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 ...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. 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 writters
statement apart from the facts of the case pleaded either in the suit pliant or
in the written statement.
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 ner instructions. The couneel 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 aspet. Does the counsel of the petitioner is
practinig 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 plcadings 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 practing at Rajampeta. The
petitioner should be ready for virgin 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 withont facing
virgin test. The pleadings of the parties to the suit or legal procedings 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 damags
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 para 13 of the rejoinder are far away from the
truth. For instance if any person seolds a begger 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 chaiming one crore rupees towards
damages for simple allegation that she has illicit intimacy with her collegue
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
petititoner 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 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 collegues and friends before whom
she suffered defamation. The respondants are not attacking the character of
the petitioner. But the petitioner and her concel 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 Evildence Act since
those pleadings are made with bonafide 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 faclse 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 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
allegfatins made in the rejoinder of the petitioner. This rejoinder of purely
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 ageist 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 suit plaint and
rejoinder through some advocate who is unknown about the pleadings in OS
No:- 43/2017 and pleadings in the rejoinder without knowing the
consequences 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 Ni:08/2013 that the fact of illicit
intimacy of plaintiff with chandrasekher Reddy was mentioned in M.C No:-
08/2013 by the advocate of the first defendant named Sri.Nusruddin of
Rajampeta on the file of J.F.C.M court at Rajampeta. There no whisper or
allegation against Sri.Nasuruddin advocate of Rajampetra who prepared M.C
No:-8/2013 petitioner alleging illicit intimacy of the plaintiff with
Chandrasekher 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.

11.Therefour the defendant 2 and 3 pray that the Honorable

Court may be pleased to dismiss this rejoinder petitioner in the interest of
justice.

Advocate