IN THE COURT OF THE JUNIOR CIVIL JUDGE: AT NALGONDA

O.S.No. 320 OF 2013

Witness number : D.W.No.1

Name : Jala Yadaiah
Father’s name : Chandraiah
Aged : 50 years
Occupation : Agriculture
Resident of : Dandempally village, Nalgonda mandal & Dist,

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, Jala Yadaiah, S/o Chandraiah, Age: 50 years, Occ: Agriculture, R/o

Nakrekal village, Nalgonda mandal & Dist,, do here by solemnly affirm and take
oath and state as follows:-
I am the deponent herein and defendant No.1 in the above suit, as such I
am well acquainted with the facts of the case.
I submit that I am the owner and possessor of the suit schedule land to an
extent of Ac.4-00 Gts, in Sy No.146, Ac.0-09 Gts in Sy No.147 in total Ac.4-09
Gts situated at Dandempally village of Nalgonda mandal and district, with the
following boundaries as,
North: Agril land of Bixamaiah,
South: Agril land of telgamalla Bixamaiah,
East: 12’ Donka,
West: Agril land of Jala Kondaiah,
And the same is acquired by me from the plaintiff for a valuable consideration
through Regd sale deed No.6414/2004, Dt.24-11-2004, on the file of SRO,
Nalgonda with the consent of the plaintiff in the presence of well educated
persons of our village and she voluntarily hand over the vacate possession with
the above said boundaries of the land in the presence of village elders and since
the date of purchase I am possessed and enjoying the same suit schedule land till
today without any interruption and I got mutated my name all revenue records
and I got Raithu bandhu scheme amount also.
 // 2 //

I submit that even though the plaintiff knowing the above all facts
by suppressing the same filed the present suit to harass me, and I have no
objection to appoint an Advocate commissioner to re-fix the boundaries of my
land as stated supra, the pleadings set up by the plaintiff and material filed before
the Hon’ble court the suit schedule property is not possessed by the plaintiff as
pleaded by her with the present title or boundaries over the suit lands.
The following documents may be marked as Exhibits;
1. Title deed cum Pattedar passbook, issued by Tahsildar, Nalgonda,
2.

In the above stated facts and circumstances that the Hon’ble court
may be pleased to dismiss the suit, in the interest of justice.
The above facts are true and correct.

Nalgonda, Deponent
Dt.24-02-2020

(Jala Yadaiah)
Solemnly sworn and signed before me on 24-02-2020 at Nalgonda

Advocate
IN THE COURT OF THE JUNIOR
CIVIL JUDGE: AT NALGONDA

O.S.NO. 320 OF 2013

Between:-
Ch.Sayamma
………Plaintiff

AND

Jala Yadaiah
……..…Defendant

CHIEF AFFIDAVIT OF DW-1

Filed on: 24-02-2020

Filed by: Defendant

Address for service

N.PRASANNA KUMAR,
Advocate, Nalgonda
IN THE COURT OF THE JUNIOR CIVIL JUDGE: AT NALGONDA
O.S.No. 326 OF 2011

Witness number : D.W.No.1

Name : M.Srinivasulu
Father’s name : Pentoji
Aged : 50 years
Occupation : President of Vikasa Handicapped Village Industries,
Resident of : Hayath Nagar, Hyderabad

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, M.Srinivasulu, S/o Pentoji, Age: 50 years, Occ: Presindent of Vikasa

Handicapped Village Industries, R/o Hayath Nagar, Hyderabad, temporarily
come down to Nalgonda, do here by solemnly affirm and take oath and state as
follows:-
I am the deponent herein and plaintiff No.1 in the above suit, as such I am
well acquainted with the facts of the case.

I submit that we are not aware that the relationship of the plaintiff with the
Buchaiah predeceased, and Vudhari Marthamma @ Maramma and about their
status whether they were landless poor or not, the plaintiffs are strangers to us.

I submit that there is no land in A-schedule an extent of Ac.1-00 Gts to

Vudhari Marthamma @ Maramma, it is false and denied that after demise of
mother of the plaintiff No.1, his name has been appearing in Pahanies as
possessor and no revenue records issued in favour of the plaintiff in respect of A-
schedule land, the plaintiff No.1 never possessed and enjoyed over the A-
Schedule property.

I submit that the plaintiff No.2 has never acquired the suit B-Schedule land
in the year 1977-78 by the Govt of A.P. vide orders in file No.P2/8490 of 1977
and never given any possession, no revenue record mutated in the name of
Plaintiff No.2 and never possessed B-schedule property.
 // 2nd page //
I submit that I am the president of Vikasa Handicapped Village Industries
association, Nalgonda with its Regd No.46 of 1993 situated at Saleem Nagar
locality of Malakpet, Hyderabad by having the land in Sy. No.827 and extent of
Ac.1-35 Gts situated at Thipparthy revenue village of Nalgonda district

I submit that the suit schedule properties which shown as A & B is false
and they are one piece of land which allotted to the Vikasa Handicapped Vilaage
Industries Association, the said land was allotted by the Government to our
Association vide Letter No.E2/10232/94, Dt.30-06-1994 on payment of market
value of Rs.13,125/- for development of said association, the Government also
conducted the Panchanama on 01-12-1995 with map and delivered the
possession and mutated the name of Association in all revenue records, since the
date of delivery the said Association has been continuation possession over the
suit schedule property as a owner.

I submit that myself is the president of the said Vikasa Handicapped

Village Industries Association and the defendants No.2 & 3 are members of the
said Association.

I submit that on 02-09-2011 the Commissioner, Rural Development,

Hyderabad requested the Project Director and Addl Dist Programme Co-
ordinator, DWAMA, Nalgonda took up the bund plantation and land
development works in the above lands and the same was permitted under
guidelines issued by MGNREGS.

I submit that plaintiffs are strangers to our Association who are the villagers
even though they have no interest, Title or possession on 23-11-2011 when our
Association members cleaning the land the plaintiffs along with Goondas started
illegal interference with the peaceful possession of Vikasa handicapped Village
Industries Association and the same was resisted our Association members and
to protect the rights of our Association our Association was filed suit for
injunction with OS No.315/2011, and the Hon’ble court was granted Ad-Interim
Injunction vide I.A.No.1049 of 2011 against plaintiff No.2 herein and others.
 // 3rd page //
I submit that even though knowing the above suit pending by suppressing
the same filed the present suit to harass our Association, I submit that the suit
schedule property possessed and enjoying by Vikasa Handicapped Village
Industries Association, the pleadings set up by the plaintiff and material filed
before the Hon’ble court the suit schedule property never possessed by the
plaintiff by having title, the Vikasa handicapped Village Industries association is
possessed the suit schedule property by having title.
The following documents may be marked as Exhibits;
1. Ex.B-1 CC of Certificate of Incorporation No.46/1993, Dt.25-06-1993
2. Ex.B-2 CC of proceedings No.F2/10232/94, Dt.30-06-1994 issued by the
District Collector, Nalgonda
3. Ex.B-3 CC of Letter No.B/2409/93 issued by MRO, Thipparthy, Dt.16-
07-1994
4. Ex.B-4 CC of Resolution of Gram Panchayath, Thipparthy, Dt.17-02-
1994
5. Ex,B-5 CC of challan No.2417, Dt.22-09-1995
6. Ex.B-6 CC of Letter from MRO, Thipparthy for mutation of suit schedule
land, Dt.05-02-1996
7. Ex.B-7 CC of Memo No.824/eGS/PM/T2010, Dt.02-09-2011 issued by
the Commissioner Rural Development, Hyderabad
8. Ex.B-8 CC of Report of Mandal Surveyor, Thipparthy mandal, Dt.25-08-
2011
9. Ex.B-9 to B-20 are CCs of Pahanies for the years 1996-1997 and 1998-
1999 to 2009-2010
10. Ex.B-21 CC of authorization letter, Dt.30-10-2011
11. Ex.B-22 CC of Panchanama, Dt.01-12-1995
12. Ex.B-23 CC of plaint vide OS No.315of 2011, Dt.28-11-2011
13. Ex.B-24 CC of order in I.A. No.1049 of 2011 in OS No.315 of 2011,
Dt.28-11-2011

In the above stated facts and circumstances that the Hon’ble court
may be pleased to dismiss the suit, in the interest of justice.
The above facts are true and correct.
Nalgonda, Deponent
Dt.08-11-2018

(M.Srinivasulu)
Solemnly sworn and signed before me on 08-11-2018 at Nalgonda

Advocate
IN THE COURT OF THE JUNIOR
CIVIL JUDGE: AT NALGONDA

O.S.NO. 326 OF 2011

Between:-
V.Daniel and others
………Plaintiffs

AND

M.Srinivasulu
……..…Defendant

CHIEF AFFIDAVIT OF DW-1

Filed on: 08-11-2018

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda
IN THE COURT OF THE JUNIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 544 OF 2006

Witness number : D.W.No.1
Name : G.Ramulu @ Ramanaiah
Father’s name : Veera Mallaiah
Aged : 45 years
Occupation : Govt. Employee
Resident of : Hyd Road, Nalgonda town and district.
CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C
I, G.Ramulu @ Ramanaiah, S/o Veera Mallaiah R/o Nalgonda town and
district, do here by solemnly affirm and take oath and state as follows:-

I am the owner and exclusive possessor of the house plot with in survey
No.836 in ward No.6 inside residential zone compressing total area as per the
plan 84.45 Sq.yards as bounded.
North: My house and house of Komati Susheela
South: Vendors land (Somavarapu Badraiah)
East: My house, and house of N.Sathyanarayana, Suvarna
and 1.6 feets lane
West: Vendors Plot (Somavarapu Badraiah)

I purchased the above house plot from its original owner by name
Somavarapu Badraiah on 01-12-2004 with a registered sale deed No.6540/2004,
(Ex.B-4) who is also vendor of Pw-1.

As per the registered sale deed there is a passage with 4.6 feet width
which running from east to west, and 45.6 feet in length running from south to
north for the purpose of way to enter in to my above house plot which I
purchased from the Somavarapu Badraiah and there is 1.6 feet drainage lane
attached to the east side of the above way.

The pw-1 failed to verify the actual possession of the land on this spot and
without verifying the prior registration, the Pw-1 purchased the house plot on my
southern side under Ex.A-1 by showing 6 feet lane on the eastern side and
claiming way by filing this suit by showing that there is 6 feet lane and that to
common passage, but there is only 4.6 feet lane is available on the eastern side
that to I purchased on 01-12-2004 for the purpose of use as way to enter in to my
house.
 Contd……..2,

// 2 //

After purchasing the house plot I obtained permission from Nalgonda

Municipality on 09-09-2005 ( Ex.B-5 ), and on 15-12-2005 I erected a gate on
the southern side on the way of 4.6 feet, and the same was showing under Ex.B-1
to B-3.

I never executed any document under Ex.A-2, there is no 6feet common

passage on the eastern side of the plaint schedule land, and there is only 4.6 feets
lane is available which exclusively belongs to me, and after that there is 1.6 feet
lane is available for flowing of drainage water.

The Pw-1 without verifying actual possession and prior documents is

illegally claiming 6 feets lane on the eastern side of the suit schedule land.

There is no such 6 feets lane is available and only 4.6 feet lane is available
on which I erected my gate and same was using to enter into my house.

I filed sketch map which shows clearly actual possession of the suit plot,
the Pw-1 is no right over the said 4.6 feet lane as such I pray the Hon'ble Court
may be pleased to dismiss the suit.

I filed the following documents and the same may be marked as

exhibits.
Ex.B-4 Regd. Sale deed with document No.6540/2004 Dt.01-12-2004
Ex.B-5 Permission from Nalgonda Municipality Dt.09-09-2005

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.17-07-2008.

( G.Ramulu @ Ramanaiah)

Verification: Solemnly sworn and signed before me at Nalgonda on this the 17th
day of July, 2008.

Advocate
IN THE COURT OF THE JUNIOR CIVIL
JUDGE :: AT NALGONDA.

O.S.NO. 544 OF 2006

Between:-
R.Lohithasyudu
………Plaintiff.

AND

G.Ramulu
……..…Defendant

CHIEF AFFIDAVIT OF DW-1

Filed on: -07-2008

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.
IN THE COURT OF THE SENIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 167 OF 2006

Witness number : D.W.No.1
Name : Sama Sathi Reddy
Father’s name : Pedda Veera Reddy
Aged : 58 years
Occupation : Agriculture
Resident of : Chandur village and mandal, Nalgonda district.

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, Sama Sathi Reddy S/o Pedda Veera Reddy R/o Chandur village and
mandal, Nalgonda district, do here by solemnly affirm and take oath and state as
follows:-

I am agriculturalist by occupation, I know the Pw-1, defendant No.2 is my

wife.

I had no past money transaction with the Pw-1, my self and my wife never
approached to the pw-1 on 10-12-2003 for a loan of Rs.3,00,000/- for my family
and business necessity, I never borrowed an amount of Rs.3,00,000/- from Pw-1
at his house at Chandur by executing Ex.A-1 infavour of Pw-1 by my self and
my wife jointly by agreeing repay the same with interest @ 24% p.a.

I never obtained a loan of Rs.5,00,000/- on 15-01-2004 for purchase of

new bore well rig from Pw-1.

Pw-1 never demanded neither to me nor my wife about the suit amount
and we never says that we will dispose our property, and we will paid the suit
amount, neither my self nor my wife having movable or immovable properties.

Pw-1 never demanded to me or my wife on 01-11-2006 about the suit

amount, neither my self nor my wife never executed the Ex.A-1 and the
signatures appearing on Ex.A-1 is not belongs to neither my self nor my wife the
same was forged by the Pw-1.
Contd……..2,

// 2 //
I along with my wife never borrowed any amount from the Pw-1, the
Ex.A-1 was forged and fabricated document which created by Pw-1 with the help
of Pw-2, as such I pray the Hon'ble Court to dismiss the suit.

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.15-02-2008.

( S.SATHI REDDY )

Verification: Solemnly sworn and signed before me at Nalgonda on this the 15th
day of February, 2008.

Advocate
IN THE COURT OF THE SENIOR CIVIL
JUDGE :: AT NALGONDA.

O.S.NO. 167 OF 2006

Between:-
Gattu Krishnaiah
………Plaintiff.

AND

Sama Sathi Reddy and another

……..…Defendants.

CHIEF AFFIDAVIT OF DW-1

Filed on: -02-2008

Filed by: Defendant No.1

 Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.

IN THE COURT OF THE SENIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 16 OF 2007
Witness number : D.W.No.1
Name : Sama Sathi Reddy
Father’s name : Pedda Veera Reddy
Aged : 58 years
Occupation : Agriculture
Resident of : Chandur village and mandal, Nalgonda district.
CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C
I, Sama Sathi Reddy S/o Pedda Veera Reddy R/o Chandur village and
mandal, Nalgonda district, do here by solemnly affirm and take oath and state as
follows:-

I am agriculturalist by occupation, I know the Pw-1 but I had no past

transaction money with the Pw-1.

I never approached to the pw-1 for a loan of Rs.5,00,000/- on 15-01-2004

for purchase bore well rig, and I never executed any promissory note under
Ex.A-1 at Pw-1 residence by agreeing repay the same with interest @ 24% p.a.

My self and my wife never jointly obtained a loan of Rs.3,00,000/- on 10-

11-2003 from Pw-1 and a false suit with O.S.No.167/2006 is pending before the
Hon’ble Senior Civil Judge, Nalgonda against me and my wife.
 The Pw-1 never demanded to me about the suit amount on 30-12-2006,
the signature on Ex.A-1 not belongs time and the same was forged by the Pw-1
with the help of Pw-2.

I am not borrowed any amount fromPw-1, as such I pray the Hon'ble

Court to dismiss the suit

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.15-02-2008.

( S.SATHI REDDY )
Verification: Solemnly sworn and signed before me at Nalgonda on this the 15th
day of February, 2008.

Advocate

IN THE COURT OF THE SENIOR CIVIL

JUDGE :: AT NALGONDA.

O.S.NO. 16 OF 2007

Between:-
Gattu Krishnaiah
………Plaintiff.

AND

Sama Sathi Reddy

……..…Defendant.

CHIEF AFFIDAVIT OF DW-1

 Filed on: -02-2008

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.

IN THE COURT OF THE JUNIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 244 OF 2004

Witness number : D.W.No.1

Name : Vanaparthi Nagaiah
Father’s name : Anjaneyulu
Aged : 26 years
Occupation : Business
Resident : Nalgonda town.

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, Vanaparthi Nagaiah S/o Anjaneyulu, R/o Nalgonda town and district,

do here by solemnly affirm and take oath and state as follows:-

I am the defendant herein and there is no such close relationship Pw-1 and
Pw-2. I never received Rs.46,000/- from Pw-1 in the presence of Pw-2, I never
deposited the Ex.A-2 to A-4 with Pw-1, and the said property belongs to Neela
Sankaraiah who is the second husband of my natural mother.
 I received notice under Ex.A-5, and I asked the copy of Ex.A-1 pronote
and the same was supplied by the Pw-1 on 15-06-2004, but when I am going to
reply the notice but the Pw-1 filed the suit without giving time to submit my
reply.

The description particulars on Ex.A-1 not belongs to me, my full

particulars is Vanaparthi Nagaiah S/o Anjaneyulu, the surname of “Neela”
belongs to my mother second husband.

The Pw-1 before issuing Ex.A-5 i.e, Legal notice, issued a another legal
notice through Sri J.Raghava Advocate Nalgonda on 08-03-2004 under Ex.B-1
by alleging that I received an amount of Rs.46,000/- on 09-07-2002, and agreed
to repay the same with interest @ 24% per annum, on receiving the same I
replied through my advocate Sri G.Venkateshwarlu by requesting supply the
copy of promissory note i.e, Ex.A-1 on 27-03-2004, but the pw-1 kept quite up to
24-05-2004.

The Pw-1 again issued the legal notice under Ex.A-5, through Sri
N.Raghupathi Advocate by new version by alleging that I received Rs.46,000/-
from Pw-1 on 09-07-2002 and agreed repay the same with interest @24% p.a.
Contd…….2,

// 2 //
and also alleged that there is on endorsement back side of the Ex.A-1, by
showing that the borrowed amount may be paid by way of installments per
month Rs.2,000/-, and I again asked the Pw-1 to supply the alleged promissory
note i.e, Ex.A-1 on 09-06-2004 under Ex.A-8, and the same was supplied by
Pw-1 on 15-06-2004.

I submit that the Ex.A-5 is quite different and inconsistent with the
second notice under Ex.B-1, the Pw-1 not given time to me to give better reply to
the notices of Pw-1 under Ex.A-5, and B-1 and filed the suit with all false
allegations.

There is no contract under Ex.A-1 to pay the interest @ 24% p.a., and the
Pw-1 is the professional money lender and doing money lending business
without valued money lending license.
 I submit that I am living with one Neela Shankaraiah who is the second
husband of my natural mother, as such the Pw-1 think that said shankaraiah is
my father and got fabricated the Ex.A-1 by filling the coloums by showing
surname and father name as “Neela Shankaraiah”, but I am the adopted son of
Vanaparthi Anjaneyulu.

I never received any amount under Ex.A-1 in the presence of Pw-2 and
no document was executed in favour of Pw-1, and Pw-1 fabricated suit
documents and filed false case. I pray the Hon’ble court to dismiss the suit.

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.07-12-2006.

( V.NAGAIAH )

Solemnly sworn and signed before me at Nalgonda on this the 7th day of
December, 2006.

Advocate

IN THE COURT OF THE JUNIOR CIVIL

JDGE :: AT NALGONDA.

O.S.NO. 244 OF 2004

Between:-
S.Ramesh
………Plaintiff.

AND

N.Nagaiah
……..…Defendant.
 CHIEF AFFIDAVIT

Filed on: 07-12-2006

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.

IN THE COURT OF THE JUNIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 500 OF 2005

Witness number : D.W.No.1

Name : Punna Raju
Father’s name : Somaiah
Aged : 42 years
Occupation : Retail oil business
Resident : Nalgonda town.

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

 I, Punna Raju S/o Somaiah, Age:42 years, Occ:Retail oil business, R/o
Nalgonda town and district, do here by solemnly affirm and take oath and state as
follows:-

I am the first defendant herein and I know the all the defendants. I never
joined in the chit series STNG2 with ticket No.19 for value of the chit
Rs.1,00,000/- and 25 months duration and Rs.4,000/- per month on 26-02-2004.
I never executed Ex.A-3 infavour of Pw-1.

I never submitted any bid form on 18-07-2004 under Ex.A-5, I never

executed an agreement of guarantee under Ex.A-6 through the other defendants.
I never received any legal notice from the Pw-1.

I submit that the Pw-1 filed the above suit with all false and fabricated
documents to harass me along with other defendants, I pray the Hon’ble court to
dismiss the suit.

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.20-12-2006.

( PUNNA RAJU )

Solemnly sworn and signed before me at Nalgonda on this the 20th day of
December, 2006.

Advocate

IN THE COURT OF THE JUNIOR CIVIL

JDGE :: AT NALGONDA.

O.S.NO. 500 OF 2005

Between:-
Sathyadurga Chit Fund (P) Ltd.,
Nalgonda.
 ………Plaintiff.

AND

P.Raju and others

……..…Defendants.

CHIEF AFFIDAVIT

Filed on: 20-12-2006

Filed by: Defendant No.1

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.

IN THE COURT OF THE JUNIOR CIVIL JUDGE :: AT NALGONDA

O.S.No. 228 OF 2006

Witness number : D.W.No.1
Name : T.Narsimha Goud
Father’s name : Janaiah Goud
Aged : 31 years
Occupation : Agriculture and Business
Resident : Thipparthy village and mandal, Nalgonda district.

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, T.Narsimha Goud S/o Janaiah Goud R/o Thipparthy village and

mandal, Nalgonda district, do here by solemnly affirm and take oath and state as

follows:-

I never approached the Pw-1 company on 02-09-2003 for a loan amount

of Rs.47,636/- for purchase computer, I never submitted any quotation offered by

I.B.M Computer Service, Nalgonda, I never executed demand promissory note

on 02-09-2003.

I never received computer from Pw-1 company under loan agreement, I

never received ay legal notice from Pw-1 company the suit documents are

fabricated and I never executed any documents infavour of the Pw-1 company.

I am not borrowed any amount from Pw-1 company, as such I pray the

Hon'ble Court to dismiss the suit.

The above facts are true and correct.

Nalgonda, DEPONENT
Dt.23-02-2007.

( T.Narsimha Goud )
Verification:- Solemnly sworn and signed before me at Nalgonda on this the 21st
day of July, 2008.

Advocate

IN THE COURT OF THE JUNIOR CIVIL

JDGE :: AT NALGONDA.

O.S.NO. 228 OF 2006

 Between:-
M/s Shriram City Union Finance Ltd.,
Hyderabad, Rep. by its Authorized
Signatory
………Plaintiff

AND

T.Narsimha Goud
……..…Defendant

CHIEF AFFIDAVIT OF Dw-1

Filed on: 21-07-2008

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.

IN THE COURT OF THE I ADDL. DISTRICT JUDGE :: AT NALGONDA

 O.S.No. 11 OF 2004
Witness number : D.W.No.1
Name : D.Govardhan
Father’s name : Ramulu
Aged : 45 years
Occupation : Business
Resident : Kondamallepally village of Devarakonda mandal,
Nalgonda district.

CHIEF AFFIDAVIT FILED UNDER ORDER XVIII RULE 14 OF C.P.C

I, D.Govardhan S/o Ramulu, Age:45 years, Occ:Business, R/o

Kondamallepally village of Devarakonda mandal, Nalgonda district, do here by
solemnly affirm and take oath and state as follows:-

I am the defendant herein and I know the Pw-1 but there is no

acquaintance with Pw-2, I am one of the partner of Sri Dhanalaxmi Theature at
Konda Mallepally village of Devarakonda mandal, Nalgonda district and not
proprietor to the said theater.

I never approached the Pw-1 on 01-08-2002 at about 8.00 a.m by

requesting to Pw-1 for arrangement an amount of Rs.4,00,000/- and I never
received the Rs.4,00,000/- from Pw-1 by executing promissory note by agreeing
repay the same with interest @ 24% p.a. on 01-08-2002 under Ex.A-1.

I never again on same day approached the Pw-1 at about 3.00 p.m by
requesting an amount of Rs.3,00,000/- and never received Rs.3,00,000/- from
Pw-1 by executing promissory note by agreeing repay the same with interest @
24% p.a. on 01-08-2002 under Ex.A-2.

I never approached to the Pw-1 on 23-11-2002 and never received an

amount of Rs.2,00,000/- from Pw-1 by executing promissory note by agreeing
repay the same with interest @24% p.a. on 23-11-2002 under Ex.A-3.

I never received an amount of Rs.9,00,000/- from Pw-1 in the presence of

Pw-2, under Ex.A-1 to A-3.
The Pw-1 never demanded to me about the suit amount and I am not
doing any real estate business now, and I am not aware about the issuing of legal
Contd……..2,
 // 2 //
notice on 05-08-2004 under Ex.A-4, and I never managed the post man to return
the said notice, I am suffering with jaundies, As such from the month of July,
2004 to October, 2004 I admitted at Hyderabad for my treatment, as such the
Ex.A-4 was returned by endorsing the same.

The Pw-1 one of the partner of Padma Sri Chit Funds, Devarakonda and I
executed the suit blank promissory notes in favour of the chit fund and taking
advantage of the same the pw-1 fabricating the suit documents and filed this suit.

There is dispute between me and Pw-1 with regard to the chit amount and
that effect on 03-07-2003, the Pw-1 and my self came to one settlement in the
mediation of Maram Krishna Murthy and Pola Shankaraiah and as per that
settlement under Ex.B-1. I was due Rs.9,00,000/- to the Pw-1 but the Pw-1 used
blank promissory notes by fabricating the same filed the present suit with all
false allegations.

I submit that I never received any amount under Ex.A-1 to A-3 and I
never executed the same in the presence of Pw-2, as such I pray the Hon’ble
court to dismiss the suit with costs, in the interest of justice.

The above facts are true and correct.

Kondamallepally, DEPONENT
Dt.18-03-2007.

( D.Govardhan )

Solemnly sworn and signed before me at Kondamallepally village of

Devarakonda mandal, Nalgonda district on this the 18th day of March, 2007.

Advocate
IN THE COURT OF THE I ADDITIONAL
DISTRICT JDGE :: AT NALGONDA.

O.S.NO. 11 OF 2004

Between:-
J.Pandarinath
………Plaintiff.

AND

D.Govardhan
……..…Defendant.

CHIEF AFFIDAVIT

Filed on: -03-2007

Filed by: Defendant

Address for service

Kampati Venkateshwarlu,
Advocate, Nalgonda.