IN THE COURT OF FOUTH ADDL DISTRICT JUDGE AT KADAPA

I.A No:-1471/2017
In
O.S No:- 43/2017
M.Bhargavi ...Petitioner/Plaintiff
Vs.
1.Smt.G.Aruna@Harini
2.M.Ramajaneya Reddy ...Respondents
3.K.Venkata Reddy /Defendants

Counter filed on behalf of the Respondents/Defendants 2 and 3

1.This petition is unjust and not at all maintainable either in law or

on facts.
2.The Petitioner is put to strict proof on all the allegations made in
the rejoinder which are not expressly admitted herein by these
respondents. The writer statement of these defendants 1 to 3 may kindly
be read as part and parcel of this counter.
3.This rejoinder of this petitioner is not prepared as per the
instructions of the petitioner. Some interested third party went to
Hyderabad and a got it prepared as per whims and fancies of the third
party. The petitioner did not give such false and purely illegal insrtuetions
to her councel appearing on her behalf in this suit at present for filing this
type of totally false and unwarranted rejoinder without the knowledge of
the advocate on the record of the suit of the plaintiff at present.
4.The petitioner made all the irrelevant and false allegations in her
suit against the respondents 2 and 3 and that the defendants 2 and 3
filed their written statement with all true facts against false allegations
of the plaintiff . So there is on necessity to file this rejoinder by repeating
the same false allegations in this rejoinder. The subsequent pleadings
arise only when there is a new fact is pleaded in the written statement
apart from the facts of the case pleaded either in the suit pliant or in the
written statement.
 ::2::
5.The councel who prepared the rejoinder is thinking that all the
facts in the written statement are afterthought. How can that councel
who prepared the rejoinder knows that it is after thought or before
thought to write pleadings as per the instructions of the parties to the
suit or proceedings. The first defendant in her writer statement pleaded
in Telugu language that she instructed her advocates to prepare
pleadings in T.O.P No:-339/2016 and counter in D.O.P No:-20/2016 as per
her instructions. The councel of the petitioner wanted the advocates of
the first defendant what is not instructed to her advocates which will be
helpfull to the petitioner and against the interests of the first defendant.
The councel who prepared the rejoinder of the petitioner wanted the
advocates of the first defendant to write which are not instructed by the
first defendant in order to help the petitioner. The councel of the
petitioner is not tracing the truth in the facts of the first defendant raised
in T.O.P No:-339/2016 and Counter in D.O.P No:-20/2016 but he is simply
saying that it would the tell-tale aspect. Does the councel of the
petitioner is practicing his profession by making tell-tale allegations
against the interests of his client bye-passing the interests of his client
beyond the instructions of his client in order to help to his opponents.
6.The respondents did not make any fresh pleadings in T.O.P No:-
339/2016 and counter in D.O.P No:-20/2016 which are not pleaded in
M.C No:-8/2013. The illicit intimacy of the plaintiff with Chandrasekhar
Reddy, joint preparing for group II examinations and other facts are
pleaded in the M.C No:- 8/2013 by the advocate of the first defendant
practicing at Rajampeta. The petitioner should be ready for virginity test
by All Indian Medical Council at Delhi if the petitioner wants to disprove
the pleadings of the first defendant. The truth cannot by hidden by filing
this type of false rejoinder without facing virginity test. The pleadings of
 ::3::
the parties to the suit or legal proceedings cannot come under
defamation as per section 499 of I.P.C. The averment should be made in
the form of pleadings for establishing the truth by way evidences and
medical report. The councel of the petitioner feels every word is
defamatory and liable for claiming damages. At this rate no pleadings can
be made against the party to the suit or proceedings as per the councel
of the petitioner who drafted the rejoinder of the petitioner. The person
who wants to claim damages should stand for medical scrutiny and other
forms of evidence for establishing her false claim of rupees one crore
damages.
7.The allegations made in pera 13 of the rejoinder are far away
from the truth. For instance if any person scolds a beggar or penniless
person, does he claim lakhs or crores of rupees towards damages for
defaming him by scolding that beggar or penniless person. The petitioner
who does not know difference between girl and woman, but she is
claiming one crore rupees towards damages for simple allegation that
she has illicit intimacy with her colleague named chandrasekhar Reddy.
There are no merits in this application and this petitioner filed this false
and vexatious petition with malafide intention by hiding the truth.
8.These respondents 2 and 3 did not attack the reputation of the
petitioner at any point of time. The petitioner did not state even in the
rejoinder about the names, address and places where and when the
plaintiff was defamed and who spoke about those defamatory statement.
The petitioner is sailing in the wind and dreaming about rupees one crore
towords damages without mentioning the names and addresses and
places where she suffered defamation. How does the facts made in T.O.P
No:-339/2016 and counter in D.O.P No:-20/2016 are defamatory when
the plaintiff utterly failed to give names of the colleagues and friends
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before whom she suffered defamation. The respondents are not
attacking the character of the petitioner. But the petitioner and her
councel are attacking the whole advocates profession and Advocates Act
of 1961.
9.The professional communications between the advocate the and
client are privileged communications as per section 126 of Evidence Act
since those pleadings are made with bonfide intention to safe guard the
interests of his client on the instructions of the client that is first
defendant. The responds 2 and 3 have duty to safeguard the interties of
his client and not to help to the opposite party by writing pleading in
support of the case of the opposite party by betraing the interests of his
client. It seens that the counsel who prepared this rejoinder has more
responsibility to help to his opponent rather than defending his own
client by causing loss and in justice to his client .
10.The allegations made in pare 18 the rejoinder are totally false
and in vented for the purpose of this false suit of the plaintiff. It is too
much to the councel who wrote rejoinder to state that the defendants 2
and 3 and that the defamatory allegations made in the suit plaint are the
words were clearly originated from D-2 and D-3 and that D-2 and D-3 of
liable for lebel. The advocate who drafted the rejoinder is personally
liable for making personal attack on the advocates and advocates Act and
that advocate is liable for criminal prosecution and civil suit is going to be
filed against him for damages for making such irresponsible and false and
baseless allegations against the reputed and senior advocates appearing
for the first defendant who filed T.O.P No:-339/2016 and counter in
D.O.P No:-20/2016. There is no truth in the allegations made in the
rejoinder of the petitioner. This rejoinder of the petitioner is purely
 ::5::
meant to defame the advocates at large and that rejoinder is against the
provisions of Advocates Act and the procedure established by law.
10 (A). A close reading of the plaint and rejoinder it is clearly
establishes that one advocate practicing at Hyderabad who belongs to
Kadapa District and some groups of advocates at Kadapa are having
personal animosity, jealousy, enmity etc. in the profession against the
defendants 2 and 3 who are directly unable to came to picture to file
vakalat in OS No:-43/2017 and rejoinder 1471/2017 are playing this
mischiefs game by personally attacking the respondent 2 and 3 in this
case and filing the false suit plaint and false rejoinder through some
advocate who is unknown about the pleadings in OS No:- 43/2017 and
pleadings in the rejoinder without knowing the consequences of criminal
prosecutions and suit for damages that are going to be taken by the
respondents 2 and 3 for making personal attack on the respondent-
Defendants 2 and 3 inspite of clear cut pleading made by the first
defendant-first respondent in her written statement as well as in I.A No:-
1200/2017. It is clearly mentioned in M.C No:- 08/2013 that the fact of
illicit intimacy of plaintiff with chandrasekhar Reddy was mentioned in
M.C No:-08/2013 by the advocate of the first defendant named
Sri.Nasiruddin of Rajampeta on the file of J.F.C.M court at Rajampeta.
There no whisper or allegation against Sri.Nasiruddin advocate of
Rajampeta who prepared M.C No:-8/2013 petitioner alleging illicit
intimacy of the plaintiff with Chandrasekhar Reddy. It Reveals and given
strength to contention of the respondents-defendants 2 and 3 that there
it conspiracy, jealousy, and enmity in making personal attack on the
advocates who are defendants 2 and 3 in the suit. This rejoinder is liable
to be dismissed in view of above stated true facts.
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11.Therefore the defendants 2 and 3 pray that the Honorable Court
may be pleased to dismiss this rejoinder of the petitioner with exemplary
costs in the interest of Justice.

Advocate for Respondents/Defendants 2 and 3

The above stated facts are verified by us and the above stated facts
are true and correct to the best of our knowledge, information and belief
and put our signature on this on 19 day of January 2018 at Kadapa.

Advocate for Respondents/Defendants 2 and 3

IN THE COURT OF FOUTH ADDL
DISTRICT JUDGE KADAPA

I.A No:-1471/2017
In
O.S No:- 43/2017

M.Bhargavi

...Petitioner/Plaintiff

Vs.

1.Smt.G.Aruna@Harini
2.M.Ramajaneya Reddy
3.K.Venkata Reddy
...Respondents/Defendants

Counter filed on behalf of the

Respondents/Defendants 2 and 3

Filed by:-

Sri. P.Srikanth Reddy, M.A., B.L.,

Advocate for Respondents/Defendants
2 and 3
Kadapa – 516001.