Tadikonda,

24-06-2024
To

1) The Chief Secretary to Government,

Govt. of Andhra Pradesh, AP Secretariat,
Velagapudi, Amaravati.

2) The Principal Secretary to Government,

Revenue Department,
AP Secretariat, Velagapudi, Amaravati.

3) The Principal Secretary to Government,

Irrigation Department,
AP Secretariat, Velagapudi, Amaravati.

4) The Principal Secretary to Government,

MA & UD Department,
AP Secretariat, Velagapudi, Amaravati.

5) The Principal Secretary to Government,

Panchayat Raj Department,
AP Secretariat, Velagapudi, Amaravati.

6) The Commissioner,
AP CRDA, Lenin Center,
Governorpet, Vijayawada.

7) The District Collector,

Guntur District at Guntur.

8) The Superintendent of Police,

Guntur District at Guntur.

9) The Superintending Engineer,

Irrigation Circle, Guntur.

10) The District Panchayat Officer,

Guntur District.

From

1) Kalari Ranga Rao, S/o. Ramaiah,

Aged about 75 years,
R/o. 11-8, Swaraja Nagar,
Tadikonda Village & Mandal, Guntur District.

2) Kukatla Mallayya, S/o. late Lakshmaiah,

Aged about 65 years, r/o. Tadikonda,
Guntur District.

3) Kukatla Sambasiva Rao, S/o. late Lakshmaiah,

Aged about 75 years, r/o. Tadikonda,
Guntur District.

Sub: - Protection of Public Property put under charity by original owner

Uppaturu Gurunatham – being grabbed by third parties claiming
to be heirs of Gurunatham whereas he died without any children
- reg.

@@@

We, 1) Kalari Ranga Rao, S/o. Ramaiah, Aged about 75 years, R/o. 11-
8, Swaraja Nagar, Tadikonda Village & Mandal, Guntur District, 2) Kukatla
Mallayya, S/o. late Lakshmaiah, Aged about 65 years, r/o. Tadikonda, Guntur
District and 3) Kukatla Sambasiva Rao, S/o. late Lakshmaiah, Aged about 75
years, r/o. Tadikonda, Guntur District do hereby submit some few lines for
necessary and favorable action in protecting the Punnamma Tank which was
dug by Kantheti Punnamma and enlarged and developed by Gurunatham by
digging canals etc totalling to an extent of around Ac.9.00 cents both of
whom died without any children.

We submit that we are native and residents of Tadikonda Village &

Mandal, Guntur District. We are having agricultural lands around the said
Punnamma Tank and its canals irrigating the lands drawing water from the
said canals.

We submit that initially, one Kantheti Punnamma had dug a Tank which
was called as PUNNAMMA Tank in an extent of Ac.0.23 cents initially in Sy.
No.12/1, 12/2 of Tadikonda Revenue Village & Mandal, Guntur District.
Thereafter, Uppaturu Gurunadham purchased lands around it by way of
various sale deeds for the purpose of developing the said PUNNAMMA Tank
and digging canals for the said Tank and laying gates for supply of water and
some land as REST Area/Park. In total, there was PUNNAMMA Tank and its
connected park and canals in an extent of around Ac.9.00 cents in Sy. Nos.10,
11, 12 and 13 of Tadikonda Revenue Village & Mandal, Guntur District.

We submit that as per the recitals of the sale deed, the land is being
given to Gurunatham for the purpose of developing Tank and digging Canals
etc for charity. The same can be seen from the recitals in Doc No.449/1921
wherein it is stated that “since you intend to purchase the property for charity,
since the Punnamma Tank is small and needs development”, Ac.4.00 cents in
Sy. No.12/1 and 12/2 which is adjacent to the Punnamma Tank, except an
extent of Ac.0.23 cents of initial Tank is transferred to Gurunatham. As such,
the initial Tank Ac.0.23 cents was not transferred to even Gurunatham.

We submit that after purchase of the aforesaid extent of around Ac.9.00

cents in Sy. Nos. 10, 11, 12 and 13 of Tadikonda Village, by Uppaturu
Gurunatham, he developed the Tank from Ac.0.23 cents into around Ac.4.00
cents and Ac.0.445 cents in Sy. NO. 10/1C & 11/1 and Ac.0.095 cents in Sy.
No. 10/1 as Canals and around Ac.4.00 cents as PARK. The entire extent
purchased by Gurunatham and left over by Punnamma was put under charity
for public use.

We submit that as per Sec. 18 of Transfer of Property Act, when the

property is put under public use for the benefit of mankind or public, the
same cannot be transferred. Sec. 18 of Transfer of Property Act is extracted
hereunder:

Sec.18- Transfer in perpetuity for the benefit of public: - The

restrictions in Sec. 14, 16 and 17 shall not apply in the case of a
 transfer or property for the benefit of the public in the
advancement of religion, knowledge, commerce, health, safety or
any other object beneficial to mankind.

Under the said circumstances, when the aforesaid land was purchased
by Uppaturu Gurunatham for charity/public purpose beneficial to mankind,
such property cannot be transferred. Further, as per Sec. 6(c) & (d) of
Transfer or Property Act, the property is not transferrable. Furthermore, the
canals in Sy. No. 10, 11 and 12 are pegged in the Village Map/FMB of the
Tadikonda Revenue Village as well. Further, as per Adangals upto 2010, the

We submit that in the present case, Uppaturu Gurunatham died

intestate without any children as his heirs. But claiming as Gurunatham’s
brother’s son’s Daughter-in-law, one Uppaturu Ratnakumari and her son’s
Upputuri Ravi Kumar and Upputuri Anil Kumar, colluded with Eede
Muralikrishna, yarramsetty Ravi, Kancheti Venkata Mourya, Kurakula Srinivasa
Rao and created documents alienating the said Tank, canals and its annexed
vacant sites among themselves to some extent and encroached into some
extent. Thereafter, laid unauthorized plots and sold the land. In the canal
land Ac.0.445 cents in Sy No.10/1C, and Ac.0.095 cents in Sy. No.10/1, one
Addanki Srikrishna is constructing a Kalyana Mandapam without any
permission whatsoever under the guise of invalid sale deeds Doc
No.5045/2022, 5046/2022, 5047/2022, 5048/2022 having been purchased
from Kurakula Srinivasa Rao.

We submit that the said Uppaturi Ratnamala and her sons claim title of
the PUNNAMMA Tank and other lands in Sy. Nos. 10, 11, 12 and 13 of
Tadikonda Village from Uppaturi Narasimha Rajendra Kumar having executed
WILL vide Doc No.433/1995 whereas the recitals of the WILL don’t utter a
word about the said survey numbers.
 We submit that when an RTI Application was filed with the CRDA and
Panchayat Raj officials, the reply given was that there is no layout approved
by them in the area and there are no plots or constructions being made.
Whereas the said Addanki Srikrishna is raising a Kalyana Mandapam.

We submit that prior to the purchase of above land by Addanki

Srikrishna from Kurakula Srinivasa Rao, the said land was under challenge
against the aforesaid persons by way of Suit OS No. 195/2021 before the
Hon’ble Prinicpal Junior Civil Judge, Mangalagiri. By way of Injunction order,
the Hon’ble Court granted injunction for the said land against the said
Upputuri Ravi Kumar and Upputuri Anil Kumar, Eede Muralikrishna,
Yarramsetty Ravi, Kancheti Venkata Mourya, Kurakula Srinivasa Rao. As such,
the injunction order is binding upon the said Addanki Srikrishna as well as he
purchased the property while the suit is pending. The Suit OS No. 195/2021
is still pending before the Court. Recently, the said Addanki Srikrishna also
filed Implead petition which was dismissed by the Hon’ble Court.

We submit that the said Upputuri Ravi Kumar and Upputuri Anil Kumar,
Eede Muralikrishna, Yarramsetty Ravi, Kancheti Venkata Mourya, Kurakula
Srinivasa Rao and the purchaser Addanki Srikrishna are interfering with the
said canals annexed to the PUNNAMMA Tank to an extent of Ac.0.045 cents in
Sy.Nos.10/1C, 11/1 and Ac.0.095 cents in Sy.No.10/1 of Tadikonda Revenue
Village & Mandal, Guntur District.

We submit that the entire extent of Ac.9.00 cents in Sy. Nos. 10/1C,
10/1, 11/1, 12 and 13 of Tadikonda Revenue Village & Mandal, Guntur District
comprising of is barred from Alienation, Transfer etc and any alienations
become invalid in terms of Sec. 6(c), 6(d) and Sec. 18 of Transfer or Property
Act.
 We submit that under the guise of such invalid documents which are
not recognized under law i.e. Transfer of Property Act, since the documents
that are registerable, recognizable and valid are only that are permitted and
valid in terms of Transfer of Property Act only. Since, the Transfer of Property
Act doesn’t permit alienation of the said land put for public use in terms of
Sec. 18 and Sec. 6 of the Transfer or Property Act, the documents are to be
treated as invalid and non-est in the eye of law. Further, there is injunction
restraining the said persons for the canals of the said Punnamma Tank as
stated above.

We submit that due to the closure of the said Tank and Canals by the
aforesaid persons, our lands are getting affected and inundated and is causing
severe troubles to us in cultivating our lands. Previously also, we have made
several complaints to the authorities; but no action has been taken till date.

Under the circumstances, we request all of you to take action against

the said persons and protect the public property i.e. PUNNAMMA Tank and its
annexed lands and Canals which were put to public use under Charity by
UPPATURU GURUNATHAM & KANTHETI PUNNAMMA which is in an extent of
Ac.9.00 cents in Sy. Nos. 10, 11, 12 and 13 of Tadikonda Village and restore
them and take legal action against the land grabbers and to further put the
said lands under Sec. 22-A of the Registration Act.

Under the circumstances, we request No.6 of you to remove the

unauthorized layouts, constructions raised in Ac.9.00 cents in Sy. Nos. 10/1C,
10/1, 11/1, 12 and 13 of Tadikonda Revenue Village & Mandal, Guntur District
falling under the CRDA region without obtaining any approval and permission
contrary to CRDA Act in terms of Sec. 115 & 116 of AP CRDA Act.

Under the circumstances, we request No. 7 & 8 of you to protect the

land an extent of Ac.0.045 cents in Sy.Nos.10/1C, 11/1 and Ac.0.095 cents in
Sy.No.10/1 of Tadikonda Revenue Village & Mandal, Guntur District in terms of
the injunction granted by the Civil Court in OS No. 195/2021 by providing
POLICE AID and restraining the aforesaid persons including Addanki Srikrishna
from interfering with the property under the Suit and from changing the
physical features of the Suit Scheduled land.

Thanking you sir,

Yours Truly,

1) Kalari Ranga Rao

2) Kukatla Mallayya

3) Kukatla Sambasiva Rao

Enclosures:
1) Copy of sale deed Doc Nos. 449/1921, 1370/1921, 1371/1921 and its neat
copies of land purchased by Gurunatham for Tank and Canals

2) Copy of WILL Doc No.433/1995 in favour of Uppaturi Ratnamala and her

sons.

3) Copy of sale deed Doc No.2173/2019 purchased by Ede Murali Krishna

form Vupputuri Ratnamala and her sons for Ac.2.23 cents in Sy. No.12-1C, 12-
1D, 12-1E, 12-2B.

4) Copy of sale deed Doc No. 3389/2013 purchased by Kurakula Srinivasa Rao
from Vupputuri Ratnamala and her sons for Ac.0.445 cents, Doc No.3390/13
for Ac.0.095 cents.

5) Copy of sale deed Doc Nos.5045/2022, 5046/2022, 5047/2022, 5048/2022

purchased by Addanki Srikrishna from Kurakula Srinivasa Rao.

6) Copy of RTI replies issued by CRDA & Gram Panchayat stating that there
are no constructions in Sy. No. 10/1C of Tadikonda Village.
7) Photographs showing constructions in Sy. No. 10/1C, 10/1, 11/1 of
Tadikonda.

8) Copy of letter of Irrigation Department dt:10-10-2023 admitting presence

of Canals/drains and PUNNAMMA Tank, but state that it doesn’t fall under it.

9) Copy of Injunction order granted in OS No. 195/2021.

10) Copy of earlier representations/complaints.

1) Kalari Ranga Rao

2) Kukatla Mallayya

3) Kukatla Sambasiva Rao

Copy to:

The Hon’ble Deputy Chief Minister,

Govt. of AP, AP Secretariat, Velagapudi, Amaravati.