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IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE:

AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between :
Thirumala Raju son of Swamy, Age: 73 years, Occ: Contractor,
Resident of House No.5-11-134, Shanthi Nagar,
Nalgonda Town & District.
…Decree Holder / Plaintiff
AND

Gongati Srinivas son of Late Ramulu, Age: 42 years,

Occ: Agriculture, Resident of House No.5-11-163,
Shanthi Nagar, Nalgonda Town & District.
…Judgment Debtor/Defendant.

EXECUTION PETITION U/O.XXI, RULE 11 (2) R/W SECTION 151 OF

C.P.C

The above named Decree Holder submits as follows :

1. Name of the Suit : O.S No : 59 of 2014

2. Description of the Decree Holder : Thirumala Raju S/o Swamy

Age: 73 years, Occ: Contractor
R/o. H. No.5-11-134, Shanthi Nagar
Nalgonda Town & Dist.
… Plaintiff
3. Description of the Judgement Debtor : Gongati Srinivas S/o Late Ramulu
Age: 42 years, Occ: Agriculture,
R/o H.No.5-11-163, Shanthinagar,
Nalgonda Town & Dist.
… J.Dr / Defendant
4. Date of Decree : 08-10-2014

5. Whether any appeal had

Preferred from the decree. : No.

6. Whether any application previously

Is filed : No.

7. Payment or Adjustment if any : No.

8. Whether decree transferred or Not ? : No.

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9. Amount with interest due upon the : Rs.4594/-

Decree or the other relief granted
Thereby together with particulars of
Any cross decree.

10. Costs of the Suit. : 4594 – 00

C.F on E.P : 1 – 00
Process : 60 – 00
Advocate Fee : 3,000 – 00
Typing & Misc., : 100 – 00
Total : 7,755 – 00

11. Against whom the execution of : Against the J.Dr.

Decree is sought.

12. The mode in which the assistance : For arrest and detention of the
Of the Court is required J.Dr. in Civil Prison U/o.XXI
R – 37(1) of C.P.C
BRIEF FACTS:

1. It is submitted that the D.Hr had filed the above suit against J.Dr when he has
interfered with his peaceful possession and enjoyment over the suit schedule
property which is clearly exhibited in OS No.59/2014. The J.Dr received the
summons but he did not prefer to appear and contest the matter and as such the
Hon’ble Court was pleased to pass a Decree in favour of the D.Hr on 08.10.2014,
restraining the J.Dr and his henchmen from interfering with peaceful possession
and enjoyment of the D.Hr over the suit schedule property.

2. That the D.Hr is the absolute owner and possessor of the House Plot
admeasuring Sq.Yrds 332 out of survey number 96/A, located in ward No. 5,
Block No: 11, Shanthi Nagar Nalgonda, which is the suit schedule property in
O.SNo.59 of 2014, and the same is bounded as under…

North : Plot of J.Dr

South : Plot of Vanaja, Shyam and part of House of Shekar

East : House of Chinnapu Reddy

West : House of Linga Reddy

3. It is submitted that apart from the above house plot which is the subject matter
of the above E.P the D.Hr is also having another house plot in Sy.No. 82 which is
adjacent to the Northern boundary of the above Plot. This house plot was
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purchased by him from Little Flower Vignana Mandhir. The D.Hr had raised
compound wall all around these plots and also erected metal gate which is clear
from the photographs and further he had also built a House and obtained House
No.5-11-14/2 from Nalgonda Municipality and paid house tax. He had further got
electricity connection bearing SC No: 4010473939 and he and his family members
are dwelling in the said house. The J.Dr had demolished part of the compound wall
as well as the gate and gate’s pillars on 21-08-2021. As such D.Hr had lodged a
complaint with P.S Nalgonda I-Town and the S.H.O has given him the
acknowledge receipt.

4. It is submitted that the J.Dr. filed suit in respect of one fabricated house plot on
concocted grounds with imaginary boundaries in OS No.5/2014 and obtained ex-
parte decree on 18.02.2015 against the D.Hr and he had filed the present EP
No.80/2019 which is at the Trial stage in the Hon’ble Court. By filing the above
EP the J.Dr is trying to occupy the schedule house plot of Decree Holder.

Hence it is prayed that the Hon’ble Court may be pleased to pass an order for
the Arrest and detention of the Judgment Debtor / Defendant in Civil Prison, in the
interest of Justice.

Decree Holder

Nalgonda,

Dt : 12 -10-2022

Thirumala Raju

Verification : I the above named Decree Holder do hereby declare that what is
stated in the above E.P., is true and correct to the best of my knowledge and belief.
Hence, verified at Nalgonda on this the 12th day of October, 2022.

Decree Holder

Thirumala Raju

Counsel for the Decree Holder.

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IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE :

AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between :

Thirumala Raju …Decree Holder / Plaintiff

AND

Gongati Srinivas …Judgment Debtor/Defendant.

SCHEDULE OF PROPERTY

Open house plot admeasuring 332 Sq.yds (277.58 Sq.mts) out of Survey. No. 96/

in Ward No.5, Block No.11 situated at Shanthinagar, Nalgonda Town t and

bounded as follows;

Boundaries :

North : Plot of Plaintiff out of Survey N0:82

South : Plot of Vanaja, Shyam & part of House of Shekar

East : House of Chinnappu Reddy, now sold to others

West : House of Linga Reddy

Decree Holder

Nalgonda
Dt : 12 -10-2022 Thirumala Raju

Advocate for the Decree Holder

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IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE :

AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between :

Thirumala Raju …Decree Holder / Plaintiff

AND
Gongati Srinivas …Judgment Debtor/Defendant.

FEE AND COSTS MEMO

Costs of the Suit. : 4594 – 00

C.F on E.P : 1 – 00
Process : 60 – 00
Advocate Fee : 3,000 – 00
Typing & Misc., : 100 – 00

Total : 7755 – 00

Advocate for the Decree Holder.

FEE CERTIFICATE

I, Sri. Sri. P. Ananda Reddy Advocate for the Decree Holder do hereby
declare that I have received a sum of Rs.3,000/- towards my Legal fee from the
decree holder in the above E.P

Hence fee Certificate.

Nalgonda,

Date : 12-10-2022

Advocate for the Decree Holder.

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FORM NO.61
(171 Payment into the Court of Cash / Process Fee Deposit)
IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE :

AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between :

Thirumala Raju …Decree Holder / Plaintiff

AND
Gongati Srinivas …Judgment
Debtor/Defendant.
Nature of Process to be issued

Travelling allowance to
for which money is deposited

Distance in miles from the

Subsistence
Village, Mandal, District,

Allowance

Expenses of sale or
Class of

Process fees
Name and Description of Person

Amount
On whom or on whose property
Munsiff where

The process is to be executed

or purpose

and order

and fro

1. Gongati Srinivas, S/o Late

Ramulu, Age: 42 Years, Occ:
Age, R/o House No.5-11-163,
Shanthi Nagar, Nalgonda
Town & District..

It is requested that the sum of Rs……………. may be received for the purpose
above mentioned.

Dated this 12th day of October, 2022.

Advocate for DHr.
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IN THE COURT OF THE

HON’BLE SENIOR CIVIL JUDGE
AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014

Between:

Thirumala Raju

…Decree Holder

AND

Gongati Srinivas
…Judgment Debtor.

EXECUTION PETITION U/O.XXI,

RULE 11 (2) R/W SECTION 151 OF
CIVIL PROCEDURE CODE

Filed on: 12-10-2022

Filed by: Advocate for Decree Holder

ADDRESS FOR SERVICE

SRI. P. ANANDA REDDY,

B. MADHUKAR RAO,
DOGIPARTHI SRIKANTH
ADVOCATES-
NALGONDA
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IN THE COURT OF THE

HON’BLE SENIOR CIVIL JUDGE
AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between:

Thirumala Raju

…Decree Holder

AND

Gongati Srinivas
…Judgment Debtor.

FORM NO.61
Process Fee Deposit

Filed on: 12-10-2022

Filed by : Advocate for Decree Holder

ADDRESS FOR SERVICE

SRI. P. ANANDA REDDY,

B. MADHUKAR RAO,
DOGIPARTHI SRIKANTH
ADVOCATES
NALGONDA
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Form No.12
Notice to show cause why warrant of Arrest should not issue
(O. XXI, Rule 37)
IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE :

AT: NALGONDA

E.P No : of 2022
IN
O.S No : 59 of 2014
Between :

Thirumala Raju …Decree Holder / Plaintiff

AND
Gongati Srinivas …Judgment Debtor/Defendant

To

Gongati Srinivas S/o Late Ramulu, Age: 42 years,Occ: Agriculture, Resident of

House No.5-11-163, Shanthi Nagar, Nalgonda Town & District.

Whereas the D.Hr. has made application to this Court for Execution of
Decree in O.S.No.59 of 2014, by arrest and imprisonment of your person. You are
hereby required to appear before this Court on the day of …..…………
2022, to Show Cause, why you should not be committed to the Civil Prison in
Execution of the said Decree.

Given under my hand and the seal of the Court, this ……….. day of
………….. 2022.

JUDGE
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Gongati Srinivas S/o Late Ramulu,

House No.5-11-163,
Shanthi Nagar,
Nalgonda Town – 508001

Gongati Srinivas S/o Late Ramulu,

House No.5-11-163,
Shanthi Nagar,
Nalgonda Town - 508001