IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant

PLAINT FILED ON BEHALF OF THE PLAINTIFF UNDER ORDER

VII AND RULE 1 OF CIVIL PROCEDURE CODE

Plaintiffs : 1.E.Lakshmi Devi W/o Krishnappa aged

60 years
2. Smt. D.Ramalakshmamma W/o
Chengalrayudu aged about 45 years, Both
Plaintiffs are Hindus, Cultivation Residing at
Gowdisanipalli Village, H/o Kothavaripalli,
Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State.

The address of the plaintiff is as above and also

C/o
Sri. K. Manohara Chari, smt. S.Saritha Advocate,
Madapalli.

Defendant : 1. T.Eswaraiah S/o Siddappa aged

about 50 years. Hindu, cultivation, residing at
Gowdisanipalli Village, H/o Kothavaripalli,
Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State.

The address of the respondent is as stated above

for service of notices etc.,

1. It is submits that plaintiffs, 1 and 2 are Wife and

daughter of Krishnappa, and defendant is brother
of Krishnappa , Both Krishnappa and defendant are sons of
Late Siddappa. Here giving Genealogical tree of plaintiffs
and defendant family.
Siddappa

Krishnappa (died)
Eswaraiah
H/o Lashmidevi 1st Plaintiff (Def.)

Ramalakshmamma
(2nd Plaintiff )
 2. The plaintiffs and defendant are members of Joint
Hindu Family and Co-partners they are living in one
roof at Gowdisanipallii. The properties mentioned in
the schedule

Corr.
Con..2
//2//
here under originally belongs to Siddappa, The said
land is classified as A.W.D. land during life
time of Siddappa, developed the land for cultivation
and cultivated the land, basing upon his possession
and enjoyment the then Thasilder Madanapalli Issued
D.K.T. Patta in his name at about 40 years back.The
Siddappa has got two sons named as Krishnappa and
Eswaraiah, after his death his two are jointly enjoying
the suit schedule property with out dispute as a
ancestral property.

3. It is submits that during the misunderstanding

between the female members, The sons of Siddapa
namd as Krishnappa and Eswaraiah is living
separately, the Krishnappa died in the year 1998,
living behind him his wife and daughter that is
plaintiffs are enjoying the share of Krishnappa, as
jointly, it has become difficult among the plaintiffs
and the defendant to be in joint family. There is no
scope to continue as joint family enjoying the
properties jointly. As per law the plaintiffs are entitled
for share of the plaint schedule property.

4. The plaintiffs are enjoying share in the plaint

schedule
property and give separate possession of the same
from long back. But the defendant is not
 ready and willing to partition the plaint schedule
property and give separate possession of his share to
the plaintiffs for obtain Pattader pass books and title
deeds from revenue Office. The defendant is making
attempts to dispose of the joint family property
without consent of the plaintiffs to their parties
named as Vasala Ramaiah and Bala Raju s/o
Gangainah of the same village for the purpose of
shifting of Silt in the suit scheduled property . Hence
the suits is filed for division of plaint schedule
property in to two equal shares by meets and bounds
and allots one such share to the plaintiffs in the plaint
schedule property.

5. The cause of action for the suit arose when the

siddappa arose D.K.T patta to the suit scheduled
property after that his elder son named as
Krishniappa died intestate in the year 1998 after
his death the plaintiff is enjoying the suit schedule
property with out disputes from any body at since
one year the co-share of the schedule property
that is defendant is trying to sale the extent to the
third parties for lifting the silt in the schedule
property with out permission of plaintiff and the
third parties are change the physical features of
the schedule property and also damaged the
tombs in the schedule property at about two date
back the plaintiffs question the act of the third
party the defendant is causing misbehaviour to
the plaintiffs so the plaintiffs filed this suit against
defendant for partition the suit property and give
separate possession of her share in the schedule
property within the jurisdiction of this Honble
court.

6. PARTICULARS OF VALUATION
 The suit schedule property is Govt. land, Rs.
60,000
Value of the plaintiffs share is Rs.
30,000
Value for the purpose or court fee and Rs.
20,000
Jurisdiction of the plaintiffs share is

A fixed court fee Rs. is paid under Sec. 34 (2)

(ii) of A.P.C.F. Act.

As per order of A.P. High Court Circular ROC.

12/SO/2002 dt:
28-02-2002 . The court fee of Rs. in view of court
stamps has been paid in cash vide challan No. dt:
in the bank of
at Madanapalli

7. PRAYER

It is therefore most humbly prayed that this Honble

court may be pleased to pass decree and judgment in favour
of the plaintiff against the defendant.
a. directing the defendant to partition the plaint schedule
joint family property in two equal shares by meats and
boundaries taking into good and bad into consideration
and put the plaintiffs in separate possession of such
share for obtain pattader pass books and title deeds
from revenue authorities, by process of law.
b. To ward suit costs and
c. Pass such other and further reliefs which this Honble
court deems fit and proper under the circumstances of
the case in the interest of justice.

The facts stated above are true and correct to the

best of my
knowledge and belief and information.

Madanapalli
Dt: - -2014 Plaintiff
 SCHEDULE

Chittoor Dist, Madanapalli Sub-Dist ,& Mandal, Kothavaripalli

Dakala, Gollapalli village mazara.

S.No:182/6, Dry an extent of 2.32 Cents DKT land

Bounded by East :Land of Reddivarpalli Peddappa South :

Indrabhavi West: Vanka North : Kalva

Plaintiffs

VERIFICATION

The schedule given above is true and correct.

Plaintiff

LIST OF DOCUMENTS

Valuation Certificates of suit property.

Advocate for Plaintiff

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant

STATEMENT FILED ON BEHALF OF THE PLAINTIFFS UNDER

ORDER VI RULE 14 (a) AND SECTION 151 OF C.P.C

Plaintiffs : 1.E.Lakshmi Devi W/o Krishnappa aged 60

years
2. Smt. D.Ramalakshmamma W/o
Chengalrayudu aged about 45 years, Both
Plaintiffs are Hindus, Cultivation Residing at
Gowdisanipalli Village, H/o Kothavaripalli,
Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State.
 Defendant :1. T.Eswaraiah S/o Siddappa aged about 50
years. Hindu, cultivation, residing at
Gowdisanipalli Village, H/o Kothavaripalli,
Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State.

Advocate for plaintiffs Plaintiffs

The above stated facts are read over and explained to me and I

found that there are true and correct to the best of my knowledge,

belief and information.

Madanapalli

Dt: Plaintiffs

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant

PROOF AFFIDAVIT FILED BY THE PLAINTIFF

I Smt. E.Lakshmi Devi W/o Krishnappa aged 60 years,

Hindus,
Cultivation Residing at Gowdisanipalli Village, H/ o
Kothavaripalli, Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State., do here by solemnly affirmed and stated as
follows;
1. I am the 1st Plaintiff in the above suit deponent here in. I am filing this
affidavit on behalf of another plaintiff also. I know the facts of the case,
defendant and also the suit Scheduled property. The enclosed plaint maybe
read as part and parcel of this affidavit.

2. I submit that the property mentioned in here under scheduled property,

here in after called as suit Scheduled property originally belongs to
Siddappa, during his life time siddappa developed the suit land and
cultivated the land basing upon his cultivation the then the thasildar issued
D.K.T Patta to him.

3. I further submit that after the death of Siddappa my husband named as

Krishnappa and his brother defendant here is enjoying jointly to scheduled
property and other properties stands in the name of siddappa with out
division as meats and bounds. I submit that my Husband died in the year
1998, after death of my husband I along with daughter is cultivating the suit
scheduled property as per my respective share, Now the defendant trying
to alienate to suit scheduled property by obtain P.P.B & T.D. to the scheduled
property by colluding revenue authorities. The sale deeds stand to the
scheduled property and to knock way my share in the scheduled property
with right, title & possession as full extent.
Hence we have filed present suit against the defendant for partition of
share in the suit scheduled property.

Hence the honourable my be pleased to number the suit and issue notice
to defendant

Deponent
st
Solemnly affirmed and signed before me on this day of 21 Sep.2014 at
Madanapalli
Advocate, Madanapalli

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant

AFFIDAVIT FILED BY THE PLAINTIFFUNDER ORDER VI RULE

15(4) AND SECTION 151 OF C.P.C.

I Smt. E.Lakshmi Devi W/o Krishnappa aged 60 years,

Hindus,
Cultivation Residing at Gowdisanipalli Village, H/ o
Kothavaripalli, Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State., do here by solemnly affirmed and stated as
follows;
1. I am the 1st Plaintiff in the above suit deponent here in. I am filing this
affidavit on behalf of 2nd plaintiff also. I know the facts of the case,
defendants and also the suit Scheduled property. The enclosed plaint maybe
read as part and parcel of this affidavit.

1. I am the 1st Plaintiff in the above suit deponent here in. I am filing this
affidavit on behalf of another plaintiff also. I know the facts of the case,
defendant and also the suit Scheduled property. The enclosed plaint maybe
read as part and parcel of this affidavit.

2. I submit that the property mentioned in here under scheduled property,

here in after called as suit Scheduled property originally belongs to
Siddappa, during his life time siddappa developed the suit land and
cultivated the land basing upon his cultivation the then the thasildar issued
D.K.T Patta to him.

3. I further submit that after the death of Siddappa my husband named as

Krishnappa and his brother defendant here is enjoying jointly to scheduled
property and other properties stands in the name of siddappa without
division as meats and bounds. I submit that my Husband died in the year
1998, after death of my husband I along with daughter is cultivating the suit
scheduled property as per my respective share, Now the defendant trying
to alienate to suit scheduled property by obtain P.P.B & T.D. to the scheduled
property by colluding revenue authorities and creating sale deed stand to the
scheduled property to 2&3 respondents to knock way my share in the
scheduled property with right, title & possession as full extent.

Hence the above stated facts are true and correct to the best of my
knowledge, belief and information.
Deponent

Solemnly affirmed and signed before me on this day of 21st sep. 2014 at
Madanapalli
Advocate, Madanapalli

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant
ST
AFFIDAVIT FILED BY THE 1 PLAINTIFF

I Smt. E.Lakshmi Devi W/o Krishnappa aged 60 years,

Hindus,
Cultivation Residing at Gowdisanipalli Village, H/ o
Kothavaripalli, Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State., do here by solemnly affirmed and stated as
follows;
1. I am the 1st Plaintiff in the above suit deponent here in. I am filing this
affidavit on behalf of another plaintiff also. I know the facts of the case,
defendant and also the suit Scheduled property. The enclosed plaint maybe
read as part and parcel of this affidavit.

2. I submit that the property mentioned in here under scheduled property,

here in after called as suit Scheduled property originally belongs to
Siddappa, during his life time siddappa developed the suit land and
cultivated the land basing upon his cultivation the then the thasildar issued
D.K.T Patta to him and causing interference of my peaceful possession and
enjoyment of petition scheduled property.

3. I further submit that after the death of Siddappa my husband named as

Krishnappa and his brother defendant here is enjoying jointly to scheduled
property and other properties stands in the name of siddappa without
division as meats and bounds. I submit that my Husband died in the year
1998, after death of my husband I along with daughter is cultivating the suit
scheduled property as per my respective share, Now the defendant trying to
alienate to suit scheduled property by obtain P.P.B & T.D. to the scheduled
property by colluding revenue authorities and trying to execute sale deed to
the scheduled property to 2 & 3 respondents to knock way my share in the
scheduled property with right, title & possession as full extent.

4. I further submit that the respondents are trying to change the physical
features of the schedule property by taking the silt in the petition scheduled
property by destroying the tombs of siddappa and my husband.

Hence it is just and proper that this Honorable Court may be

pleased to restrain the defendant, their men and agents from in any way
interfering with our peaceful possession and enjoyment of us in the
petition Scheduled property by way of ad-interim injunction pending
disposal of the main suit. Otherwise we will suffer heavy loss and
hardship
Deponent
Solemnly affirmed and signed before me on this day of

Advocate,
IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT
MADANAPALLI

I.A.No: /2014
O.S. No: /2014
Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma Plaintiffs/ Petitioners
And
T.Eswaraiah . Defendant/ Respondents

PETITION FILED ON BEHALF OF THE PETITIONER/PLAINTIFF

UNDER ORDER 39 RULE 1 AND SECTION 151 OF C.P.C
 For the reasons stated in the enclosed affidavit it is prayed that this
Honorable Court may be pleased to restrain the respondents/defendants,
their men and agents from in any way interfering with Petitioners/Plaintiffs
peaceful possession and enjoyment by permanent Injunction in the
petition scheduled property by way of granting ad-interim injunction in
favour of petitioners, till pending disposal of the main suit. Otherwise they
will suffer heavy loss and hardship

Madanapalli
Dt: -10-2014. Advocate for Petitioners/Plaintiffs.

SCHEDULED

Chittoor Dist, Madanapalli Sub-Dist ,& Mandal, Kothavaripalli

Dakala, Gollapalli village mazara.

S.No:182/6, Dry an extent of 2.32 Cents DKT land

Bounded by East :Land of Reddivarpalli Peddappa South :

Indrabhavi West: Vanka North : Kalva

Advocate for plaintiffs

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI
O.S. No: /2014
Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant
ST
AFFIDAVIT FILED BY THE 1 PLAINTIFF
I Smt. E.Lakshmi Devi W/o Krishnappa aged 60 years,
Hindus,
Cultivation Residing at Gowdisanipalli Village, H/ o
Kothavaripalli, Dubbiganipalli Post Madanapalli Mandal,
Chittoor dist. A.P. State., do here by solemnly affirmed and stated as
follows;
1. I am the 1st Plaintiff in the above suit deponent here in. I am filing this
affidavit on behalf of another plaintiff also. I know the facts of the case,
defendant and also the suit Scheduled property. The enclosed plaint maybe
read as part and parcel of this affidavit.

2. I submit that the property mentioned in here under scheduled property,

here in after called as suit Scheduled property originally belongs to
Siddappa, during his life time siddappa developed the suit land and
cultivated the land basing upon his cultivation the then the thasildar issued
D.K.T Patta to him and causing interference of my peaceful possession and
enjoyment of petition scheduled property.

3. I further submit that after the death of Siddappa my husband named as

Krishnappa and his brother defendant here is enjoying jointly to scheduled
property and other properties stands in the name of siddappa without
division as meats and bounds. I submit that my Husband died in the year
1998, after death of my husband I along with daughter is cultivating the suit
scheduled property as per my respective share, Now the defendant trying to
alienate to suit scheduled property by obtain P.P.B & T.D. to the scheduled
property by colluding revenue authorities and the defendant is trying to
execute sale deed to the scheduled property to 2 & 3 respondents to
knock way my share in the scheduled property with right, title & possession
as full extent by alienating the schedule property and 4 th respondent is ready
to issue D.-form patt in the name of 2 & 3 respondents for shifting the silt in
the suit schedule property.

4. I further submit that the respondents are trying to change the physical
features of the schedule property by taking the silt in the petition scheduled
property by destroying the tombs of siddappa and my husband.

Hence it is just and proper that this Honorable Court may be

pleased to restrain the defendant, their men and agents from in any way
Not to alienating the petition Scheduled propertytill pending
disposal of the main suit. Otherwise we will suffer heavy loss and
hardship
Deponen
Solemnly affirmed and signed before me on this day of

Advocate,

IN THE COURT OF THE PRINCIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

I. A No: /2014
O.S.NO. /2014

Between

1.Smt. Lakshmi devi

2. Smt. Ramalakshmamma .Plaintiffs/petitioners

And
 1. Sri. Naga Raghunatha Reddy
2. Sri. Vasala Ramaiah
3. Sri Vasala Bala raju
4. The Thasilder Madanapalli Respondents/Defendants

PETITION FILED ON BEHALF OF THE PETITIONER/PLAINTIFF

UNDER ORDER 39 RULE 1 AND SECTION 151 OF C.P.C

For the reasons stated in the enclosed affidavit it is prayed that this
Honorable Court may be pleased to restrain the respondents/defendants,
their men and agents from in any way interfering with Petitioners/Plaintiffs
peaceful possession and enjoyment by declaring right and title in the
petition scheduled property by way of granting ad-interim injunction in
favour of petitioners, for not to alienate the petition scheduled property
till pending disposal of the main suit. Otherwise they will suffer heavy loss
and hardship

Punganur
Dt: 06-02-2014. Advocate for Petitioners/Plaintiffs.
SCHEDULED
Chittoor Dist, Madanapalli Sub-Dist ,& Mandal, Kothavaripalli
Dakala, Gollapalli village mazara.

S.No:182/6, Dry an extent of 2.32 Cents DKT land

Bounded by East :Land of Reddivarpalli Peddappa South :

Indrabhavi West: Vanka North : Kalva

IN THE COURT OF THE PRICIPLE JUNIOR CIVIL JUDGE AT

MADANAPALLI

O.S. No: /2014

Between
1.Smt. Lakshmi devi
2. Smt. Ramalakshmamma . ..Plaintiffs
And
T.Eswaraiah .Defendant

AFFIDAVIT OF THIRD PARTY

I,
, Chittoor District, do here by solemnly affirm and state on oath as follows:

1. I am third party in the above suit and deponent here in.

2. I know parties to the suit and the suit property as I am native of the
suit village.
3. I submit that the plaintiffs are the Share owners of the suit property
through her ancestors and they are in possession and enjoyment of the
same. The plaintiffs are in possession the suit land. Now I came to
Know that the defendant is trying to sell the suit scheduled property.
Hence this affidavit.
4. I swear and declare that the contents of my affidavit are true and
correct and nothing is concealed or misrepresented.

Deponent.

Solemnly affirmed and signed before me on this day of

Advocate, Punganur.