents.



plaintiff has maintained vacant space suit schedule property. On
15.01.2024 at morning 9.30 am, the defendants with their henchmen
came to plot no 24 suit schedule property and not to go ahead of
house construction & threatening the site workers not to proceed the
construction work and also tried to trespass into the suit schedule
property in the presence of Plaintiff.

and filing this petition. The Plaintiff do hereby declare that except the
present suit, he did not file any other suit or applications against the
I therefore pray that the Hon`ble court may be pleased to dispense

with the obligation of issuing the notice as required under section 80
of C.P.C. to the 1 and 2 respondent/defendant and pass such other
order or orders as may be deem fit ad proper in the interest of justice.

On this the day of January 2024
At: Hyderabad Deponent
//Advocate/Hyderabad//
IN THE COURT OF HON’BLE
JUDGE, MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
AFFIDAVIT
FILED
BY PLAINTIFF
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
AT: MANCHERIAL
IA.NO. /2024
IN
O.S.No. of 2024
Between:
..Plaintiff
AND

….Defendants
PETITION FILED UNDER SECTION 151 OFC.P.C
For the reasons stated in the accompanying affidavit it is, therefore

pray that the Hon`ble court may be pleased to dispense with the
obligation of issuing the notice as required under section 80 of C.P.C.
to the 1& 2 respondent/defendant and pass such other order or
orders as may be deem fit ad proper in the interest of justice.
Date
Place Counsel for the Petitioner
PETITION SCHEDULE PROPERTY
All that part of the No 1191 in Survey No. 112 admeasuring 191.28
Sq. yds Equallnet to 229 Sq Yds situated at Registration District
Adilabad Sub District Mancherial , Jilla Parishath & District Adilabad
block Samithi Laskhtipet mandal Mancherial Gram Panchayath
Naspur Code no 82 village limits , Plot No : 24 sold in vide a Sale deed
in Doc No.1191/1986, Registered on the file of Sub-Registrar
Mancherial District and bounded as follows:
BOUNDARIES

South: Plot No.23
East: Road
West: Plot No 49
Date:
Place Counsel for the Petitioner
JUDGE,MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2

SECTION 151 OFC.P.C
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
FORM NO.7
LIST OF DOCUMENT (Rule 9,10 and 62)
(Under Order VII Rule 14 or Order XIII R.1 of CPC)
AT: MANCHERIAL
O.S.No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
LIST OF DOCUMENTS FILED BY PLAINTIFF .01.2024
SL DATE PARTICULARS OF DOCUMENTS

No.
1. Certified copy of the Sale Deed
number 1191
2. Certified copy encumbrance

Certificate
3. English True Translation of Sale
Deed Document No: 1191
4. Suit Scheduled Property Map
5. Death Certificate of Late Sri Surender
Raju Plaintiff father
6. Addar Card of Plaintiff
7.
Date : 01. 2024

Place: Hyderabad. COUNSEL FOR PLAINTIFF
JUDGE, MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
List of Documents Filed by

plaintiff
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad
AT: MANCHERIAL
O.S.No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
Bank , Street no 2, Gandhi Nagar. Hyderabad 500060 Do hereby
appoint and retain
M/s Sri Smapath Kumar and B.NACHIKETH
Advocate’s , flat no 302, Vaishanvi Estates, Hyderabad
Advocate/s to appear for me/us in the above

Suit/Appeal/Petition/Case and to conduct and prosecute (or defend)
the same and all proceedings that may be taken in respect of any
application for execution of any decree or order passed therein. I/We
empower my/our Advocate/s to appear in all miscellaneous
proceedings in the above suit or matter till all decrees or orders are
fully satisfied or adjusted to compromise and to obtain the return of
documents and draw any moneys that might be payable to me/us in
the said suit or of matter (and I/We do further empower my/our
Advocate/s to accept on my/our behalf, service of notice of all or any
appeals or petitions filed in any court of Appeal, Reference or Revision
with regard to the said suit or matter before the disposal of the same
in this Hon’ble Court.
Certified that the executant who is well acquainted with

English/Urdu/Telugu and this Vakalatnama and the contents of the
Vakalatnama have been read out and explained in
Urdu/Hindi/Telugu to executant as he/she they begin unacquainted
with English who appeared perfectly to understand the same and
signed or put his/her/their name or mark in my presence.
Identified by: Advocate, Executed day of

January 2024
ADVOCATE/HYD
JUDGE, MANCHERIAL
AT MANCHERIAL
OS No. of 2024
Between:
..Plaintiff
AND
….Defendants 1&2
VAKALATNAMA
Filed on: -1-2024

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
FORM NO 2 SUMMONS FOR SETTLEMENT OF ISSUES
(Order V Rules 3 & 5)
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
Sri Madugula Peeraiah
….Defendants
To
Sri Madugula Peeraiah , S/o Not known, Aged about: 60 years,
Whereas the Sri Pavan Kumar Kasu
Has instituted as suit against for : Suit for Permanent Injunction
You are hereby summoned to appear in this court in person or by

pleader duly instructed and able to answer all material questions
relating to the suit or who shall be accomplanied by some person able
to answer all such question on the ………………………… day of
…………………..20 ……………….at 10.30 clocks.
In the forenoon to answer the claim , and further you are hereby
directed to file within 30 days of service of this Summon a written
statement of your defence and to produce on the said by all
documents in your possession or power upon which you base your
defence.
TAKE notice that in default of your appearance and to file your

written statement within 30 days the suit will be heard and
determined in your absence.
GIVEN number my hand seal of this court this
Day of …………………..20
JUDGE
NOTICE : 1 Should you appeared your witness will not attend on their
own accord you can have summons from this court to compel the
attendance of any witness a and production of any document that
you have a right to call necessary witness
2. If you admit the claim you should pay the money in to court
together with cost of the suit to avoid execution of the decree , which
may be against your person or property or both
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
….Defendant
To


…………………..20 ……………….at 10.30 clocks.
defence.

IN THE COURT OF THE HON’BLE PRINICIPAL JUNIOR CIVIL JUDGE,
MANCHERIAL DISTRICT
Day of …………………..20
JUDGE
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
….Defendants
To


…………………..20 ……………….at 10.30 clocks.
defence.

MANCHERIAL DISTRICT
Day of …………………..20
JUDGE
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
Sri Madugula Swamy Das
….Defendants
To
Sri Madugula swamy Das , S/o Not known, Aged about: 45
years, Cast : Scheduled Cast, Occu: private Service, R/o. SC
colony, Mandal: Naspur , District : Mancherial


…………………..20 ……………….at 10.30 clocks.
defence.

MANCHERIAL DISTRICT
Day of …………………..20
JUDGE
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
Sri Madugula Swamy Das
….Defendants
To
Sri Madugula Swamy Das, S/o Not known, Aged about: 45 years,


…………………..20 ……………….at 10.30 clocks.
defence.

MANCHERIAL DISTRICT
Day of …………………..20
JUDGE
AT: MANCHERIAL
O.S No. Of 2024

Between:
..Plaintiff
AND
Sri Madugula Swamy
….Defendants
To
Sri Madugula Swamy Das , S/o Not known, Aged about: 45
years, Cast : Scheduled Cast, Occu: private Service, R/o. SC
colony, Mandal: Naspur , District : Mancherial
Whereas the Sri Kasu Pavan Kumar


…………………..20 ……………….at 10.30 clocks.
defence.

MANCHERIAL DISTRICT
Day of …………………..20
JUDGE
FORM NO 61
(171 payment in to the court of cash /Process Fee deposit)
AT: MANCHERIAL
OS.No of 2024
Between:
Plaintiff
Kasu Pavan Kumar
Petitioner
Appellant
Complainant
Decree holder
AND
Defendant
Sri Madugula Peeraiah & others
Respondent
Accused
Judgment – debtor
Nature of Name and Village Distance Travelling Subsistence
process Description of taluq, in miles allowance AMOUNT allowance
to be person on district from the
issued or whom or on munsiff court PROCESS
purpose whose property where house FEES
for which the process is process
deposited to be executed is to
and executed
order if
any
number
which
deposit
made
Sri 70 70
Madugula
Peeraiah ,
S/o Not
known,
R/o. SC
colony,
Mandal:
Naspur ,
District :
Mancherial
Sri
Madugula
Swamy
das , S/o
Not
known,
R/o. SC
colony,
Mandal:
Naspur ,
District :
Mancherial
It is requested that the sum of Rs.70 may be received for the purpose
above mentioned Date this the day of JAN 2024 COUNSEL
FOR PLAINTIFF

JUDGE, MANCHERIAL
AT MANCHERIAL
OS No of 2024
Between:
Kasu Pavan Kumar
Plaintiff
Petitioner
Appellant
Complainant
Decree holder
AND
Madugula Peeraiah others
Defendant
Respondent
Accused
Judgment – debtor
Process
Fee CASH Deposit Form
Filed on: JAN OF 2024
Filed by: Counsel for PLAINTIFF
Address for Service

B.NACHIKETH
Advocate’s
flat no 302
Vaishanvi Estates
Hyderabad -29
TRUE TRANSLATION
Document No:1191/1986
Serial number : 1598 Document Purchased on dated: 27.03.1986
Document Written on Date: 31.03.1986
Purchaser Name : Adluri Narasimha Raju , S/o Rama Raju
To Whom : Self , R/o.Naspur Village
Stamp duty : Rs 200/- Nature of transaction : Kushki (Dry Land ) sale
deed
SALE DEED
VALUE : Rs.2,000/-
date 31.03.1986
The following suit Scheduled Property Purchased by following
Sri Late Kasu Surender Raju , S/oHanumantha Raju , Age : 30
years, Occupation : Government Employee , Village & Post
Manchiryala ,Hno : 22-55, R/o. Laksitipet , District: Adilabad
herein after called as VENDEE
The following suit Scheduled Property Sold by following

1. Sri Adluri Narasimha Raju , S/o. Sri Rama Raju , Age : 40
years, Occupation : Agriculture , R/o. Hno: 25-55,Village & Post
: Mancherial Taluk : Laksitipet , District : Adilabad
2. Sri Guduru Madhusudan Raju , S/o. Sri Narayana Raju , Age :
45 years, Occupation : Agriculture , R/o. Village & Post :
Mancherial Taluk : Laksitipet , District : Adilabad herein after
called as VENDORS
NATURE
Till date we are absolute owners of this Suit scheduled property which
is immovable writing this Sale Deed document as given schedule
land sold to you without any coercion as well as personal needs For
Rs. 2000/- ( Two thousand rupees only ) purpose and wilful consent
and You can give this land to sons , daughters , inherited family
members , donation , gift or anything with full of rights happily
enjoyed by you. We are bearing all expenses and sold this land to you
and this sale deed will be executed.
SCHEDULE PROPERTY
All that part of the No 1191 in Survey No. 112 admeasuring 191.28
Sq. yds Equallnet to 229 Sq Yds situated at Registration District
Adilabad Sub District Mancherial , Jilla Parishath & District Adilabad
block Samithi Laskhtipet mandal Mancherial Gram Panchayath
Naspur Code no 82 village limits , Plot No : 24 sold to you. vide a Sale
deed in Doc No.1191/1986, Registered on the file of Sub-Registrar
Mancherial District and bounded as follows:
BOUNDARY’S
South: Plot No.23
East: Road
West: Plot No 49
As above mentioned boundaries plot sold to you and surrender to you
.Hence there are no government & Private taxes due if yet all any
taxes are there myself responsible for those. This land is not a
Assigned land & Tribal as per Andhra Pradesh Government
Ordinance No 9/77.
This Scheduled property market value Rs. 2000/-.There is no

objections in this regard and this deed is written my free of consent . I
am writing this document as my as full consent and this document is
true
SIGNATURES OF SELLER
1. Sri Adluri Narasimha Raju
2. Sri Guduru Madhusudan Raju
WITNESS
1, AND 2
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Sri V Thirmal Rao Village : Mancherial
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Pavan Kumar Kasu Injuction at Mancherial

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Pavan Kumar Kasu Injuction at Mancherial

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IN THE COURT OF THE HON’BLE PRINICIPAL JUNIOR CIVIL

JUDGE, MANCHERIAL DISTRICT

2) Sri Madugula Swamy Das, S/o Not known, Aged About 40

PLAINT FILED UNDER ORDER 7 RULE 1

1. DISCRIPTION OF THE PLAINTIFF;

The address for service of summonses notices processes etc., on the

2. DISCRIPTION OF THE DEFENDANT;

The address for the service of summonses, notices processes etc., on

It is submitted that the Plaintiff father acquired the house property

4. It is humbly submitted that the plaintiff’s father (Vendee) has

6. It is humbly submitted that the defendants 1 and 2 with henchmen

7. It is humbly submitted that Plaintiff wants to take help of this

8. It is humbly submitted that defendants have changed their mind

On 15.01.2024 at morning 9.30 am, the defendants with

In view of the above circumstances its time to

The Plaintiff do hereby declare that except the present suit,

8. JURISDICTION & DECLARATION:

The suit is filed within the period of Limitation.

The suit is valued at Rs.10, 000(Rupees Ten Thousands only) being a

Hence verified at Hyderabad on this the day of January 2024.

All that part of the Plot No 24 in survey No.398 admeasuring area

North: Mr. Nagender sing Land

Hence verified at Hyderabad on this the day of January 2024.

1. Certified copy of the Sale Deed number: 1191

PLAINT FILED UNDER

Filed on: -1-2024

Filed by: Counsel for Plaintiff

M/s Sri Smapath Kumar,

2) Sri Madugula Swamy Das, S/o Not known, Aged About 40

1. I submit that I am the petitioner herein and as such I am well

2. It is submitted that the Plaintiff father acquired the house property

4. It is humbly submitted that the plaintiff’s father (Vendee) has

5. It is humbly submitted that the suit schedule property is hard

7. It is humbly submitted that the defendants 1 and 2 with henchmen

8. It is humbly submitted that Plaintiff wants to take help of this

9. It is humbly submitted that defendants have changed their mind

On 15.01.2024 at morning 9.30 am, the defendants with their

In view of the above circumstances its time to approach this Hon’ble

I, therefore pray that this Hon’ble Court may be pleased to

Sworn and signed before me

PETITION FILED UNDER

Filed on: -1-2024

Filed by: Counsel for Plaintiff

M/s Sri Smapath Kumar

2) Sri Madgula Swamy Das, S/o Not known, Aged About 40

PETITION FILED UNDER ORDER 39 RULE 1&2 OFC.P.C

For the reasons stated in the accompanying affidavit it is, therefore

North: Mr Nagender sing Land

Date: Counsel for the Petitioner

PETITION FILED UNDER

Filed on: -1-2024

Filed by: Counsel for Plaintiff

M/s Sri Smapath Kumar

2) Sri Madugula Swamy Das, S/o Not known, Aged About 40

1. I submit that I am the petitioner herein and as such I am well

2. It is submitted that the Plaintiff father acquired the house property

4. It is humbly submitted that the plaintiff’s father (Vendee) has

5. It is humbly submitted that the suit schedule property is hard

6. It is humbly submitted that the defendants 1 and 2 with henchmen

7. It is humbly submitted that Plaintiff wants to take help of this

8. It is humbly submitted that defendants have changed their mind

9. It is humbly submitted that Defendants 1 and 2 with their

In view of the above circumstances its time to approach this Hon’ble