IN THE HONOURABLE COURT OF THE REVENUE DIVISIONAL OFFICER: 7 AT ANAKAPALLE wacar, RC No, 346/2023 Pappala Demudu Raju Appellant And Potiun Sritakshmi and others: Respondents COUNTER FILED ON BEHALF OF RESPONDENT (POTLURI SRILAKSHM) 1. The materia allegations of the above appeal are not true, correct and deried by, the respondent and the appellant is put to strict proof of all those allegations which are ‘ot expressly aversed herein and shall not deem to have admitted by this respondent/Potluri Sriiakshmi. 2 The appeal is not maintainable under law 3, This respondent Potluti Srilakshmi rumbly submit that the allegations of appeal contra tothe following are fot true, correct and denied 4(a) This respondent Potluri Srilakshen) respectably submits that originally, the schedule comprising property of an extent of Ac. 4-22 cents in S. No. 22 of Kalapaka revenue village was belongs to first origin of Papeala and Indela people, After the death of those first ongin, the said property vas devolved to their descendents. Accordingly, head of che branch, Pappala Sanyasi got four sons namely (1) Pappala Sanyasi (2) Pappala Kamnayya (3) Pappaia Narasayya (4) Pappala Peda Kanakayya. On their deatn, the said properly was devolved to their sons respectively to (1) Pappala Sanyasi who is son of Sanyasi (2) Pappala China Kanakayya who is. son of Kannayya (3) Pappala Moola Konda who is son of Narasayya (4) Pappala Appatao who is son of Peda Kanakayya fo) On the death of another head of some alter br fare of property Was. devolved (o his son Pappala Apparac. 3h, Panala Ademma sio late Peda Kanakayya, hiss (@) Their names were mutated in revenue records for their land holding and they got in possession with absolute rights in respect of the above said survey number praperty with absolute owners. y, the above said sharers (1) Pappaia Sar ariel Bulsoes ai yyasi (2) Pappaia China anakayya, (2) Pappala Moola Korea and (4) Pappsia Aoparao joinly sold away ofan vtent of Ac. 3-25 cents in &. No. 22 of Kalapaka vilage and some ather property to Viyyapu Tataly lo Venkataowany by vrs of reuistred sale deed dated 02-09-1987 vide document No. 26/1967 for # valuable sele consideration. Recognising the «enjoyment of those sale deed fands with absolute igh, the revenue sued pattadar and tte deed passbooks dated 20-10-2000 tis in reins of wore of asane a. Noun] Yaen moemuha A GFE Cone and No. 22/2 Fexcan aback: Ct conOn rd : Te, 228 Tae ast of Ac. 1-20 cents of Kalapaka vilage. Since then, the eaid Virvape ‘Tatalu got \n possession with absolute rights. possession ant ‘authorities andway of an extent of 12/2 of Kalapaka ste Limited (©) Therwatie, the sad Viyyapu Tatalt slo Verikataswamy sold a jrased as stated above) in S. No. 2 ‘Ac. 0-74 cents (in out of land purct sitage sth apectivng the boundaries, tothe Prakriya Constructione Prival 4412/2008. Since then, the said Prakriya dated 26-04-2008 vide document No. CConatnyelone got n-poasession wih absolute righs. In the sald wale deed [ee ites that the vendors Viyysnu Tatalu got the paltadar passbook beating C. No, 115403 and 18 patia!No. 354 in reapect of S.No. 2212 for an extent of Ac, 0-74 cents, So, the said \Viyyapia Tatalu got absolute rights and he sold the same to the Prakria Constnuctions with clear title 1) Thereafter, the present respondent Potlurl Srilakshmi purchased the present etiedule property and. some other properties fram Prakkriya Constructions: Private Limted by vitue of registered sale doed dated 19-01-2012 vide Gocument No, 854/2012 which was registered in SRO, Latkelapalem for valid sale consideration. Since then, the said respondent Potluti Srilakshmi got in possession and enjoyment of all those lands cluding present plaint schedule property perfected With clear, rightand tile, The sald sale deed held through Power of Attorney by name Pollur| Srinivas s/o Raghavenira fae acted as authorized Agent of Praikriya Constructions Private Limited for resentation of drafted sale deed at 191.2012 g) The internal evidence of the eaid sale.deed dated 19-01-2012 reveals that the ig Privaie Limited. purcnasod plain‘ schedule property under read. Sale deed dt 2642008 vide vender \¢. Praikriya Gonstn ih particular from Viyyapu T gocuent No.1412/2008 registered in SRO Lankelanaiam. 4), Trus this respandant Poll Srtakshmi eantinued her possession and enjoyment of het land and so) 1 land and fecognizing the same, the revenue authorities iesued pattadar and tile deed pass books bearing C, No, 627491 of Kelopak vitage for the present pint schedule property and some olher property 1 the respondent / Pett stlakshrni under tre A P. Record of Rights in Lane! and Pattadar passboors Act. te) Aacorsinaly, the name of the respondertPetiun Sriakshmi was entered in the reverue records as register pottdar, Since then, she got in possession and enjoyment saith absolute owner in rospect of paint schedole and some other property. Accordingly the Taheidar, Paravaca Issued No. adangal capy. The Tahsldar, Paravada Mandal ied 1-B Register copy dated 22. 12 confirming the issuance of pattadar andi tite jered by passbook patta No. 55. for the plaint Accordingly, the fespendentiPotiun deed passbooks to the 3 cefe seneduie property by entering in 1B. register. Silekshmi 1s fn possession and enjoyment of plant schedule property continuing since har pedecossors with the knowledge of one andi alt including the plaintif fe) Late the rsondertPothr Sela sold away ofan extent of and Ac.0.02%4 tg in out of land purchased as stated above i, Ac. 0-74 cents covered by S.No. 22/2 of Kalapaka vilage (which 5 covered in plaint schedule property) ta the Hinduja National Power Construction under 1694. Sate dead at 30.3.2016 vide document No.916/2018 for valid. sole consideration and registered in SRO Lankelapalem: On that the espondentiPotlr SriaKshnt is having sho remaining extent of land Ac: 0-71 Ys cents inTh crore amano er ee oe npn the appellant/pstiioner is a a they have nothing to do with the same. The so cal Pappala people as aforesaid iological son of the person belonging to first origin of ee ee ’aid and no such a person in that village and he is completely poridant ah enquiries came to know that for some time the appellartipetitioner is making false ciaims with court Itgations with a view to grab the Properties of innocent persons and in such a manner he filad a false case/eomplaint 7 Accordingly, the SFA reveals that the land of Ac.0.74ets. in S.No.22/1 stands in the name of Pappala Sanyasi under Patta No.410 and whereas the land of Ac.0.74cts in S No.22/2 stands in the name of Pappala Appanna under Patta No.411, and the land of 2068s. in S.No22/3 stands in the name of Pappaia At wna and her sons, Narayana, China Kanakayya and Peda Kanakayya under Patta No.464 and the land of .c1.84cts in S.No.22/4 stands in the name of Indala Sanyasi under Patta No243 Accordingly, separate pass books were issued in their individual names. ‘The documents filed by the appoliant/petitioner will not confer any right to the him and the same will not bind the legal rights of this respondentiPotluri Stilakshmi 9, This respondentiPotluri Srilakshmi submit th appellant als and Prakrya Constructions, Hinduja National Power Consisuctions and Viyyapu Musalayya @ ne appellant have no land. The suit against this respon Appaianaicu in respect of 8 No. 22/2 cf Kalapaka village in OS No. 44/2020 on the fle of Honourable Court ofthe Principal Junior Civil Judge at Anakapalle, The said suit 's pending in the Hon'ble Court arid also | am coniesting the same. After filng the sult, the present appellant filed application before you. So, said applicat nis nol entertain this application 40. This respondent/Potluri Srilakshmi therefore pray that 1 ne Honourable court may be pleased to dismiss the above appeal with costs. Anakapalle, } Ot } Respondent (Potluri Sriiakshmi)