By Regd Post with Ack-due

Kadapa city,
Date:13-11-2017.
From
Sri.K.Venkata Reddy B.Com, B.L
Advocate
2/476 Nagaraju peta,
Kadapa City

To

The Tahsildar of Vempalli

Vempalle mandal Revunue office
Vempalle Town post and Mandal
Kadapa District.

Sir,
Sub:- Legal notice for not issuing pattadar pass and title deed in the name of
Kotturu chennaiah or his legal heirs for the schedule lands by cancelling the
pattadar pass book and title deed of my client for the schedule property due
to the pendency of A.S 80/2017 of my client and O.S 8/16 of Venkata
Ramanaiah in courts at Kadapa city-Rg .

Under the instructions and on behalf of my client Sri.Adimulam Uttanna son

of late potti vempalle aged about 60 years, residing in Kapu veedhi, Vempalle,
Town, post and Mandal Kadapa District, I hereby issue this legal notice to you with
the following facts.

1.One Smt. Lakshimi Devi wife of Ramamohan aged about 62 years residing
in main Bazar in Vemapalle Town & Mandal, Kadapa District, firsly made totally
false agreement of sale with ante date dated sale agreement dated 05-09-1995 in
favour of her relative named sure Venkata Ramanaiah S/o Chinna Venkata Ramaiah
residing at Vempalle Town & Mandalm Kadapa District , at present residing at door
No:-32/94-2 Devuni Kadapa, Kadapa city for the schedule property for the alleged
sale consideration of Rs:-2,16,000/- in order to defeat, the already sold schedule
property to my client on 08-02-1996 for Rs:-1,40,000/-. The said Inugonda Lakshmi
Devi firstly sold the schedule property to my client on 08-02-1996 for Rs:-
1, 40, 000/- . The said Lakshimi Devi fraudulently made an agreement of sale in
favour of her Ielatine sure Venta Ramanaiah with ate date agreement dated 05-09-
1995. The said Ingonda Lakshimi Devi thirdly sold the same schedule property to
her elder brother named Chennaiah on 08-07-2002.
 (2)

2.The said Lakshmi Devi sold the schedule property to three persons named
1.Sure Venkata Ramanaiah 2. Adimulam Uttanna (my client) and 3. Chennaiah with
fraudulent intention. My client filed O.S 146/2002 in Principal Senior Civil Judge
Court at Kadapa agaist Inagonda Lakshmi Devi and Chennaiah who died in 2013
year by leaving his widow, daughter and sons and also against Sure venkata
Ramanaiah and that court dismissed that O.S 146/2002 on 06-09-2017 without
costs. My client filed appeal A.S 80/2017 in Sixth Addl District Judge Court at Kadapa
against the said 09 persons for getting the schedule property by setting aside the
decree and Judgement of the lower court passed on 06-09-2017 and for getting the
decree and Judgement in O.S 146/2002 in favour of my client for the schedule
property. The said appeal A.S 80/2017 is pending in Sixth Addl District Judge court
at Kadapa and that appeal A.S 80/2017 is posted to 06-12-2017 for appearance of
those 09 persons in that court on 06-12-2017.

3.Sure Venkata Ramanaiah also filed O.S No:-08/2016 in Addl Senior Civil
Judge Court at Kadapa against Inugonda Lakshmi Devi and also agaist my client for
the schedule property which is posted to 13-12-2017 in that court for enquiry. The
alleged purchaser of the schedule property during 2002 year named Chennaiah
being the elder brother of Lakshmi Devi died during 2013 year by leaving his widow,
sons and daughter who did not file any suit in any Court against Lakshmi Devi and
my Client for getting decree over the schedule property. So Kotturu Chennaish and
his Legal heirs did not get the schedule property since there is no decree and
Judgment in favour of Kotturu Chennaiah and his legal heirs from any court. So
Kotturu Chennaiah or his legal heirs have no right or authority over the schedule
land.

4.There is one appeal A.S 80/2017 in Sixth Addl District Judge Court at
Kadapa and one Civil Suit O.S 8/2016 in Addl Senior Civil Judge court at Kadapa are
pending in those Courts for the schedule property. So the Legal heirs of Kotturu
Chennaiah have no right or authority to get pattadar pass book and title deed in
their names for the schedule property until the disposal of A.S 80/2017 and O.S
8/2016 relating to schedule property in those courts. My client has every right and
title to have valid pattadar pass book and title deed in his name without any
cancellation of those records for the schedule property.

5. Therefore please take this legal notice and that my client is praying you
not to cancel pattadar pass book and title deed of my client for the schedule
property and not to issue pattadar pass book and title deed in the names of Kotturu
Chennaiah or his legal representatives until the disposed of appeal A.S 80/2017 in
Sixth Addl district Judge Court at Kadapa and O.S 8/2016 in Addl Senor Civil Judge
Court at Kadapa over the schedule mentioned property of my client in the interests
of Justice.

Advocate
 (3)

Schedule

Landed property situated in Vempalle village field’s Vempalle mandal,

Vempalle Sub District, Kadapa District.

S No:-247 Extent Acs 2.42 out of Acs 4.84.

Boundaries:-

East - Land of Lakhmi Devi

West - Land of Yaddula Venkataiah
North - Vanka
South - Rasta

Enclosures:-

(1).Copy of agreement of sale dated 05-09-1995 executed by Lakshmi Devi in

favour of sure Venkata Ramanaiah for the schedule property.

(2).Copy of agreement of sale dated 08-02-1996 executed by Lakshmi Devi in

favour of Adimulam Uttanna( my client).

(3). Copy of appeal A.S 80/2017 on the file Sixth Addl District Judge at Kadapa
posted to 06-12-2017.

Advocate
 By Regd Post with Ack-due
Kadapa city,
Date:13-11-2017.
From
Sri.K.Venkata Reddy B.Com, B.L
Advocate
2/476 Nagaraju peta,
Kadapa City

To
The Revenue Divisional Officer
Office of the R.D.O
Jammalamadugu Town Post and Mandal
Kadapa District

Sir,
Sub:- Legal notice for not issuing pattadar pass and title deed in the name of
Kotturu chennaiah or his legal heirs for the schedule lands by cancelling the
pattadar pass book and title deed of my client for the schedule property due
to the pendency of A.S 80/2017 of my client and O.S 8/16 of Venkata
Ramanaiah in courts at Kadapa city-Rg .

Under the instructions and on behalf of my client Sri.Adimulam Uttanna son

of late potti vempalle aged about 60 years, residing in Kapu veedhi, Vempalle,
Town, post and Mandal Kadapa District, I hereby issue this legal notice to you with
the following facts.

1.One Smt. Lakshimi Devi wife of Ramamohan aged about 62 years residing
in main Bazar in Vemapalle Town & Mandal, Kadapa District, firsly made totally
false agreement of sale with ante date dated sale agreement dated 05-09-1995 in
favour of her relative named sure Venkata Ramanaiah S/o Chinna Venkata Ramaiah
residing at Vempalle Town & Mandalm Kadapa District , at present residing at door
No:-32/94-2 Devuni Kadapa, Kadapa city for the schedule property for the alleged
sale consideration of Rs:-2,16,000/- in order to defeat, the already sold schedule
property to my client on 08-02-1996 for Rs:-1,40,000/-. The said Inugonda Lakshmi
Devi firstly sold the schedule property to my client on 08-02-1996 for Rs:-
1, 40, 000/- . The said Lakshimi Devi fraudulently made an agreement of sale in
favour of her Ielatine sure Venta Ramanaiah with ate date agreement dated 05-09-
1995. The said Ingonda Lakshimi Devi thirdly sold the same schedule property to
her elder brother named Chennaiah on 08-07-2002.
 (2)

2.The said Lakshmi Devi sold the schedule property to three persons named
1.Sure Venkata Ramanaiah 2. Adimulam Uttanna (my client) and 3. Chennaiah with
fraudulent intention. My client filed O.S 146/2002 in Principal Senior Civil Judge
Court at Kadapa agaist Inagonda Lakshmi Devi and Chennaiah who died in 2013
year by leaving his widow, daughter and sons and also against Sure venkata
Ramanaiah and that court dismissed that O.S 146/2002 on 06-09-2017 without
costs. My client filed appeal A.S 80/2017 in Sixth Addl District Judge Court at Kadapa
against the said 09 persons for getting the schedule property by setting aside the
decree and Judgement of the lower court passed on 06-09-2017 and for getting the
decree and Judgement in O.S 146/2002 in favour of my client for the schedule
property. The said appeal A.S 80/2017 is pending in Sixth Addl District Judge court
at Kadapa and that appeal A.S 80/2017 is posted to 06-12-2017 for appearance of
those 09 persons in that court on 06-12-2017.

3.Sure Venkata Ramanaiah also filed O.S No:-08/2016 in Addl Senior Civil
Judge Court at Kadapa against Inugonda Lakshmi Devi and also agaist my client for
the schedule property which is posted to 13-12-2017 in that court for enquiry. The
alleged purchaser of the schedule property during 2002 year named Chennaiah
being the elder brother of Lakshmi Devi died during 2013 year by leaving his widow,
sons and daughter who did not file any suit in any Court against Lakshmi Devi and
my Client for getting decree over the schedule property. So Kotturu Chennaish and
his Legal heirs did not get the schedule property since there is no decree and
Judgment in favour of Kotturu Chennaiah and his legal heirs from any court. So
Kotturu Chennaiah or his legal heirs have no right or authority over the schedule
land.

4.There is one appeal A.S 80/2017 in Sixth Addl District Judge Court at
Kadapa and one Civil Suit O.S 8/2016 in Addl Senior Civil Judge court at Kadapa are
pending in those Courts for the schedule property. So the Legal heirs of Kotturu
Chennaiah have no right or authority to get pattadar pass book and title deed in
their names for the schedule property until the disposal of A.S 80/2017 and O.S
8/2016 relating to schedule property in those courts. My client has every right and
title to have valid pattadar pass book and title deed in his name without any
cancellation of those records for the schedule property.

5. Therefore please take this legal notice and that my client is praying you
not to cancel pattadar pass book and title deed of my client for the schedule
property and not to issue pattadar pass book and title deed in the names of Kotturu
Chennaiah or his legal representatives until the disposed of appeal A.S 80/2017 in
Sixth Addl district Judge Court at Kadapa and O.S 8/2016 in Addl Senor Civil Judge
Court at Kadapa over the schedule mentioned property of my client in the interests
of Justice.

Advocate
 (3)

Schedule

Landed property situated in Vempalle village field’s Vempalle mandal,

Vempalle Sub District, Kadapa District.

S No:-247 Extent Acs 2.42 out of Acs 4.84.

Boundaries:-

East - Land of Lakhmi Devi

West - Land of Yaddula Venkataiah
North - Vanka
South - Rasta

Enclosures:-

(1).Copy of agreement of sale dated 05-09-1995 executed by Lakshmi Devi in

favour of sure Venkata Ramanaiah for the schedule property.

(2).Copy of agreement of sale dated 08-02-1996 executed by Lakshmi Devi in

favour of Adimulam Uttanna( my client).

(3). Copy of appeal A.S 80/2017 on the file Sixth Addl District Judge at Kadapa
posted to 06-12-2017.

Advocate