IN THE COURT OF THE HON’BLE VIII JUNIOR CIVIL JUDGE:

CITY CIVIL COURT, AT: HYDERABAD.

OS.No. 2510 OF 2022

BETWEEN:-
Punna Raj Gopal
…Plaintiff

AND

Mamidi Venkat Kumar …Defendant

WRITTEN STATEMENT FILED BY DEFENDANT

The Defendant herein submits the Written Statement to the above suit, as
Under: -

1. At the outset, the suit filed by the plaintiff for the relief of suit for
Perpetual Injunction restraining the defendant their agents, henchmen or
anybody claiming through them from interfering with the enjoyment of
the property being peacefully enjoyed by the plaintiff as owner, in respect
of the suit schedule property is not maintainable in the eye of law, as the
Plaintiff had suppressed true facts by misleading the Hon’ble court want
to obtain the orders of Interim injunction to grab the property of the
Defendant , illegally and unlawfully, and by wasting the precious time of
this Hon’ble court by way of filing this type of case. The plaintiff his
called upon to prove the allegations made in the plaint under reply. The
allegations specifically denied by this defendant are hereby called upon to
prove the same. The allegations which are not specifically admitted are
deemed to be denied and called upon to prove the same strictly. The suit
is not maintainable and is liable to be dismissed in limini.

Contd: 2
 :: 2 ::

2. Paras I and un-para no. II of the plaint pertains to description of the

parties, needs no specific reply.

3. That the defendant herein submits that in reply to para 3 of the plaint it is
false that the plaintiff is the absolute owner and possessor of the House
bearing Municipal No. 18-1-203/82/A, plot No. 80/A, admeasuring 50
Square yards or equivalent 41.80 Sq. meters, situated at Krishna Reddy
Nagar, Uppuguda, Hyderabad, having acquired the same through alleged
a registered Gift Deed bearing document No. 3612 of 2022 dated 19-05-
2022 from its lawful owner and possessor Smt. P. Uma Rani, who is
plaintiff mother. It is false and denied by the defendant herein that the
plaintiff from the date of acquiring he is in peaceful possession and
enjoyment of the said acquired property as absolute owner till today and
previously my mother was in peaceful possession of the suit schedule
property. As matter of fact the plaintiff father P. Ashok S/o. P.
Shankaraiah, sold the property through Notarized Agreement of Sale in
favour of G. Srinivas who is the vendor of the defendant herein dated 9-
04-2001, and the said G. Srinivas sold the property in favour of defendant
herein through Notarized Agreement of Sale dated 26-07-2017 and from
that date on wards defendant herein is in the peaceful possession of the
suit schedule property.

4. That the defendant herein submits that in reply to para 4 of the plaint, it is
true that originally Mohammed Yousufuddin S/o. Gulam Mohiuddin is
the original owner of the open land bearing plot No. 82 in Sy. No. 87
admeasuring 100 Sq. yards. It is true that wherein the said land owner
Contd : 3
 :: 3 ::

sold away the same in favour of M. Raj Narsamma, W/o. M. Narsimha

through Notarized Agreement of Sale dated 06-03-1987, thereafter M.
Raj Narsamma executed an Registered Irrevocable General Power of
Attorney deed vide document No. 1395 of 1993 dated 20-08-1993 in
favour of Tirumani Kalavathi and appointer her as the General Power of
Attorney with all powers on her name in respect of plot bearing No. 82 in
Sy.No. 87 admeasuring 100 Sq. yards situated at Krishna Reddy Nagar,
Uppuguda. It is true that Tirumani Kalavathi has sold away the plot
admeasuring 50 Sq.yards out of 100 Sq.yards in Sy.No. 87 of house
bearing No. 18-1-203/82/A with on asbestos room in favour of Punna
Ashok/ S/o. P. Shankariah through a Notarized Agreement of sale dated
20-07-1996. It is false to say that the Punna Ashok has sold away the
same in favour of Makkam Ramesh, through Notarized Agreement of
Sale dated 27-10-2007. As matter of fact the said Punna Ashok already
sold the said property in favour of G. Srinivas through Notarized
Agreement of sale dated 9-04-2001 and the said G. Srinivas had sold
through Notarized Agreement of sale in favour defendant herein. It is
false and denied that Makkam Ramesh has sold away the same in favour
of P. Uma Rani, W/o. Punna Ashok through a Notarized Agreement of
Sale dated 28-12-2020 and thereafter plaintiff mother became an
original owner and possessor of the suit schedule property. It is false to
say that the mother of plaintiff namely P. Uma Rani has gifted the above
described property with natural love and affection towards the plaintiff
through Registered Gift Settlement Deed, vide document No. 3612 of
2022, dated 19-05-2022.
Contd: 4
 :: 4 ::
5. That the defendant herein submits that in reply to para 5 & 6 of the plaint,
it is false and denied that the plaintiff herein had executed a fabricated
document and it false that the plaintiff duly has paid the property tax.
And it is further submit that it is false that the plaintiff is enjoying the
same as absolute owner and possessor till today.

6. That the defendant herein submits that in reply to para 7 of the plaint the
contents of the para under reply are false and baseless, hence denied.

7. That the defendant herein submits that in reply to para 8 of the plaint, the
entire allegations of the para under reply are false, baseless, created and
concocted story of the plaintiff, only in order to get some orders and
under the guise of such orders he wanted to grab the suit schedule
property and it is false to say that defendant having developed ill
intention towards the suit schedule property due to increase of land values
in vicinity of the suit schedule property and came to the suit schedule
property with their henchmen’s on 12-06-2022 and tried to occupy with a
sole intention to cause loss to the plaintiff who is an lady on 24-05-2021
the defendant No.2 had come to the suit schedule property and forcible
tried to evict the same illegally. It is false to say that defendant and his
henchmen on 17-06-2022 and tried to occupy the suit schedule property
at that time the plaintiff with help of his family members have resisted
the illegal acts of the defendant and also lodged complaint. It is false to
say that police visited the suit schedule property on the same day and on
seeing the police officials, the defendants and his henchmen’s were fled
away by threatening me that they will occupy the suit schedule property

Contd: 5
 :: 5 ::

by one way or the other, but police failed to register the complaint but
they have suggested me to approach the civil court stating that the matter
is civil in nature.

8. That the defendant herein submits that in reply to para 9 of the plaint, the
plaintiffs has got no cause of action and the dates as mentioned in the
para does not claim the cause of action for filing the present suit, and the
plaintiff had filed the present suit with all false and fabricated documents,
baseless allegations created and concocted story, as such the suit is liable
to be dismissed for want of cause of action.

9. That the defendant herein submits that in reply to para 10 of the plaint,
the plaintiff undervalued the suit and paid the insufficient court fees, and
as such the suit is liable to be dismissed for undervaluing and paying the
insufficient court fees.

10. That the defendant herein submits that in reply to para 11 of the plaint,
when the plaintiff had no cause of action for filing the present suit, as
such this Hon’ble court has got no Jurisdiction to entertain the suit.

11. That the defendant herein submits that in reply to para 12 of the plaint,
the prayer of the plaintiff is misconceived, mischievous and
misrepresented, and as such the same cannot be granted and is liable to be
dismissed in limini.

Contd: 6
 :: 6 ::

12.That the defendant is relying on the following documents:-

i) Xerox copy of Notarized Agreement of Sale dated 9-08-2001,
ii) Xerox copy of Notarized Agreement of Sale dated 26-07-2017.
iii) Xerox copy of property tax receipt dated 03-06-2022.

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

dismiss the suit of the plaintiffs with exemplary costs, in the interest of
justice.

PLACE: Hyderabad.

DATE: 27-07-2023. DEFENDANT

COUNSEL FOR THE DEFENDANT

VERIFICATION
I, the Defendant No.3, herein do hereby declare that all the contents of the
above written statement are true and correct to the best of my knowledge
and belief, hence verified the same on this the 27th day of July, 2023, at
Hyderabad.

PLACE: Hyderabad.

DATE: 27-7-2023. DEFENDANT

 IN THE COURT OF THE
HON’BLE VIII JUNIOR CIVIL
JUDGE: CITY CIVIL COURT
AT: HYDERABAD.
O.S.NO. 2510 OF 2022

BETWEEN: -

Punna Raj Gopal

…Plaintiff

AND

Mamidi Venkat Kumar

…Defendant

WRITTEN STATEMENT
FILED BY DEFENDANT

Filed on: 27-7-2023

Filed by:-

M/s. Arvind Kumar Mavoori &

Associates

Counsel for Defendant