IN THE COURT OF THE HON’BLE Xi ADDL.

CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.No. 503 of 2023

In

O.S. NO: 387 OF 2017

BETWEEN:

SRI A. RAGHU NANDAN ...Petitioner/Plaintiff

AND

SRI Dasari Ram Babu ..Respondent/Defendants

AFFIDAVIT

I, SRI A. RAGHU NANDAN, S/o. Sri Satyanarayana, aged 55 years,

Occ: Academician and Consultant, R/o. 7-1-277/27, MIGH -205/B,

B.K.Guda, Opp: Municipal Ward Office, S.R.Nagar, Hyderabad -38 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 the Petitioner herein has filed above suit for

Specific Performance Suit. The Petitioner herein came to know about

the nature of the Respondents 1 and 2 that they are habituated to

taking loans by entering into agreements and avoid payment by one

pretext or the other. The Petitioner further came to know that the
property which they are putting as a bait to get loans for them is an

encroached property and the documents are fabricated. Further the

building constructed on the said land is an unauthorized one and it is

constructed without leaving set-backs, parking space and also

encroached 3 feet public road. After realizing the true colours of the

Respondents/Defendants 1 and 2 and the nature of illegal property.

3. The Petitioner came to know that the said building does not have

proper Ownership documents, no construction permissions and the

building Ground + 2 Floors is constructed with deviations and

encroachment of public road and without parking. The 2 nd Floor is

constructed without structural stability. Further, the Petitioner came to

know that the commercial shops constructed by the Respondents 1 & 2

were sold to one Mr.K.Sunil Kumar @ Sunil Yadav. And the said Sunil

Yadav in-turn gave lease of the one shop to run a “Super Poultry

Chicken & Egg Centre.” Further, the Defendant No.1 has sold a shop in

the scheduled property to one Dr.Srikanth Cheryala, who is now

running ‘Meenakshi Medical & General Store’.

4. It is further submitted that the Respondent NO.1 and 2 are

trying to alienate the suit schedule property through “Notarized

Irrevocable Gift Deed” in favour of their son i.e., Dasari Krishnam Raju

by modifying H.No. 8-2-269/19/293/D/12.

5. It is submitted that the house Number of the Suit Scheduled

property is modified by the Defendants No.1 and 2 property sold

ground floor south-west corner shop to Sunil Yadav and another shop

to Dr. Srikanth Cheryala, proposed defendants No.3 & 4 with modified

House Number i.e., H.No. 8-2-269/19/473 and now modified to 8-2-

269/19/667 and further modified H.No. 8-2-269/19/293/12/A.

Thus it is clear that the Defendants No.1 and 2 are changing the house

numbers without proper authority and also changing the nature of the

property and it will seriously affect the above suit. As such there is a

need for this Hon’ble Court to issue appropriate orders directing the

Defendants not to create third party interest in the suit schedule

property. If the said order is not given then the Petitioner /Plaintiff will

suffer irreparably and cause huge loss to the Petitioner.

6. That it is submitted that in view of the facts mentioned above,

Mr.Dasari Krishnam Raju, Mr. K.Sunil Kumar @ Sunil Yadav and

Dr.Srikanth Cheryala are to be impleaded as party to the suit to enable

the petitioner/plaintiff to seek relief of Specific Performance otherwise

the petitioner /plaintiff will be put loss.

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

implead the Mr.Dasari Krishnam Raju, Mr. K.Sunil Kumar @ Sunil Yadav

and Dr.Srikanth Cheryala as party respondents to the suit and array as

Defendant No.3 to 5 and pass such other relief or reliefs as this Hon’ble

Court may deem fit and proper in the circumstances of the suit.

Deponent
Solemnly and sincerely affirm this
the day of 27-01-2023
and signed his name in my presence.

BEFORE ME

ADVOCATE :: Hyderabad
 IN THE COURT OF THE HON’BLE XI ADDL. CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.No. OF 2023

IN
O.S. NO: 387 OF 2017
BETWEEN:

SRI A. RAGHU NANDAN,

S/o. Sri Satyanarayana, aged 55 years,
Occ: Academician and Consultant,
R/o. 7-1-277/27, MIGH -205/B,
B.K.Guda, Opp: Municipal Ward Office,
S.R.Nagar, Hyderabad -38. ...Plaintiff

AND

1. SRI Dasari Ram Babu,

S/o. Kishtaiah, aged 68 years,
Occ. Business, R/o.House No.8-2-293/19/12/A,
Indira Nagar, Banjarahills, Hyderabad -500045

2 SMT. Anantha Lakshmi,

W/o. Sri D.Ram babu,
Aged about 60 years, Occ: Housewife,
R/o. House No.8-2-293/19/12/A,
Indira Nagar, Banjarahills, Hyderabad -500045. … Respondents/
Defendants No.1 & 2
3. K.Sunil Kumar @ Sunil Yadav
S/o. Not known to the Petitioner
Aged about 47 years, Occ: Business,
Sunil Kirana & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.

4. Dr.Srikanth Cheryala,
S/o. Not known to the Petitioner
Aged about 42 years, Occ: Business,
Meenakshi Medical & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.
5. Dasari Krishnam Raju,
S/o. Dasari Rambabu,
Aged about 42 years, Occ: Business,
Meenakshi Medical & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.

…. Respondent/ proposed Defendant No.3 to 5

PETITION FILED UNDER O. I Rule 10 R/w 28 OF C.P.C.

For the reasons stated in the accompanying affidavit, the

petitioner herein pray that this Hon'ble Court may be pleased to
implead the Mr.Dasari Krishanma Raju, Mr. K.Sunil Kumar @ Sunil
Yadav and Dr.Srikanth Cheryala as party respondents to the suit and
array as Defendant No.3 to 5 and pass such other relief or reliefs as
this Hon’ble Court may deem fit and proper in the circumstances of the
suit.

Place: Hyderabad
Date: 27-01-2023 Counsel for Plaintiff
IN THE COURT OF THE HON’BLE XI
Addl CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.NO. of 2023

IN

O.S. NO. 387 OF 2017

BETWEEN:

SRI A. RAGHU NANDAN,

...Plaintiff

AND

SRI Dasari Ram Babu,

And others ..Defendants

PETITION FILED UNDER

O. I Rule 10 R/w 28 OF
C.P.C.

FILED ON: 27-01-2023

FILED BY:

M/s.S.Chakrapani,
Shiva Shankar,
Advocates,
Flat No.101, Krishnaveni Pride
Apts.,
Plot No.204, Kamalapuri Colony,
Yousufguda, Hyderabad – 73

Cell No.9441219659
 IN THE COURT OF THE HON’BLE Xi ADDL. CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.No. of 2023

In

O.S. NO: 387 OF 2017

BETWEEN:

SRI A. RAGHU NANDAN ...Petitioner/Plaintiff

AND

SRI Dasari Ram Babu ..Respondent/Defendants

AFFIDAVIT

I, SRI A. RAGHU NANDAN, S/o. Sri Satyanarayana, aged 55 years,

Occ: Academician and Consultant, R/o. 7-1-277/27, MIGH -205/B,

B.K.Guda, Opp: Municipal Ward Office, S.R.Nagar, Hyderabad -38 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 the Petitioner herein has filed above suit for

Specific Performance Suit. The Petitioner herein came to know about

the nature of the Respondents 1 and 2 that they are habituated to

taking loans by entering into agreements and avoid payment by one

pretext or the other. The Petitioner further came to know that the
property which they are putting as a bait to get loans for them is an

encroached property and the documents are fabricated. Further the

building constructed on the said land is an unauthorized one and it is

constructed without leaving set-backs, parking space and also

encroached 3 feet public road. After realizing the true colours of the

Respondents/Defendants 1 and 2 and the nature of illegal property.

3. The Petitioner came to know that the said building does not have

proper Ownership documents, no construction permissions and the

building Ground + 2 Floors is constructed with deviations and

encroachment of public road and without parking. The 2 nd Floor is

constructed without structural stability. Further, the Petitioner came to

know that the commercial shops constructed by the Respondents 1 & 2

were sold to one Mr.K.Sunil Kumar @ Sunil Yadav. And the said Sunil

Yadav in-turn gave lease of the one shop to run a “Super Poultry

Chicken & Egg Centre.” Further, the Defendant No.1 has sold a shop in

the scheduled property to one Dr.Srikanth Cheryala, who is now

running ‘Meenakshi Medical & General Store’.

4. It is further submitted that the Respondent NO.1 and 2 are

trying to alienate the suit schedule property through “Notarized

Irrevocable Gift Deed” in favour of their son i.e., Dasari Krishnam Raju

by modifying H.No. 8-2-269/19/293/D/12.

5. It is submitted that the house Number of the Suit Scheduled

property is modified by the Defendants No.1 and 2 property sold

ground floor south-west corner shop to Sunil Yadav and another shop

to Dr. Srikanth Cheryala, proposed defendants No.3 & 4 with modified

House Number i.e., H.No. 8-2-269/19/473 and now modified to 8-2-

269/19/667 and further modified H.No. 8-2-269/19/293/12/A.

Thus it is clear that the Defendants No.1 and 2 are changing the house

numbers without proper authority and also changing the nature of the

property and it will seriously affect the above suit. As such there is a

need for this Hon’ble Court to issue appropriate orders directing the

Defendants not to create third party interest in the suit schedule

property. If the said order is not given then the Petitioner /Plaintiff will

suffer irreparably and cause huge loss to the Petitioner.

6. That it is submitted that in view of the facts mentioned above,

Mr.Dasari Krishnam Raju, Mr. K.Sunil Kumar @ Sunil Yadav and

Dr.Srikanth Cheryala are to be impleaded as party to the suit to enable

the petitioner/plaintiff to seek relief of Specific Performance other wise

the petitioner /plaintiff will be put loss.

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

restrain the Defendants 1 and 2 not to create any third party rights

over the Suit Scheduled Property till disposal of the suit and pass such

other reliefs as this Hon’ble Court may deem fit and proper in the

circumstances of the case.

Deponent
Solemnly and sincerely affirm this
the day of 27-01-2023
and signed his name in my presence.

BEFORE ME

ADVOCATE :: Hyderabad
 IN THE COURT OF THE HON’BLE XI ADDL. CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.No. OF 2023

IN
O.S. NO: 387 OF 2017
BETWEEN:

SRI A. RAGHU NANDAN,

S/o. Sri Satyanarayana, aged 55 years,
Occ: Academician and Consultant,
R/o. 7-1-277/27, MIGH -205/B,
B.K.Guda, Opp: Municipal Ward Office,
S.R.Nagar, Hyderabad -38. ...Plaintiff

AND

1. SRI Dasari Ram Babu,

S/o. Kishtaiah, aged 68 years,
Occ. Business, R/o.House No.8-2-293/19/12/A,
Indira Nagar, Banjarahills, Hyderabad -500045

2 SMT. Anantha Lakshmi,

W/o. Sri D.Ram babu,
Aged about 60 years, Occ: Housewife,
R/o. House No.8-2-293/19/12/A,
Indira Nagar, Banjarahills, Hyderabad -500045. … Respondents/
Defendants No.1 & 2
3. K.Sunil Kumar @ Sunil Yadav
S/o. Not known to the Petitioner
Aged about 47 years, Occ: Business,
Sunil Kirana & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.

4. Dr.Srikanth Cheryala,
S/o. Not known to the Petitioner
Aged about 42 years, Occ: Business,
Meenakshi Medical & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.
5. Dasari Krishnam Raju,
S/o. Dasari Rambabu,
Aged about 42 years, Occ: Business,
Meenakshi Medical & General Stores,
R/o. 8-2-293/19/12/A, Indira Nagar,
(lane beside Indralok Complex) Road No.2,
Banjara Hills, Hyderabad -45.

…. Respondent/ proposed Defendant No.3 to 5

PETITION FILED UNDER Order 39 Rule 1 OF C.P.C.

For the reasons stated in the accompanying affidavit, the petitioner

herein pray that this Hon'ble Court may be pleased to restrain the

Defendants 1 and 2 not to create any third party rights over the Suit

Scheduled Property till disposal of the suit and pass such other reliefs as

this Hon’ble Court may deem fit and proper in the circumstances of the

case.

Place: Hyderabad
Date: 27-01-2023 Counsel for Plaintiff
IN THE COURT OF THE HON’BLE XI
Addl CHIEF JUDGE
CITY CIVIL COURT AT HYDERABAD

I.A.NO. of 2023

IN

O.S. NO. 387 OF 2017

BETWEEN:

SRI A. RAGHU NANDAN,

...Plaintiff

AND

SRI Dasari Ram Babu,

And others ..Defendants

PETITION FILED UNDER

Order 39 Rule 1 OF C.P.C.

FILED ON: 27-01-2023

FILED BY:

M/s.S.Chakrapani,
Shiva Shankar,
Advocates,
Flat No.101, Krishnaveni Pride
Apts.,
Plot No.204, Kamalapuri Colony,
Yousufguda, Hyderabad – 73

Cell No.9441219659