By Regd Post with Ack-due

Kadapa,
23-06-2018.
From:-
1. Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District
2. Sri.M.Ramanjaneya Reddy M.A., B.L
Advocate
Door No:-2/468-1 Up stares,
Nagarajupet,
Kadapa city post and District
To:-
Sri. Sudhakar Babu B.A., B.L
Advocate and Notary
Door No. 1/954/3
Yarramukapalle Post
Kadapa city.
Sri,
Sub:- Reply notice for your legal notice dated 16-06-2018 – Rg.
Under the instructions and on behalf of our client Sri. Maddirevula
Viswanatha Reddy son of Obul Reddy, Head Master, residing in the house
bearing door No.37/21 S.N Colony Rayachoty town Post & Mandal,
Kadapa District, we hereby issue this reply notice to you for your legal
notice dated 16-06-2018 issued on behalf of your client Kalimili
Prabhakar S/o Rosaiah residing at door No. 1-3-412 Mangali street,
Nawabpet, Nellor city with the following facts.
***
1. Our client issued reply notice dated 17-05-2018 admitting the
execution of agreement of sale on 12-02-2018 for selling your notice
schedule property for Rs.65,20,000/- by receiving the token advance
amount of Rs. 16,30,000/- and that your client should pay the remaining
balance sale price within three months and get registered sale deed from
our client on or before 12-05-2018 and that your client got the
endorsement on the back of that sale agreement on 17-05-2018 by
paying Rs.15,00,000/- for getting registered sale deed on or before 18-06-
2018 after paying the balance sale price of Rs.33,90,000/- to our client.
The agreement of sale dated 12-02-2018 became void and endorsement
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after one month from 17-05-2018 i.e after 18-06-2018 became void. You
did not pay the balance sale price of Rs.33,90,000/- to our client and that
you utterly failed to get registered sale deed from our client as per the
terms of endorsement dated 17-05-2018. Hence the agreement of sale
dated 12-02-2018 and endorsement dated 17-05-2018 came to an end by
operation of law on 19-06-2018 as that agreement of sale and
endorsement of 17-05-2018 are herely cancelled as well by virtue of this
reply notice and that your client is not entitled to get refund of
Rs.31,30,000/- from our client since your client utterly failed to perform
his part of contract as recited in the agreement of sale and endorsement
of sale. Our client has been ready and willing to perform his part of
contract by executing registered sale deed in favour of your client on or
before 18-06-2018.
2. The agreement was written on 12-02-2018 in the presence of
two daughters of our client named Mounika and Noshitha and that your
client asked the daughters of our client for selling of that land to your
client. The two daughters of our client expressed their intention to
execute registrar sale deed in favour of your client as per the conditions
laid douen in the agreement of sale as well as in endorsement. So the
allegation of your client as to getting the consent of the two daughters is
meaningless since the two daughter of our client agreed on 12-02-2018
to sell that property to your client. Your client is unable to know that the
daughter of our client Mounika is that first attester to that agreement of
sale dated 12-02-2018.
3. Your client is kept in touch with real facts as to the clearing of
mortgage and loan to H.D.F.C bank and that our client gave clearance
certificates to your client. Our client gave pattadar pass books of our
client and Mounika on 12-02-2018 and our client and his two daughters
were always ready and willing to execute registered sale deed in favour
of your client on or before 18-06-2018 but your client was not ready and
willing to get regular sale deed from our client and his two daughter on
or before 18-06-2018 since your client has no money and no capacity to
pay the reaming balance consideration amount of Rs.33,90,000/- to our
client. The truth is that the son-in-law of your client refused to send
amounts to your client for purchasing this agreement schedule property.
So your client became helpless without money and that your client totally
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failed to pay the balance sale price of Rs.33,90,000/- to our client and
utterly failed to perform his part of contract on or before 18-06-2018 as
recited in endorsement dated 17-05-2018. Your client became helpless
and chosen the path of throwing the blame on our client by saying that
our client cheated your client. Our client never cheated your client since
our client gave all the title deeds and clearance certificates to your client
previously by expressing his and his daughter intention to execute regular
sale deed in favour of your client on or before 18-06-2018. Your client is
not at all entailed to get back the advance amount on the ground that
your client totally failed to perform his part of contract on before 18-06-
2018.
4. Your client issued two legal notices dated 11-05-2018 and 16-
06-2018 to our client for the purpose of harassing and defaming our
client. Our client is head master of M.P.P School at Chitluru and got
Uttam teacher award, Medal and certificate during 2005 from D.E.O of
Kadapa District. Further our client won the election for collage chairman
post during 1981-1982 became chairman for the students union of Gout
Degree collage at Rayachoty. Our client belongs highly reputed family
commanding lot of respect from the society. Your client made 4 times cell
phone calls to our client by scolding and threatening our client by going
to the extent of dismissing our client from his Head master Job. Then our
client was forced to apply for leave by fearing for the threats of your
client. The son-in-law of our client in working as engineer in America. The
second daughter of our client appeared for civil service examination and
appearing for Group-1 examination in Hyderabad. Further the second
daughter of our client was selected as professor and going to appear for
interview at Bangalore city in ISRO .The wife of our client is kidney
patient due very often visiting the house of our client and threatening
them with dire consequences. Our client got fixed with stunt, his wife and
two daughter suffered mentally and physically due to unlawful and
unethical threats of your client with regard to the agreement of sale
dated 12-02-2018. Your client defamed our client in the above
circumstance to the extent of rupees two crores towards damages. Your
client gave complaint in Rayachoty and C.K Dinne police stations against
our client even though our client did not scold and did not ill-treat your
client at any point of time. Our client treated your client with utmost
respect and Honour.
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Our client submitted the following documents to your client:-
1) Field map.
2) Pattadar pass books.
3) 1-B Namoona.
4) Registered sale deed of our client.
5) E.C
6) Clearance certificates.
5. Therefore please take this reply notice and please advise to
your client that your client is not entitled for the refund of Rs.31,30,000/-
and that amount has been forfeited to the account of our client and
further please take notice that the agreement of sale dated 12-02-2018
and the endorsement dated 17-05-2018 are hereby cancelled by virtue of
this reply notice. Further please take this reply notice that our client is
going to file defamation suit against your client in the court of law
claiming damages of rupees two crores by holding your client liable for
costs and consequences.

Advocate

Copy to party:-
Kalimili Prabhakar S/o Rosaiah,
residing at door No. 1-3-412,
Mangali street, Nawabpet,
Nellor city.