IN THE COURT OF THE HONORABLE ……………………………… JUDGE,

AT HANAMKONDA, HANAMKONDA DISTRICT

O.S. No. OF 2023

BETWEEN:

GADIPE PRASHANTH S/O ILAIAH,

Age about 42 Years, Occ: Advocate,
Flat No.101, Sun Residency,
Annapurna Colony, Mallapur,
Hyderabad, Telangana State,

..Plaintiff/Petitioner
AND

1. Dr. MULKA CHANDRAMOULI, S/O GOPAIAH,

Aged About 47 Years, Occupation: Pvt. Practitioner,
R/O Flat No.202, Ganapathi Apartment,
Near Amrutha Theatre,
Hanamkonda Dist, Telangana State.

2. Mrs. Bommathi Gouthami W/O Dr. MULKA CHANDRAMOULI

D/O Bommathi sudarshan, aged about 36 years,
R/O Flat No.202, Ganapathi Apartment,
Near Amrutha Theatre,
Hanamkonda Dist, Telangana State
..Defendant/s

PLAINT FILED UNDER SEC.26 & ORDER-7, RULE 1&2 OF C.P.C.

I. DESCRIPTION OF THE PLAINTIFF’S :

GADIPE PRASHANTH S/O ILAIAH, Age about 42 Years, Occ: Advocate,

Flat No.101, Sun Residency, Annapurna Colony, Mallapur, Hyderabad,
Telangana State.
The address of the Plaintiff’s for the purpose of service of all notices,
summons and process etc., is that of their counsel M/s G. Ravi kumar,
Advocate, Reddy's Law Associates, H.No.9-94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony, Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile: 73308 92719. Email: pra.atdc@gmail.com
II. DESCRIPTION OF THE DEFENDANTS:
1. Dr. MULKA CHANDRAMOULI, S/O GOPAIAH,Aged About 47 Years,
Occupation: Pvt. Practitioner, R/O Flat No.202, Ganapathi Apartment,
Near Amrutha Theatre, Hanamkonda Dist, Telangana State.
2. Mrs. Bommathi Gouthami W/O Dr. Mulka Chandramouli,D/O Bommathi
Sudarshan, aged about 36 years,R/O Flat No.202, Ganapathi Apartment
Near Amrutha Theatre, Hanamkonda Dist, Telangana State.
The address of the defendants for the purpose of service of all notices,
Summons and process etc., is the same as mentioned above.
II. Brief facts of the case:

1. It is submitted that Defendant no. 1, is the sole and absolute owner in

possession of Open plot situated at HANAMKONDA Revenue Village,
Sy.no.1089 with in Greater Warangal Municipal Corporation Limits,
Warangal Dist. and within the registration Dist. Warangal and Sub-Dist.
Warangal Urban, to an extent measuring of 116 Sq. yards or 96.97
Sq.mts. Bearing Registered Sale Deed vide Doc. No. 18272/2018 dated
27.08.2018.

2. It is submitted that, earlier Defendant no.1 had a purchased above

said scheduled property from Thakkalla Kumaraswamy @ Raja Kumara
Swamy S/o Late Rajaiah through a registered sale deed bearing a vide
document no.18272/2018, SRO Warangal on dated 27.08.2018.

3. It is submitted That, Defendant no.1 had approached Plaintiff and

offered to sell the suit schedule property, it is further submitted
that, defendant No.1 had expressed to plaintiff that defendant
No.1 is in dire need of money to meet debts and expenses.

4. It is submitted that, it is also relevant to state that negotiations

with regard to sale consideration and other terms of sale were
finalized between the Plaintiff and defendant No.1, during the
course of such negotiations, both came to conclusion for the price
of suit schedule property for a total sale consideration of
Rs.13,34,000 /- (Thirteen Lakhs, Thirty Four Thousand Rupees
Only)@ Rs 11,500 per yard.

5. It is submitted that, The Defendant No.1 made the Plaintiff to pay

Total amount of Rs 13,34,000 /- (Thirteen Lakhs,Thirty Four
 Thousand Rupees Only) @ Rs 11,500 per yard, Cash as the
Defendant no.1 requested to meet his urgent needs, in respect of
said property. It is also submitted that, defendant No.1 also
executed a simple sale deed towards plaintiff on Rs. 100/- Non-
judicial stamp paper bearing No, Z 466034 on dated 09.09.2021
along with acknowledge receipt of amount received.

6. It is submitted that the defendant No.1 had requested to plaintiff

that he will execute a registered sale deed within a week i.e. on
16.09.2021, it is further submitted that, after one week plaintiff
called on mobile phone defendant no.1 and requested to execute a
registered sale deed, later defendant No.1 replied that he will
execute within a couple of days over on phone.

7. It is submitted that, the defendant No.1 is well known

‘ACUPUNTURE’ Doctor and having familiar name in Hanamakonda
Town. It is further submits that, On 20.09.2021 Defendant No.1
came to plaintiff and requested that Defendant No.2 i.e. his wife
is sick, suffering from Covid and assured Plaintiff to execute the
registered sale deed before 30.09.2021.

8. It is submitted that the Plaintiff have been requesting the

Defendant no.1 to execute a regular Registered Sale Deed in their
favour, but the Defendant no.1 has been postponing the matter on
one or other pretext, though the Plaintiff having patience obeying
the words of the Defendant no.1. It is further submits that on
10.11.2021, plaintiff went to defendant No.1 residence to ask and
request to execute a registered sale deed, there plaintiff found
door Lock and enquired about both defendants neighbor’s, but no
one had whereabouts.

9. It is submitted that the Defendant no.1 has dodged the matter by

not meeting the Plaintiff regularly since the month of 30.09.2021
by not facing, the attitude of the Defendant no.1 is very much
 cheating in nature and the way adopted by the Defendant no.1 is
illegal and untenable under law. It is submitted that plaintiff vexed
with the dilly dally attitude of the Defendant no.1, it is further
submits that plaintiff came to know on checking Encumbrance
Certificate on Online and shocked, that on 05.10.2021 Defendant
No.1 executed a ‘Mortgage of Deposit of Title Deed’ towards
Defendant No.2 bearing Registered document no. 25420 of 2021
AT HANAMKONDA SRO.

10. It is submitted that, after searching a lot, after approximately two

years, on 24.06.2023 plaintiff found defendant no.1 at his
residence. It is further submitted that plaintiff requested to
defendant No.1 to release the Mortgage of Deposit of Title Deed’
from defendant No.2 and execute a registered sale deed.

11. It is submitted that both defendant No.1 and defendant No.2 is

creating some dill dolly stories, that defendant No.2 is saying that
defendant No.1 is not her husband. it is further submits that, It is
reliably learnt that the both husband and wife i.e. Defendant No.1
and Defendant No.2, Were colluded and trying to negotiate with
the third parties to alienate the Suit Schedule Property in view of
the increased market value.

12. It is submitted that, the plaintiff had approached Local Police

station and given a complaint on defendants, as it is in Civil in
nature, the police authorities had advised plaintiff to approach
Hon’ble court. It is further submitted that, the plaintiff served a
legal notice on 01.07.2023, through by hand and same was
acknowledge defendants, but no response from defendants side,
which clearly establishes that the Defendants is bent upon to
usurp the hard-earned money of the Plaintiff and cause wrongful
losses to them.
 13. It is submitted that In the event, the Defendants succeeds in his
ill attempts of alienating the Suit Scheduled Property to third
Parties, the Plaintiff will be put to irreparable loss and injury which
cannot be compensated by any means. Hence this Suit.

CAUSE OF ACTION:-
The cause of action arose on 09.09.2021 when the Plaintiff and
the Defendant No.1 had executed a simple sale deed towards
plaintiff on Rs. 100/- Non-judicial stamp paper bearing No,
Z466034 on dated 09.09.2021 along with acknowledge receipt of
amount received to the Plaintiff. The cause of further arose when
the Defendant no.1 even after promising to execute a registered
Sale Deed in favour of the plaintiff failed to comply with his words
and started dodging the matter of receiving remaining sale
consideration and convey title in favour of the Plaintiff herein. The
cause of action further arose when the Plaintiff was constrained to
issue a Legal Notice dated: 01.07.2023 calling upon the Defendant
No.1 and Defendant No.2 to execute a registered Sale Deed in
favour of the Plaintiff. The cause of action finally arose when the
Plaintiff learnt that the Defendants are trying to negotiate with
third parties to alienate the Suit Schedule Property and the same
is continuing and subsisting.

V. JURISDICTION:
This Hon'ble Court has jurisdiction to try the suit, the suit-scheduled
Property is in Balasamudram , Hanamkonda and which is in the territorial
and pecuniary jurisdiction of this Hon'ble Court.

VI. LIMITATION:
The Plaintiff submits that the suit is filed within limitation.
VII. DECLARATION:
The Plaintiff submits that, they have not filed any other suit or other
proceedings are pending between the parties for similar relief in respect of
the subject matter of the suit.
VIII. COURT FEE & SUIT VALUATION:

The Present market value of the suit schedule property admeasuring 116
sq.yards, is valued at Rs 13,34,000 /- @ Rs 11,500 per yard, being the
market value of the suit schedule plot. The court fee payable in a suit for
declaration and injunction in respect of immovable property is on ½ of the
market value which is Rs. 6,67,000/-. A court fee of Rs 9126 /- paid herewith
under section 24(B) of APCF and S.V.Act.

Further the plaintiff also seeking the relief to declare the ‘Mortgage of Deposit
of Title Deed’ bearing Registered document no. 25420 of 2021 on 05.10.2021,
which was executed by Defendant No.1 towards Defendant No.2, AS NULL
and VOID and said relief is notionally valued at Rs 10,000/- and court fee of
Rs 786 /- is paid herewith under section 26(c) of APCF and S.V.Act.

And thus total court fee of Rs 9912 /- is paid which is sufficient

PRAYER:

The plaintiff most humbly pray that this Hon’ble Court may be pleased
to decree the suit with costs in the following manner:
i) That a decree declaring that the plaintiff is the absolute owner of
the suit schedule plot and for a permanent injunction restraining
the defendant and his men from interfering with the peace full
position of the schedule plot by the plaintiff,
ii) That to declare the ‘Mortgage of Deposit of Title Deed’ Registered
document bearing no. 25420 of 2021 on 05.10.2021, which was
executed by Defendant No.1 towards Defendant No.2, AS NULL and
VOID.
iii) That the cost of the suit be awarded,
iv) That to grant any other relief or reliefs as this Hon’ble Court deems
fit and proper in the circumstances of the case and in the interest
of justice.

DATE: 2023
Hanamkonda PLAINTIFF

Counsel for Plaintiff

 VERIFICATION

I, Gadipe Prashanth S/O Ilaiah, Age about 42 Years, Occ: Advocate,

Flat No.101, Sun Residency, Annapurna Colony, Mallapur, Hyderabad,
Telangana State, herein do hereby declare that the contents of the Plaint
No.1 to 13 are true and correct to the best of my knowledge, belief and
information and as per legal advice received.
Hence verified on, 2023 AT HANAMKONDA .

Date:
Hanamkonda PLAINTIFF/petitioner

SUIT SCHEDULE OF PROPERTY

Open plot situated at HANAMKONDA Revenue Village, Sy.no.1089 with in

Greater Warangal Municipal Corporation Limits, Warangal Dist. and within the
registration Dist. Warangal and Sub-Dist. Warangal Urban, to an extent
measuring of 116 Sq. yards or 96.97 Sq.mts, Telangana State.

BOUNDARIES AS FOLLOWS:

NORTH : HOUSE OF B.VIDYASAGAR

SOUTH : 30 Feet Road Wide
EAST : HOUSE OF VENKATESHWAR RAO
WEST : 30 Feet Road Wide

Date:
Hanamkonda PLAINTIFF/Petitioner
IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA DISTRICT

O.S. No. OF 2023

BETWEEN:
Gadipe Prashanth
..Petitioner/Plaintiff
AND

Dr. Mulka Chandramouli and another

..Respondents/Defendants
LIST OF DOCUMENTS
Date if any
of
Description of
S.No documents Parties to the Document
Document
vernacular
in English
Simple sale deed copy
1. 09.09.2021 Simple Sale Deed between Plaintiff &
Defendant No.1(Original)
Bearing Registered Sale
Deed vide Doc. No.
2. 27.08.2018 Registered sale deed 18272/2018 dated
27.08.2018,(Xerox) of
Defendant No.1
‘Mortgage of Deposit of
‘Mortgage of Deposit of Title Title Deed’ Registered
3. 05.10.2021 document bearing no.
Deed’ Registered document
25420 of 2021 on
05.10.2021,(Xerox)
4. 01.07.2023 Legal notices Legal notices to defendant
No.1 & 2
5. Encumbrance certificate Encumbrance certificate of
suit schedule Plot

6. Marriage certificate Marriage certificate of

Defendant No.1 and No.2

Date:
Hanamkonda PLAINTIFF/Petitioner

Advocate for Petitioner’s/Plaintiff’s.

 IN THE COURT OF THE
HONORABLE
……………………………… JUDGE,
AT HANAMKONDA ,
HANAMKONDA DISTRICT

O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Peti
tioner/Plaintiff
AND

Dr. Mulka Chandramouli and another

..Respondents/Defendants

LIST OF DOCUMENTS

FILED ON:

FILED BY:
M/s Ravi Kumar, Advocates,
Reddy's Law Associates, H.No.9-
94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony,
Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile:
9395192719. Email:
pra.atdc@gmail.com

COUNSEL FOR PETITIONER

IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA, HANAMKONDA DISTRICT

O.S. No. OF 2023

BETWEEN:

Gadipe Prashanth
..Petitioner/Plaintiff
AND

Dr. Mulka Chandramouli and another

..Respondents/Defendants

VERIFICATION AFFIDAVIT

I, Gadipe Prashanth S/o Ilaiah, do hereby solemnly and sincerely affirm

and sincerely state on oath as follows:

1. I am the Petitioner herein and as such I am well acquainted with the

facts of the case.

2. It is submitted that Defendant no. 1, is the sole and absolute owner in

possession of Open plot situated at HANAMKONDA Revenue Village,
Sy.no.1089 with in Greater Warangal Municipal Corporation Limits,
Warangal Dist. and within the registration Dist. Warangal and Sub-
Dist. Warangal Urban, to an extent measuring of 116 Sq. yards or
96.97 Sq.mts. Bearing Registered Sale Deed vide Doc. No.
18272/2018 dated 27.08.2018.

3. It is submitted that, earlier Defendant no.1 had a purchased above

said scheduled property from Thakkalla Kumaraswamy @ Raja
Kumara Swamy S/o Late Rajaiah through a registered sale deed
bearing a vide document no.18272/2018, SRO Warangal on dated
27.08.2018.
4. It is submitted That, Defendant no.1 had approached Plaintiff and
offered to sell the suit schedule property, it is further submitted that,
defendant No.1 had expressed to plaintiff that defendant No.1 is in
dire need of money to meet debts and expenses.

5. It is submitted that, it is also relevant to state that negotiations with

regard to sale consideration and other terms of sale were finalized
between the Plaintiff and defendant No.1, during the course of such
negotiations, both came to conclusion for the price of suit schedule
property for a total sale consideration of Rs.13,34,000 /- (Thirteen
Lakhs, Thirty Four Thousand Rupees Only)@ Rs 11,500 per yard.

6. It is submitted that, The Defendant No.1 made the Plaintiff to pay

Total amount of Rs 13,34,000 /- (Thirteen Lakhs,Thirty Four
Thousand Rupees Only) @ Rs 11,500 per yard, Cash as the Defendant
no.1 requested to meet his urgent needs, in respect of said property.
It is also submitted that, defendant No.1 also executed a simple sale
deed towards plaintiff on Rs. 100/- Non-judicial stamp paper bearing
No, Z 466034 on dated 09.09.2021 along with acknowledge receipt of
amount received.

7. It is submitted that the defendant No.1 had requested to plaintiff that

he will execute a registered sale deed within a week i.e. on
16.09.2021, it is further submitted that, after one week plaintiff called
on mobile phone defendant no.1 and requested to execute a
registered sale deed, later defendant No.1 replied that he will execute
within a couple of days over on phone.

8. It is submitted that, the defendant No.1 is well known ‘ACUPUNTURE’

Doctor and having familiar name in Hanamakonda Town. It is further
submits that, On 20.09.2021 Defendant No.1 came to plaintiff and
requested that Defendant No.2 i.e. his wife is sick, suffering from
Covid and assured Plaintiff to execute the registered sale deed before
30.09.2021.
9. It is submitted that the Plaintiff have been requesting the Defendant
no.1 to execute a regular Registered Sale Deed in their favour, but
the Defendant no.1 has been postponing the matter on one or other
pretext, though the Plaintiff having patience obeying the words of the
Defendant no.1. It is further submits that on 10.11.2021, plaintiff
went to defendant No.1 residence to ask and request to execute a
registered sale deed, there plaintiff found door Lock and enquired
about both defendants neighbor’s, but no one had whereabouts.

10. It is submitted that the Defendant no.1 has dodged the matter by not
meeting the Plaintiff regularly since the month of 30.09.2021 by not
facing, the attitude of the Defendant no.1 is very much cheating in
nature and the way adopted by the Defendant no.1 is illegal and
untenable under law. It is submitted that plaintiff vexed with the dilly
dally attitude of the Defendant no.1, it is further submits that plaintiff
came to know on checking Encumbrance Certificate on Online and
shocked, that on 05.10.2021 Defendant No.1 executed a ‘Mortgage of
Deposit of Title Deed’ towards Defendant No.2 bearing Registered
document no. 25420 of 2021 AT HANAMKONDA SRO.

11. It is submitted that, after searching a lot, after approximately two

years, on 24.06.2023 plaintiff found defendant no.1 at his residence.
It is further submitted that plaintiff requested to defendant No.1 to
release the Mortgage of Deposit of Title Deed’ from defendant No.2
and execute a registered sale deed.

12. It is submitted that both defendant No.1 and defendant No.2 is

creating some dill dolly stories, that defendant No.2 is saying that
defendant No.1 is not her husband. it is further submits that, It is
reliably learnt that the both husband and wife i.e. Defendant No.1 and
Defendant No.2, Were colluded and trying to negotiate with the third
parties to alienate the Suit Schedule Property in view of the increased
market value.
 13. It is submitted that, the plaintiff had approached Local Police station
and given a complaint on defendants, as it is in Civil in nature, the
police authorities had advised plaintiff to approach Hon’ble court. It is
further submitted that, the plaintiff served a legal notice on
01.07.2023, through by hand and same was acknowledge
defendants, but no response from defendants side, which clearly
establishes that the Defendants is bent upon to usurp the hard-
earned money of the Plaintiff and cause wrongful losses to them.

Hence, it is prayed that this Hon'ble Court may be pleased to pass a

decree and judgment in my favour and against the defendants and such other
reliefs as this Hon’ble Court may deem fit and proper in the circumstances of
the suit.

Last page corrs. Deponent

Solemnly and sincerely affirm this
the day
and signed his name in my presence.

BEFORE ME
ADVOCATE :: Hanamkonda
IN THE COURT OF THE HONORABLE
……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA
DISTRICT

O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Plaintiff

and

Dr. Mulka Chandramouli and another

..Defendant/s

VERIFICATION AFFIDAVIT

FILED ON:

FILED BY:
M/s Ravi Kumar, Advocate,
Reddy's Law Associates, H.No.9-
94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony,
Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile:
9395192719. Email:
pra.atdc@gmail.com

COUNSEL FOR PETITIONER

IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA DISTRICT

O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Plaintiff

and

Dr. Mulka Chandramouli and another

..Defendants
AFFIDAVIT FILED UNDER ORDER VI, RULE-15(4) OF C.P.C.

I, Gadipe Prashanth S/o Ilaiah, do hereby solemnly and sincerely affirm

and sincerely state on oath as follows:
1. I am the petitioner/plaintiff in the above suit and as such I am well
acquainted with the facts of the case and depose as under and file this
affidavit as under:
2. I submit that I have filed the suit for Declaration and Injunction, and
also to declare the ‘Mortgage of Deposit of Title Deed’ registered document
bearing no. 25420 of 2021 on 05.10.2021, which was executed by Defendant
No.1 towards Defendant No.2, AS NULL and VOID., against the defendants
herein.

3. I submit the contents of the plaint, averments made therein are true,
correct and genuine one. I also filed the documents along with the plaint.

Hence, I pray this Hon’ble Court to Decree the above suit as prayed for.

last page corrs. Deponent

Solemnly and sincerely affirm this
the day of
and signed his name in my presence.

BEFORE ME
ADVOCATE :: Hanamkonda
IN THE COURT OF THE HONORABLE
……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA
DISTRICT

O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Plaintiff

And

Dr. Mulka Chandramouli and another

..Defendants

AFFIDAVIT FILED UNDER

ORDER-VI, RULE-15(4) OF C.P.C.

FILED ON:

FILED BY:
M/s Prashanth Gadipe, Advocate,
Reddy's Law Associates, H.No.9-
94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony,
Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile:
9395192719. Email:
pra.atdc@gmail.com

COUNSEL FOR PETITIONER

IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA DISTRICT

O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Plaintiff

and

Dr. Mulka Chandramouli and another

..Defendants

STATEMENT OF ADDRESS UNDER ORDER VI RULE 14 A C.P.C

Plaintiff/s Name and Address Defendant/s Name and Address

GADIPE PRASHANTH S/O ILAIAH,
Age about 42 Years, Occ: Advocate,
Flat No.101, Sun Residency,
Annapurna Colony, Mallapur,
Hyderabad, Telangana State,
1. Dr. MULKA CHANDRAMOULI, S/O
GOPAIAH,Aged About 47 Years,
Occupation: Pvt. Practitioner,
R/O Flat No.202, Ganapathi
Apartment,Near Amrutha Theatre,
Hanamkonda Dist, Telangana State.

2. Mrs. Bommathi Gouthami W/O Dr.

MULKA CHANDRAMOULI, D/O
Bommathi sudarshan, aged about 36
years, R/O Flat No.202, Ganapathi
Apartment, Near Amrutha Theatre,
Hanamkonda Dist, Telangana State

Date: COUNSEL FOR PLAINTIFF’s

Place: Hanamkonda
IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA, HANAMKONDA DISTRICT

I.A.No. OF 2023
IN
O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Petitioner/Plaintiff
AND

Dr. Mulka Chandramouli and another

..Respondents/Defendants

AFFIDAVIT

I, Gadipe Prashanth S/o Ilaiah, do hereby solemnly and sincerely affirm

and sincerely state on oath as follows:

1. I am the Petitioner herein and Plaintiff in the suit and as such I am

well acquainted with the facts of the case.

2. It is submitted that Defendant no. 1, is the sole and absolute owner

in possession of Open plot situated at HANAMKONDA Revenue
Village, Sy.no.1089 with in Greater Warangal Municipal Corporation
Limits, Warangal Dist. and within the registration Dist. Warangal and
Sub-Dist. Warangal Urban, to an extent measuring of 116 Sq. yards
or 96.97 Sq.mts. Bearing Registered Sale Deed vide Doc. No.
18272/2018 dated 27.08.2018.

3. It is submitted that, earlier Defendant no.1 had a purchased above

said scheduled property from Thakkalla Kumaraswamy @ Raja
Kumara Swamy S/o Late Rajaiah through a registered sale deed
bearing a vide document no.18272/2018, SRO Warangal on dated
27.08.2018.
4. It is submitted That, Defendant no.1 had approached Plaintiff and
offered to sell the suit schedule property, it is further submitted that,
defendant No.1 had expressed to plaintiff that defendant No.1 is in
dire need of money to meet debts and expenses.

5. It is submitted that, it is also relevant to state that negotiations with

regard to sale consideration and other terms of sale were finalized
between the Plaintiff and defendant No.1, during the course of such
negotiations, both came to conclusion for the price of suit schedule
property for a total sale consideration of Rs.13,34,000 /- (Thirteen
Lakhs, Thirty Four Thousand Rupees Only)@ Rs 11,500 per yard.

6. It is submitted that, The Defendant No.1 made the Plaintiff to pay

Total amount of Rs 13,34,000 /- (Thirteen Lakhs,Thirty Four
Thousand Rupees Only) @ Rs 11,500 per yard, Cash as the
Defendant no.1 requested to meet his urgent needs, in respect of
said property. It is also submitted that, defendant No.1 also executed
a simple sale deed towards plaintiff on Rs. 100/- Non-judicial stamp
paper bearing No, Z 466034 on dated 09.09.2021 along with
acknowledge receipt of amount received.

7. It is submitted that the defendant No.1 had requested to plaintiff that

he will execute a registered sale deed within a week i.e. on
16.09.2021, it is further submitted that, after one week plaintiff called
on mobile phone defendant no.1 and requested to execute a
registered sale deed, later defendant No.1 replied that he will execute
within a couple of days over on phone.

8. It is submitted that, the defendant No.1 is well known ‘ACUPUNTURE’

Doctor and having familiar name in Hanamakonda Town. It is further
submits that, On 20.09.2021 Defendant No.1 came to plaintiff and
 requested that Defendant No.2 i.e. his wife is sick, suffering from
Covid and assured Plaintiff to execute the registered sale deed before
30.09.2021.

9. It is submitted that the Plaintiff have been requesting the Defendant

no.1 to execute a regular Registered Sale Deed in their favour, but
the Defendant no.1 has been postponing the matter on one or other
pretext, though the Plaintiff having patience obeying the words of the
Defendant no.1. It is further submits that on 10.11.2021, plaintiff
went to defendant No.1 residence to ask and request to execute a
registered sale deed, there plaintiff found door Lock and enquired
about both defendants neighbor’s, but no one had whereabouts.

10. It is submitted that the Defendant no.1 has dodged the matter by not
meeting the Plaintiff regularly since the month of 30.09.2021 by not
facing, the attitude of the Defendant no.1 is very much cheating
in nature and the way adopted by the Defendant no.1 is illegal and
untenable under law. It is submitted that plaintiff vexed with the dilly
dally attitude of the Defendant no.1, it is further submits that plaintiff
came to know on checking Encumbrance Certificate on Online and
shocked, that on 05.10.2021 Defendant No.1 executed a ‘Mortgage of
Deposit of Title Deed’ towards Defendant No.2 bearing Registered
document no. 25420 of 2021 AT HANAMKONDA SRO.

11. It is submitted that, after searching a lot, after approximately two

years, on 24.06.2023 plaintiff found defendant no.1 at his residence.
It is further submitted that plaintiff requested to defendant No.1 to
release the Mortgage of Deposit of Title Deed’ from defendant No.2
and execute a registered sale deed
12. It is submitted that both defendant No.1 and defendant No.2 is
creating some dill dolly stories, that defendant No.2 is saying that
 defendant No.1 is not her husband. it is further submits that, It is
reliably learnt that the both husband and wife i.e. Defendant No.1
and Defendant No.2, Were colluded and trying to negotiate with the
third parties to alienate the Suit Schedule Property in view of the
increased market value.
13. It is submitted that, the plaintiff had approached Local Police station
and given a complaint on defendants, as it is in Civil in nature, the
police authorities had advised plaintiff to approach Hon’ble court. It is
further submitted that, the plaintiff served a legal notice on
01.07.2023, through by hand and same was acknowledge
defendants, but no response from defendants side, which clearly
establishes that the Defendants is bent upon to usurp the hard-
earned money of the Plaintiff and cause wrongful losses to them.

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

“Ad interim Injunction” restraining the respondents/defendants from
alienating, transferring or otherwise creating any charge in favour of the third
parties during the pendency of the main suit, in the interest of justice.

last page corrs. Deponent

Solemnly and sincerely affirm this
the day of 2023
and signed his name in my presence.

BEFORE ME
ADVOCATE :: Hanamkonda
IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA, HANAMKONDA DISTRICT

I.A.No. OF 2023
IN
O.S.No. OF 2023

BETWEEN:

GADIPE PRASHANTH S/O ILAIAH,

Age about 42 Years, Occ: Advocate,
Flat No.101, Sun Residency,
Annapurna Colony, Mallapur,
Hyderabad, Telangana State,

..Plaintiff/Petitioner
AND .

1. Dr. MULKA CHANDRAMOULI, S/O GOPAIAH,

Aged About 47 Years, Occupation: Pvt. Practitioner as a Doctor,
R/O Flat No.202, Ganapathi Apartment,
Near Amrutha Theatre,
Hanamkonda Dist, Telangana State.

2. Mrs. Bommathi Gouthami W/O Dr. MULKA CHANDRAMOULI,

D/O Bommathi sudarshan, aged about 36 years,
R/O Flat No.202, Ganapathi Apartment,
Near Amrutha Theatre,
Hanamkonda Dist,
Telangana State.

..Respondents/Defendants

PETITION FILED UNDER ORDER 39, RULE-1&2,

R/W.SEC.151 OF C.P.C.

For the reasons stated in the accompanying affidavit, the petitioner/

plaintiff herein pray that this Hon’ble Court may be pleased to grant AD
INTERIM INJUNCTION restraining the respondents/defendants, their
associates, henchmen or any other person or persons working on their behalf
from alienating, transferring, encumbrance or otherwise creating any charge
in favour of the third parties in respect of petition schedule land during the
pendency of the main suit and pass such other order or orders as this Hon’ble
Court deems fit and proper in the interest of justice.

SCHEDULE OF PROPERTY

Open plot situated at HANAMKONDA Revenue Village, Sy.no.1089 with in

Greater Warangal Municipal Corporation Limits, Warangal Dist. and within the
registration Dist. Warangal and Sub-Dist. Warangal Urban, to an extent
measuring of 116 Sq. yards or 96.97 Sq.mts, Telangana State.

BOUNDARIES AS FOLLOWS:

NORTH : HOUSE OF B.VIDYASAGAR

SOUTH : 30 Feet Road Wide
EAST : HOUSE OF VENKATESHWAR RAO
WEST : 30 Feet Road Wide

Date:
Hanamkonda Counsel for Petitioner
 IN THE COURT OF THE
HONORABLE
……………………………… JUDGE,
AT HANAMKONDA,
HANAMKONDA DISTRICT

I.A.No. OF 2023
IN
O.S.No. OF 2023

BETWEEN:

Gadipe Prashanth
..Plaintiff/Petitioner

and

Dr. Chandramouli and another

..Defendant/s

PETITION FILED
UNDER ORDER-39,
RULE 1 & 2 R/W.SEC.151 CPC

FILED ON:

FILED BY:
M/s G. Ravi kumar, Advocate,
Reddy's Law Associates, H.No.9-
94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony,
Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile:
9395192719. Email:
pra.atdc@gmail.com

COUNSEL FOR PETITIONER

 FORM No.8
Particulars or Value of Immovable Property
(Rule-11 and 87 of Part - Volume -1 CRP and Co.)
IN THE COURT OF THE HONORABLE ……………………………… JUDGE,
AT HANAMKONDA , HANAMKONDA DISTRICT

O.S.No. OF 2023

BETWEEN:
Gadipe Prashanth
..Plaintiff
AND

Dr.Mulka Chandramouli and another

..Defendant/s
Valuation of Immovable Property under Section 10 of
Andhra Pradesh Court Fee and Suit Valuation Act

1. Sl.Items of Immovable Property Residential Plot

2. Registration District and Sub-District SRO Warangal, Warangal

3. Taluk, Village where property is Hanamkonda

situated

4. Survey No.Sub-Division Number S.No. 1089

5. Extent 116 Sq. yards or 96.97

Sq.mts,
6. Class of Lands Wet and Dry

7. Rent Value of the land

8. Market Value of the Residential Plot Rs 13,34,000/-(Thirteen

9. Value for purposes of
Court fee and jurisdiction
with the provision of law
Under which it is valued.
Lakhs,Thirty Four Thousand
Rupees Only) @ Rs 11,500 per
yard
Total Value ,Rs 13,34,000/- of suit
schedule property, S.No. 1089, 116
Sq. yards or 96.97 Sq.mts,
Hanamkonda, SRO Warangal,
Warangal SRO Warangal, Warangal,
and total Court Fee paid Rs.9912/-

10. Remarks

Date: 2023
Hanamkonda Plaintiff/Petitioner
 IN THE COURT OF THE
PRL. JUNIOR CIVIL JUDGE,YADADRI-
HANAMKONDA DISTRICT

O.S.No. OF 2023

BETWEEN:

Barre Nagesh and others

….PLAINTIFF
AND

Barre Pedda Swamy and others

DEFENDANT

VAKALAT
ACCEPTED

FILED ON: 22-01-2023

FILED BY:

M/s Prashanth Gadipe, Advocate,

Reddy's Law Associates, H.No.9-
94/1/15, Flat No.15, Bhavani
Nilayam, Ramchander Singh Colony,
Uppal Bus Depot, Maharaja Function
Hall, Hyderabad-500098. Mobile:
9395192719. Email:
pra.atdc@gmail.com
Advocate
ADVOCATE FOR PLAINTIFF
FORM OF CHALLAN NO.
Date : : 22-01-2023
FOIL
STATE BANK OF HYDERABAD, ______________ BRANCH, Warangal

Please receive a sum of Rs.____/- [Rupees

___________________________________ ONLY] towards cash in lieu of
court fee stamps and credit the same in saving Bank Account No.
________________ of the PRL. JUNIOR CIVIL JUDGE,YADADRI-
HANAMKONDA DISTRICT. Particulars of the amount are furnished below:
Amount deposited by:
Plaintiff By his/her Advocate Sri Prashanth Gadipe
Case Number: O.S.NO OF 2023

IN THE COURT OF THE PRL. JUNIOR CIVIL JUDGE,YADADRI-

HANAMKONDA DISTRICT

O.S.NO. OF 2023
Between:
Barre Nagesh and others
…. Plaintiff/Appellant
AND
.Barre Pedda Swamy and others
…..Defendant/Respondent
C.F. on GROUNDS OF APPEAL Rs
C.F. on MEMO OF Rs
APPEARANCE
C.F. on DECREE & Rs
JUDGEMENT
C.F. on APPEAL Suit Batta Rs

TOTAL = Rs.

SIGNATURE OF DEPOSITOR OR HIS ADVOCATE

FORM OF CHALLAN NO. Date : : 22-01-2023

FOIL
STATE BANK OF HYDERABAD, ______________ BRANCH, Warangal

Please receive a sum of Rs.____/- [Rupees

___________________________________ONLY] towards cash in lieu of
court fee stamps and credit the same in saving Bank Account No.
________________ of the PRL. JUNIOR CIVIL JUDGE,YADADRI-
HANAMKONDA DISTRICT. Particulars of the amount are furnished below:
Amount deposited by:
Plaintiff By his/her Advocate Sri Prashanth Gadipe
Case Number: O.S.NO OF 2023