AN THI HONOURABLE count op THE REVENUE DIVISIONAL OFFICER: ALLE AT ANAKAP, Between RC No aaaanan PAPPAIa Dont Rang ee And Hagpondents POtun Siigkahe) ang others cou INTER FILED ow BEHALF OF RESPONDENT (POTLUR! SRILAKSHM) 1 The materiay allegations af tha above arpeal are nat inze, correct and denied by Ne espondent and (he appetant is put to strict proof of all those allegations which are MOL expressiy Naversed herein and shall not deen to have admitted by tis FespondenuPotlur: Sritakshy ms lakshm 3 me vi inet martanatio under aw otapoeal len! Potiuri Srilakshmi humaly submit that the allegations of ape: Contra 10 the folowing are not tive, correct and denied 41) This respondent Potlun Srlakshimi respectably submits that originally, the Schedule comprising property of an extent of Ac. 422 cents nS. No, 22 of Kulapaka fevenue village was belongs to fst origin of Pappala and Indsta people. Atter the dealh Of those first origin, ine said property was devolved to their descendents Accordingly. head of one ranch, Pappata Sanyasi got four sons namely (1} Pappain Sanyasi (2) Pappala Kannoyya (3) Pappaia Narasayya (4) Pappata Peda Kanakayya. On their ‘eath, the said property was devolved to their sons respectively to (1) Pappala Sanyasi who Ig son ef Sanyasi (2) Pappala China Kanakayya who is san of Kannayya (3) Pappata Moola Konda wha is son of Narasayya (4) Pappala Apparao who is son of Pega Kanakayya (b) On the death of another head of some other branch, Pappala Ademma g/o late Peda Kanakayya, his share of property was devolved to his son Pappata Apparao. (c) Their names were mutated in tevenue records for their land helding and they got im Possession with absolute nights in respect of the abave said survey number proparty with absolute owners. (4) Subsequently, the above sal¢ sharers (1) Pappala Sanyasi (2) Pappata China Kanakayya, (3) Pappaia Moola Konda and (4) Pappaia Apparaa jointly sold away of an extent of Ac. 3-25 cants in S. No. 22 af Kalapaka village and some other property to Viyyapu Tatalu sfo Venkataswamy by virtue af registered sale desd dated 02-03-1987 vide document No. 626/1987 for a’ valuable sale consideration, Recognising the possession and enjayment of those sale deed lands with absolute rights, the revenue authorities and issued pattadar and tile deed passbooks dated 20-10-2000in his In respect of some of extent in S. No. 22/1 with measuring Ac. 0-7 cents and S.No. 22/2 for an extent of Ac 0-74 cents and S No. 22/3 for an extent of Ac, 7-20 cenls of Kalapaka village, Since then, the said Viyyapu Tataly got in possession with absolute rightssad SIEM TALI wie yy stent of isang Mil many nF A aes Lae SAN alaeany ay tbs agi af Ratapab ne Bra tm Ponti mann Prison (aenitedt Timea eu Me taB00M tees ven wed Peaenya eee eee ain taan ae ene Ve gat gala simmrd ot enciten tho ivy mts VaR O64 a bane 8 mere tg cual E88 tate eH) 279 Vet wt astan| cf ae 110 ents 0 th ami Vivvape Hatali gel abectate pity e NN Sal th ware fa Hrabriga Cometruetions will ceva titles hia Peabien ” * {0 Therein, the pee a enn PSP" FespAneinn Pete’ fuabanen Sebedule MOPCITY Abt waMD Ethny Moporins fh | purchneed the present 268 Priaaln nie saitiied mene Seed dalnd 19.01.9019 wete document Ha SANE ene roe i" | Lankolapatam fa oF valitl Mala considntutan Since inep sad respondect Poti! Srtahehyn) OES Linwert ly wilh Of relator ana 91 im peasesnian and enjoy enjoyment of all those lands including present pl neluding PIN Schedule rape periseing wan lar nght and tin The gait sate deea Reid through Power of Ay ever by: nams’ Paik Stine fo Raghavendra of Praliya Canstructions Private Limited tor 12012 19) The internat evidence of the Kriya Constructions " Farticulay from Viyyapy Gotument Na.1412/2008 regis Private Limited putchased piain schedule property Tatalu etc under regs Sale deed 12642008 vide tered in SRO Lankslapaigm Sa) Thus this respondent Pet ‘uri Slakshmi continued her Possession and enjoyment Of Per Jand and some other tand and Fecegnizing the same, the revenue aulthetion ‘ssued Battadar and tiie deed pass Looks bearing €. No 627451 of Kalapaxa witage far the present plaint schedule Properly end some other properly to the respondent f Potluri Srilakeshmi under the A.P, Recsed of Rightsin Land ‘and Pattadar pasebooks Act (b) Accordingly, the mame of the respondent/Potlunt Shlzkahmi was entered in the Fevenue records as register patidar Since then, she got in possession and enjoyment | ‘wah absclute ovner in respect of piaiM schedule and some cther property. Accordingly, the Tahsiitar, Paravada issued Na 3 sdangal copy The Tabsikfar, Paravada Mandal esued 1-@ Register cony dated 22-08-2022 confining the issuance of pattadar and tile Seed passbooks to the 3° defendant covered by passbook palta No, S$ fer the platnt schedulo property ty entering in 1B register. Accordingly, the respendenvPotlur Sriiskshmi Is Jn possession and enjoyment of plait schedule property cantinuing sinee her predecessors with the knowledge cf ane and ail including the plointif Fr. fc} Later, the respondent’Patiurt Srlakshiw sold away of an extent of land Ae 0.02% cls in out of land purchased as stated above Le. Ac, 0-74 cents covered by S.No, 2212 af Kalapaka wilage {vdich Is covered in plaint schedule Property) ta the Hindula National Power Construction under regd, Sale need at.30.3, 2015 vide document No. 8186/2015 tor valid sale consideration sand registered in SRO Lonkelapaiom. On that the: respondent Pottufi Sriakshow is having the remaining extent of fand Ac. 0-71 Ye-cents InST ; ‘out of Ac 0-74 cents 3 nants 6 The ay enjoyment of the appeliantipes: ‘S70 BY Blatht teheduie and ant in porsession with absolute Ppetiany; teed Petitioner oF hig family members mevor been in possession and PFOPEHY ond they have nathing to do wilh the same The so called Won °F Rot bslogical gon of the person belonging to fst ongin of 1s completely MEF Is makin ©F enquines came to know that for some time the 9 fAISe claims with cour Atigations with a view fo grab Ihe metent Persons and in such a manner he filed a false case/complaint the name of meat SFA reveais that te tand of Ac.0.74cts in S.ND.22/1 ast " S.N0.2202 stands ing ner Para Wo a1Dand whereas the land af Ae. 0 74 en AG1.20cts,. in 5. '@ Name of Pappata Arpanna under Patta No411, and the land ol Narayana obi 9.22/3 stands in the name of Pappala Ademma and her sons, Aes a '@ Kanakayya and Peda Kanakayya under Patta No.454 and the land of ©:1-64¢l8.in S.No.22/4 stands in the. name of Indala Sanyasi under Palta No.243 Accordingly, Separate pass backs wete issued in thelrindwidual names Properties of in 7 Ascordi 8. The documents filed by the appella nt/petitioner will not confer any right te the him and the same will net bind ine legal rights of this respondent’Potluri Srilakshmni 8. This respondenuPotlun Srilakshmi submit that the appetant have na land. The appellant also filed a suit against this respondent and Prakriya Constructions, Hindula National Power Constructions and Viyyapu Musatsyya @ Appalanaidu In respect of S. No. 22/2 of Kalapaka village in OS No. 44/2020 on the file of Honourable court of the Principal Junior Civil Judge at Anakapalle. The said suil is pending in the Hon'ble Court and also | am contesting the same. After filing the suit, the present appellant filed application before you. So, the said application is not entertain this application. 10. This respondenvPotturi Sritakshmi therefore pray that the Honourable court may be pleased to dismiss the above appeal with costs. Respondent Anakapalle, } «Poturi Sritakshmi) Dk }