All Noticesses
All Noticesses
All Noticesses
3. It is to further inform you that my client reliably came to know that during the
pendency of the above suit, the 4 th defendant by name Thogurothu Guru Naidu s/o
late Somulu, who is younger brother of my client is approached your authority to
incorporate his name in all the revenue records in online system with regarding to
the above said landed properties with out having any exclusive right, title,
possession and enjoyment of the above said lands.
4. Therefore, I hereby request you not to issue or alter any revenue records in
favour of the above said Thogurothu Guru Naidu s/o late Somulu, of
Routhulapalem village, H/o Revidi, Padmanabham Mandal, with out conducting any
enquiry, in respect of the above said lands situated in survey Nos: 155/4, 153/26,
171/14, 171/11, 170/16, 155/11, 170/11 to an extents Ac. 0.36 cents, Ac.0.12
cents, Ac.0.64 cents, Ac. 0.25 cents, Ac. 0.53 cents, Ac. 0.31 cents, and Ac. 0.22
cents respectively of Routhulapalem Village, H/o Revidi village, Padmanabham
Mandal, else my client will take necessary steps in a court of law.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 11-12-2017.
To,
Sri. G. Tirupathi Rao,
Advocate, Door No: 25-07-11,
Dasannapata,
VIZIANAGARAM.
REGISTERED REPLY LAWYER’S NOTICE
1. Under instruction from my client Sri. Gottapu Srinivasa Rao S/o
Ramunaidu, Visalakshi Nagar, Visakhapatnam, I am giving you the reply notice to
your notice dated: 23-11-2017 issued on behalf of Shriram Chits pvt. Ltd., Branch
II, Jeeyar complex, Vizianagaram, as here under:-
2. The allegations made in your notice that my client joined as a subscriber in
your client’s chit fund company, in group and ticket no; VXZL-01/47(80001/47)
valuing of Rs: 10,00,000/- payable in monthly installments at the rate of Rs:
20,000/- for 50 months, and my client participated in the auction on 27-08-2013
and agreed to forgo of Rs: 4,00,000/- and my client finished sureties and they
executed an agreement of guarantee on 05-02-2014 in favour of your client and my
client and his guarantors executed on demand promissory note for the due amount
in favour client and committed default in payment of future subscriptions, and after
repeated demands made by your client my client did not pay the due amount and
my client filed a claim petition before the Honourable Deputy Registrar of Chits at
Vizianagaram in ACP No: 88/2015, and during the pendency of the said claim
petition my client approached your client and issued a cheque bearing No; 027827
for Rs; 6,02,880/- dated 23-10-2017 of Union Bank, Visakhapatnam, to your client
towards total due installment amount, and your client presented the said cheque in
AXIS Bank, Vizianagaram on 2610-2017 for collection and the same was returned
by my client’s bank as funds insufficient, and your client received the said memo
on 27-10-2017 and it seems that my client gave the cheque to your client with
dishonest intention and knowing fully well about insufficient amount in my client’s
bank account. Thus my client is bound to pay the aforesaid cheque amount and in
default, my client is libel for the criminal action shall be taken by your client for
the offence under section 138 &142 of N. I. Act, etc,. are all absolutely false and
invented by your client for the purpose of your notice.
3. My client states that in fact he joined as a subscriber in the chit conducted by
your client’s company after three months from commencement of the group in
ticket no; VXZL-01/47(80001/47) valuing of Rs: 10,00,000/- payable in monthly
installments at the rate of Rs: 20,000/- for 50 months, and participated in the
auction, but your client failed to pay the bid amount with in 6 months, due to late
payment my client went to some financial crises in his business, but my client had
paid monthly subscription regularly for the above chit and obtained receipts from
your client.
4. My client further state that he issued a cheque on 23-10-2017 for Rs;
6,02.880/- to your client towards due installments of the said chit is absolutely
false, and the said cheque might have obtained by your client from my client at the
time of payment of the bid amount of the said chit in the year 2014 towards
security of the future installments and that it may used by your client to get
wrongful gain himself to cause wrongful loss to my client, but my client did not
issued the said cheque on 23-10-2017.
5. Therefore please advise your client to send a Xerox copy of the alleged
cheque to my client so as to enable my client to send proper reply after going
through the same.
6. This is therefore advise your client not to embark on any useless and
vexatious litigation and in spite of this reply, if he proceeds further, it will be at his
own risk and peril and your client will also liable to pay the expenses to be
incurred by my client in defending the case.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 11-12-2017.
To,
SRI. SHAH JAHAN,
Advocate, City Civil & High Court,
Dream Park Complex, Arcadia 1 Flat 41-468,
South Kumrakhali, Sonarpur Stn Road,
KOLKATA - 7001103.
Under instruction from my client M/S SRI SAI SAREE CENTER, SHOP NO:
4, GANESH TETILE MARKET, CANTONMENT, VIZIANAGARAM-535003,
ANDHRA PRADESH. I am giving you the reply notice to your notice dated: 25-
11-2017 issued on behalf of your client M/S. RAJENDRA TEXTILES OF 24,
KALAKAR STREET, KOLKATA 700007, its partner SHRI SUBHASH CHAND
JAIN, as here under:-
2. The allegations made in your notice that your client is highly reputed
company and dealing in high quality Sarees, Lahenga and other ladies accessories.
Knowing good market reputation and my client approached to outlet of your client
a couple of years ago to buy some articles which your client sold to my client on
his assurance and representation and having good faith upon him towards the
payment of bills with in 39 days purchases under the term and conditions as agreed
and accepted by my client and your client and under such terms of payment with in
30 days from the date of purchase, my client had purchased some articles on credit
from your client under valid sales Bill/Invoices/ References, with the promises that
my client will make payments within 30 days of purchase as agreed and accepted
by my client, and on 23-11-2012 my client purchased articles from the outlet of
your client for the value of Rs: 42,000/- and after that day my client never
contracted your client nor made the payments against such purchase, and on 22-12-
2012 your client contracted my client, times and again and demanded for the
payment of Rs:42,000/- sometimes by sending their representatives at my client’s
place and sometimes by calling over phone but my client never did respond to your
client nor did make the payment of legal dues, and from my client activities, it
becomes axiomatic and his dishonest intention from very beginning to heress and
sheet your client, though your client helped my client by selling the articles on
credit of 30 days from the date of purchase, depending upon my client’s assurance
and reputation and that from the circumstances as well as my client’s non-payment
of dues proves my client’s bad, mollified and criminal intentions of cheating and
breach of trust, which your client was not aware of, and also my client is liable for
interest @ 18% per annum on the outstanding dues from 23-11-2012 to till
realization of the dues in full and final,. are all absolutely false and invented by
your client for the purpose of your notice.
3. My client state that in fact the entire transaction took place in the year 2012,
your client’s agents occasionally came to Vizianagaram and collected the said
amount during in the year 2012, thereafter no other transaction was done in
between your client and my client, and as such my client has not liable to pay any
amount to your client, and your client has invented false theory to get wrongful
gain for himself and to cause wrongful loss to my client by issuing the notice dt.
25-11-2017 through you with out any legal sanctity.
4. My client further states that he is doing his business since long back with
good reputation with out any remark, my client has stopped his business with your
client when the above transaction ends and due to that vengeance, your client
instructed you with all false and vague allegations and caused to issue the notice
dated 25-11-2017 to my client to get wrongful gain for himself and to cause
wrongful loss to my client.
5. This is therefore advise your client not to embark on any useless and
vexatious litigation and in spite of this reply, if he proceeds further, it will be at his
own risk and peril and your client will also be liable to pay the expenses to be
incurred by my client in defending the case.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 18-07-2018
To,
1. Sri. Siripurapu Mutyala Rao S/o late Appanna
R/o Korukonda Village, Vizianagaram Mandal/ district.
2. Sri. Upperla Venkata Satyannarayana S/o Venkanna,
R/o Plot No: 4, Sector-2, M.V.P. colony, Visakhapatnam.
3. Sri. Bolla Viswa Mohan S/o Ranga Rao,
R/o Door No: 2-1-48/1, Sreenagar, Kakinada town, East Godavari dist.
4. Therefore, I am hereby informing all of you that in spite of this notice, if you are enter in to
further transaction in respect of the notice schedule property basing on the sale deed dated 19-04-
2006 and sale agreement cum General Power of Attorney dated 06-01-2007 in favou of third
parties, all of you will be held liable for the legal consequences which may be taken up by my
clients in the court of law and also held liable for the costs and consequences thereof.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE
Vizianagaraam district, Vizianagaram West Sub Registration district, Vizianagaram Mandal,
Korukonda Village. Dry land situated in survey No; 213/12 to an extent of Ac. 0-68 cents of dry land.
A D V O C A T E,
1. Under the instructions from my clients 1 Smt. Kasireddi Pentamma W/o Demudu,
resident of Korukonda Village, Vizianagaram Mandal/district, 2. Smt. Gorle Atchayyamma w/o
Yernibabu, R/o Thatayyagari Veedhi, Jami Village/Mandal, Vizianagaram district, 3. Smt.
Edubilli Ramanamma w/o late Sivannarayana, R/o Alamanda Village, Jami Mandal,
Vizianagaram district. I issue the following notice to all of you as here under:-
2. The No: 1 of you and my clients are the children of Siripurapu Appanna through his wife
Siripurapu Bangaramma, The said Siripurapu Appanna succeeded the landed properties from his
ancestors both wet and dry lands situated at Korukonda Village of Vizianagaram Mandal, The
said Siripurapu Appanna died intestate at about 30 years back leaving behind him his wife and
children as his class-1 legal heirs and subsequently his wife Siripurapu Bangaramma also died
intestate at about 25 years back leaving behind her the No-1 of you and my clients are her class-1
legal heirs. After the death of the parents of the No: 1of you and my clients, the No; 1 of you
manage the joint family properties as a male member of the joint family. My client further states
that the notice schedule property along with other properties are in joint possession and
enjoyment of all the joint family members,( i,.e,. the No; 1 of you and my clients). Recently my
clients came to know that the No:1 of you is acting detrimental to the rights of my clients in the
joint family properties and without consent and knowledge of my clients the No: 1 of you have
executed a registered sale deed 06-05-2006 vide document No; 3731/2006 in favour of the No:2
of you and the No:2 of you also executed a sale agreement cum General Power of Attorney dated
09-01-2007 vide document No; 208/2007 in favour of the No:3 of you in respect of the notice
schedule property. My clients further states that they are having shares in the notice schedule
property along with the No:1 of you in the notice schedule property. As my clients are not the
parties to the sale deed executed by the No:1 of you in favour of the No:2 of you is not binding
on my clients and as such the rights of my clients are not be transferred to the No:2 & 3 of you to
the extent their shares in the notice schedule property. The No: 1 of you acting detrimental to the
interests of my clients in respect of notice schedule property. My clients further states that they
came to know yesterday, the No: 2 and 3 of you are going to execute further documents in favour
of the third parties in respect of the notice schedule property.
3. Therefore, I am hereby informing all of you that in spite of this notice, if you are enter in to
further transaction in respect of the notice schedule property basing on the sale deed dated 06-05-
2006 and sale agreement cum General Power of Attorney dated 09-01-2007 in favou of third
parties, all of you will be held liable for the legal consequences which may be taken up by my
clients in the court of law and also held liable for the costs and consequences thereof.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE
Vizianagaraam district, Vizianagaram West Sub Registration district, Vizianagaram Mandal,
Korukonda Village. Dry land situated in survey No; 211/12 to an extent of Ac. 0-39 cents of dry land.
A D V O C A T E,
1. Under the instructions from my client Sri. Bangari Anil Kumar, S/o Vijaya, R/o Plot
No: 24, Dandumaramma Colony, Cantonment, Vizianagaram town. I issue the following notice
as under.
2. You have represented before my client on 24-09-2016 that you are the absolute
owner of the notice schedule property and that you had purchased the said land from one
Yerubothu Umadevi of Narava Village by way of Registered sale agreement cum General
Power of Attorney dated: 07-05-2015 vide document No; 2543 / 2015 of West-Sub
Registrar office, Vizianagaram, in respect of the zerayothi wet land situated in survey Nos:
137/12 and 137/16 of Narava Village, Gantyada Mandal, Vizianagaram district, to an total
extent of Ac.0-26 cents, and you further represented before my client on the same day
i,.e,.24-09-2016, for your necessities and to develop other properties, you want to sell away
the notice schedule lands to my client and executed an agreement of sale on 24-09-2016 in
favour of my client agreeing to sell away the notice schedule land to an extent of Ac.0-26
cents consist of two items at the rate of Rs:30,000/- (Rupees thirty thousand only) per one
cent and the total consideration amount of Rs;7,80,000/-(Rupees seven lakhs and eighty
thousand only), out of the total sale consideration you have received Rs:7,50,000-00
(Rupees seven lakhs and fifty thousand only) from my client as an advance, and the
remaining balance of Rs: 30,000/- is to be payable by my client to you at the time of
registration of the said land and the time is fixed for registration is two months and after
registration you further agreed to deliver the possession of the land to my client, and you
further agreed to execute the register sale deed in favour of my client or his nominee at his
expenses.
3. My client has demanded you on so many occasions in the month of October and
November, 2016 for registration of the sale deed, but in vine. This is to inform you that my
client is always ready to perform his part of contract of agreement of sale dated 24-09-2016,
and in spite of my clients readiness, you have postponed the same on some pretext or the
other.
4. This is therefore demanding you to register the regular sale deed in favour of my client
or his nominee after receiving the balance of sale consideration and deliver the possession
thereof to my client with in fifteen days from the date of receipt of this notice, or else my
clients will be constrained to take appropriate legal action in the court of law for necessary
remedies, in which case you will be held liable for all costs and consequences thereof.
zanagaram.
Date:10-02-2017. ADVOCATE
NOTICE SCHEDULE
Vizianagaram district, Vizianagaram West Sub Registration district, wet land situated at
Narava Village, Gantyada Mandal, bearing the following survey numbers: 137/12 & 137/16
consist of two items, the total extent of Ac: 0-26 cents.
1) Item No:1 is situated in S.No: 137/12 to an extent of Ac.0-12 cents, bounded by:-
East:- Land of Yerubothu Ramulu
South:- Land of Bugatha Appalaswamy
West:- “ Gorja
North:- Land of Saradi Venkatappadu
1) Item No: 2 is situated in S.No: 137/16 to an extent of Ac.0-14 cents, bounded by:-
East:- Nakkala Gedda
South:- Wet land of Jami Badrayya
West:- “ Gorja
North:- Item No:1. ADVOCATE
2. On 18-09-2014 you have represented before my client that you have obtained an
agreement of sale in respect of the property from Sri. Golagani Venu and others, who purchased the
said property by way of registered sale deed dated 27-1-2010 vide document No; 155/2010 of Sub
Registrar’s office, Vizianagaram, from Katha rama Krishna Rao in respect of the vacant site bearing
plot No: 134, situated in Vasavi Nagar lay out L.P.No: 40 / 1997, and in survey No: 49 / 1 of
Karakavalsa Village, H/o Ramavaram Village, Gantyada Mandal, Vizianagaram district, to an extent
of 220 square yards measuring East to West 60 feet, North to South 33 feet and bounded by on 1)
East:- Plot No: 115 of vacant site, 2) South:- Plot No: 135 of vacant site, 3) West:- “40” feet lay out
road, and 4) North:- Plot No: 133 of vacant site, and you have further represented before my client
on the same day i,.e,.18-08-2014 that you are unable meet the amount to get the regular sale deed
from your vendor, and thereafter you want to sell away the afore said vacant site to my client at the
rate of Rs:1800/- per one square yard for which my client agreed to purchase the same and you
have executed an agreement of sale in respect of the above said vacant site on 18-08-2014 in
favour of my client agreeing to sell away the said site at the rate of Rs: 1800/- per square yard and
on the same day you have received an amount of Rs: 50,000/ as an advance from my client.
Thereafter you have received Rs;50,000/- on 23-8-2014, Rs:1,46,000/ on 27-09-2014 and Rs:
1,50,000/- on 25-11-2014 towards balance of total sale consideration from my client and endorsed
the same on the reveres side of the agreement of sale agreement and you have further agreed to
bring the original owner of the said site by name Golagani Venu and others to execute the register
sale deed in fovour of my client or his nominee, and in spite of my client readiness, you have
postponed the same on some pretext or the other.
3. Subsequent to the sale agreement dated 18-08-2014, in spite of repeated demands for
registration of regular sale deed, you have put deaf ear on all occasions and postponing the same on
some.
4. My client is always ready and willing to perform his part of contract.
5. This is therefore to give you this notice that unless you bring the original owner of the vacant
site by name Golagani Venu and others and get the sale deed registered in favour of my client or his
nominee with in a week from the date of receipt of this notice or else my client will be constrained to
take appropriate legal action agonist you in the court of law, in which case you will be held liable for
all costs and consequences thereof.
A D V O C A T E.
Laxmana Under
R/o the
Nandaminstructions
Village,of H/o
my client Sri. Village,
Narava SankranaGantyada
Mallu Naidu S/o
Mandal,
Vizianagaram district. I issue the following notice as under.
Thatyou
stating that you
areoffered to sell owner
the absolute the notice
of theschedule vacant site
notice schedule to my
site and theclient
said
site is purchased by you by way of Registered sale deed vide document No:
3593/2012 dated 13-09-2012 in respect of the vacant site plot No:18 Eastern
part, situated in Manibhushan Colony lay out in survey No: 118/2,3 of
Ramavaram Village, Gantyada Mandal, Vizianagaram district, to an extent of
200 square yards, bounded on 1) East:- Vacant site of others, 2) South:- plot
No:23, 3) West:- western part of the plot No;18, and 4) North:- lay out road,
and you have further represented before my client on the same day i,.e,.14-04-
2016 the said site is situated with in the boundary of the said lay out and also
you shown the said site to my client physically is a lay out bit plot no: 18, but
not eastern part of the plot No:18, which is cross bit and nearly 50 square
yards in the said site is not useful for construction of house.
This is oftherefore
agreement amount demanding
Rs: 1,00,000/- you towith
together return the there
interest said on
advance sale
@ of 24%
per annum from the date of the sale agreement with in a week from the date of
receipt of this notice or else my client will be constrained to take appropriate
legal action agonist you in the court of law for recovery of the said amount, in
which case you will be held liable for all costs and consequences thereof.
A D V O C A T E.
1. Under instructions from my client Sri. Hiralal Mishra S/o late Mangal Prasad
Mishra, resident of Door No: 6/12, Aravind Apartments, Near Santoshimatha
Temple, Mayuri Junction, Vizianagaram, I am giving you the registered notice to
you as here under:-
2. You have borrowed an amount of Rs: 2,00,000-00 (Rupees two lakhs only)
from my client on 05-02-2017, for the purpose of development of your properties
and in evidence thereof you have executed a demand promissory note for
Rs:2,00,000/- in favour of my client on the same day i,.e on 5-2-2017, agreeing to
repay the same on demand together with subsequent interest thereon @ 2 % p.m.
either to my client or to her order and in spite of repeated demands made by my
client for repayment of the amount due to him, you have issued a cheque for Rs:
2,00,000/-bearing No:660350, dated: 18-02-2018, drawn on State Bank of India,
Saluru Bazar Branch, towards part payment of the amount due on the above said
promissory note.
3. My client has presented the said cheque for collection in to his bank i,.e., the
Canara Bank, V.T.Agraharam Branch, Vizianagaram on 07-05-2018 and the same is
returned unpaid for the reason “EXCEEDS ARRANGEMENT” vide its memo
dated: 10-5-2018 and the same was served on my client on 11-05-2018 through his
banker. It appears that you are having knowledge about the consequences in case of
dishonor of cheque, and issued the above said cheque to my client only to deceive
my client and to avoid the payment. This is therefore demanding you for payment of
the returned cheque amount of Rs:2,00,000/- with in fifteen days from the date of
receipt of this notice to my client, failing which you would deemed to have
committed an offence punishable under section 138 &142 of N. I. Act.
4 This is therefore to give you this notice calling upon you to pay the
dishonored cheque amount within 15 days from the date of receipt of this notice,
failing which my client will be constrained to take appropriate legal action in the
court of law against you, in which case you will held liable for all costs and
consequences thereof.
Copy to: Smt. Anjali Gunnamma, W/o Rama Mohan Dora,
Working as Teacher in Girijan Vidhya Vikas School,
Kondalingalavalsa Village, Mentada Mandal, ADVOCATE
3. My client has presented the said cheque for collection in to her bank i,.e., the
Canara Bank, V.T.Agraharam Branch, Vizianagaram on 05-05-2018 and the same is
returned unpaid for the reason “FUNDS INSUFFICIENT” vide its memo dated: 08-
5-2018 and the same was served on my client on 14-05-2018 through her banker. It
appears that you are having knowledge about the consequences in case of dishonor
of cheque, and issued the above said cheque to my client only to deceive my client
and to avoid the payment. This is therefore demanding the No: 1 of for payment of
the returned cheque amount of Rs:9,84,000/- with in fifteen days from the date of
receipt of this notice to my client, failing which you would deemed to have
committed an offence punishable under section 138 &142 of N. I. Act.
4 This is therefore to give you this notice calling upon the No:1 of you to pay
the dishonored cheque amount within 15 days from the date of receipt of this notice,
failing which my client will be constrained to take appropriate legal action in the
court of law against the No: 1 of you, in which case you will held liable for all costs
and consequences thereof.
ADVOCATE
M. PRABHAKARA RAO Mobile No:9440762096
V. DEMUDU BABU Mobile No: 94402 37075,
ADVOCATE R/o H.No:218, M.I.G.11,Phase.111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
Date:- 22-06-2016.
TO,
1. Sri. Burra Syam Sunder S/o late Ramalinga Sastri
R/o Door No:2-186-1, F.F-3, Ramavarappadu Village,
Vijayawada, Krishna district.
2. Smt. Burra Aruna Laxmi W/o Syam Sunder
R/o Door No:2-186-1, F.F-3, Ramavarappadu Village,
Vijayawada, Krishna district.
ADVOCATE
V. DEMUDU BABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
===========================================================
Date:-06-03-2019.
T0,
1. Smt. Dontala Appayyamma W/o late Narasimhulu,
R/o Mahanti Veedhi, Kanapaka Vzianagaram.
2. Sri. Dontala Suresh Kumar s/o late Narasimhulu,
Rest: ---- do----
3. Smt. Majji Varalaxmi W/o Sadhu D/o late Narasimhulu,
Rest: ---- do----
4. Smt. Pathivada Ammalu D/o late Narasimhulu,
w/o Appalanarayana, rest --- do ---
5. Smt. Sunkari Meena D/o late Narasimhulu, w/o Ganesham
R/o Majji Veedhi, near Sunkara veedhi, Vzianagaram.
6. Smt. Bonthu Bujji D/o late Narasimhulu, w/o Ramu Naidu,
R/o Saibaba colony, Kanapaka Vzianagaram.
7. Sri. Dontala Ganesh Kumar s/o late Narasimhulu,
R/o Mahanti Veedhi, Kanapaka Vzianagaram.
8. Sri. Dontala Venkata Ramana s/o late Appala Naidu,
R/o Door No; 1/23-3-9, Golla Veedhi, Kanapaka Vzianagaram.
9. Sri. Dontala Srinivasa Rao S/o late Appala Naidu,
R/o Rest --- do ------.
10. Smt. Dontala Lakshmi w/o late Appala Naidu,
R/o Rest --- do ------.
2. My clients states that No: 1 of you is the wife and No: 2 to 7 of you are
the children of the deceased late Dontala Naresimulu, and No: 10 of you
is the wife and the No; 8 & 9 of you are sons of late Dontala Appala
Naidu, It is further states that during the life time of the said Dontala
Narasimhulu and his son Dontala Suresh Kumar and the No: 8 & 9 of you
who are sons of late Dontala Appala Naidu have sold away the notice
schedule land to my client under two registered sale deeds dated 13-
10-2003 and 03-04-2004 for total valid consideration of Rs: 1,02,000/-
and at the time of registration of two sale deeds the notice schedule
property was delivered possession to my client and thereafter, after
getting the possession of the said property my client formed a lay-out in
the notice schedule property and in some other landed property in the
name and style of “ SAI KEERTHANA NAGAR” and divided in to various
plots and sold away all the plots to third parties by way registered
documents and delivered possession of the respective plots to the
respective purchasers and some of the purchasers have built residential
buildings in those plots.
3. It is further submit that one Kandi Ram babu who is a sister’s son of
Dontala Narasimhulu ( who is the husband of No: 1 of you and the father
of No: 2 to 7 of you) and one Dontal Appala Naidu (who is the father of
No; 8 and 9 of you and husband of No; 10 of you) has filed a suit in O.S.
255/2008 on the file of the Prl. Junior Civil Judge’s court at
Vizianagaram against Dontala Narasimhulu and 11 others, in which all
of you have been showned as defendants, for partition of the notice
schedule property and in which all of you have been set ex pate and my
client is the only contesting party and after getting trail the suit is
decreed with costs on 13-09-2017 granting 1/3 rd share in the schedule
property to the plaintiff. It is also further informed that the No; 8 of you
have also appeared before the court and gave evidence in favour of the
plaintiff. Hence all the defendants except my client have been set ex
parte in the said suit hence it appears that all of you sailed with the
plaintiff and put my client in to loss. Therefore all of you are liable to
pay the value of the 1/3rd share in the notice schedule property to my
client in case if the plaintiff in O.S 255/2008 by name Kandi rambabu
succeeds in getting possession of the 1/3rd share in the notice schedule
property and further all of you are also liable to face criminal case under
section 420 of IPC
4. It is also further inform that my client has preferred an Appeal No:
17/2018 on the file of the Honourable District Judge at Vizianagaram
against the decree and judgment in O.S 255/2008 dated 13-09-2017
against said Kandi Rambabu and all of you and the same is pending.
5. This is therefore to give you this notice to pay the market value of the
1/3rd share in the notice schedule property which comes to Rs:
55,00,000/- approximately along with damages to my client within a
week from the date of receipt of this notice or else my client will be
constrained to take appropriate legal action in the court of law for the
reliefs under both civil and criminal in nature, in which case all of you
will be held liable for all costs and consequences thereof.
A D V O C A T E.
NOTICE SCHEDULE
Vizianagaraam District, Vizianagaram Sub-Registration district,
Vizianagaram Mandal, K. L Puram Village, wet land situated in K. L Puram
Village to an total extent of Ac. 0-86 cents-
S.No: Survey Nos: Extent of Land:
1. 159/1 Ac. 0-11 cents
2. 159/5 Ac. 0-17 cents
3. 153/16 Ac. 0-04 cents
4. 153/17 Ac. 0-04 cents
5. 153/19 Ac. 0-02 cents
6. 149/8 Ac. 0-04 cents
7. 149/9 Ac. 0-04 cents
8. 149/15 Ac. 0-04 cents
9. 149/16 Ac. 0-18 cents
10. 153/13 Ac. 0-04 cents
A D V O C A T E,
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 11-12-2017.
To,
Sri. G. Tirupathi Rao,
Advocate, Door No: 25-07-11,
Dasannapata,
VIZIANAGARAM.
5. Therefore please advise your client to send a Xerox copy of the alleged
account copy of their business to my client so as to enable my client to send proper
reply after going through the same.
6. This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 11-12-2017.
To,
SRI. SHAH JAHAN,
Advocate, City Civil & High Court,
Dream Park Complex, Arcadia 1 Flat 41-468,
South Kumrakhali, Sonarpur Stn Road,
KOLKATA - 7001103.
1. Under instruction from my client M/S SRI SAI SAREE CENTER, SHOP
NO: 4, GANESH TETILE MARKET, CANTONMENT, VIZIANAGARAM-
535003, ANDHRA PRADESH. I am giving you the reply notice to your notice
dated: 25-11-2017 issued on behalf of your client M/S. RAJENDRA TEXTILES
OF 24, KALAKAR STREET, KOLKATA 700007, its partner SHRI SUBHASH
CHAND JAIN, as here under:-
2. The allegations made in your notice that your client is highly reputed
company and dealing in high qulity sarees, Lahenga and other ladies accessories.
Knowing good market reputation and my client approached to outlet of your client
a couple of years ago to buy some articales which your client sold to my client on
his assurance and representation and having good faith upon him towards the
payment of bills with in 39 days purchases under the term and conditions as agreed
and accepted by my client and your client and under such terms of payment with in
30 days from the date of purchase, my client had purchased some articales on
credit from your client under valied sales Bill/Invoices/ Referances, with the
promises that my client will make payments within 30 days of purchase as agreed
and accepted by my client, and on 23-11-2012 my client purchased articales from
the outlet of your client for the value of Rs: 42,000/- and after that day my client
never contracted your client nor made the payments against such purchase, and on
22-12-2012 your client contracted my client, times and agin and demanded for the
payment of Rs:42,000/- sometimes by sending their representatives at my client’s
place and sometimes by calling over phone but my client never did respond to your
client nor did make the payment of legal dues, and from my client activities, it
becomes axomatic and his dishonest intention from very beginning to heress and
sheet your client, though your client helped my client by selling the articales on
credit of 30 days from the date of purchase, depending upon my client’s assurance
and reputation and that from the cercumatamces as well as my client’s non-
payment of dues proves my client’s bad, malifide and criminal intentions of
cheating and breach of trust, which your client was not aware of, and also my
client is liable for interest @ 18% per annum on the outstanding dues from 23-11-
2012 to till realization fo the dues in full and final,. are all absolutely false and
invented by your client for the purpose of your notice.
3. My client state that infact the entire transaction took place in the year 2012,
your client’s agents regularly came to Vizianagaram and collected the said
amounts with in the time in the year 2012, thereafter no other transaction was done
in between your client and my client, as such my client has no dues to your client,
after long laps of 5 years your client lay false theary to get wrongful gain himself
and to cause wrongloss to my client by issung this notice through you with out any
legal valiedity.
4. My client further state that doing his business since long back in good
reputation with our any remark in Vizianagaram, my client was stopped his
business to your client due to reason best known to your client, due to that gladge,
your client instructed to you with all false and vauge allegations on my client to get
wrongful gain himself and to cause wrongloss to my client by issung this notice
through you with out any legal validty.
5. This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
Date:- 11-06-2019
To,
Sri. Bogi Ramana,
S/o Satyam,
R/o Gunkalam Village,
Vizianagaram Mandal/Town.
REGISTERED LAWYER`S NOTICE
1. Under instructions from my client Sri. Adireddi Ravi Kumar S/o Surya Rao
resident of Madupada Village, Gantyada Mandal, Vizianagaram district. I issue the
following notice as here under-
2. My client states that you are doing construction works business and that
during the course of your business you are approached my client agreed to
construct R.C.C Slabbed house (G+1) in a vacant site situated in survey No;
158/19 part to an extent of 200 square yards in Sri Sai Lalitha Nagar, Phase-III lay-
out of K.L Puram Village, of Vizianagaram Municipality and you are also stating
that the said site is purchased by you from one Allu Atchim Naidu and it has been
in your possession and enjoyment of the same.
3. My client further states that you are approached my client and stating that
now your are ready to starting construction of RCC house (G+1) in afore said
vacant site and you are also engineered my clint to agreed to purchase the said
RCC ground floor house in the said building at the rate of total sale consideration
of RS: 35,00,000/- (Rupees Thirty five lakhs only) and out of which you have
received an amount of Rs:5,00,000/- (Rupees five lakhs only) from my client
towards advance of sale consideration on 02-03-2017 you have executed an
agreement of sale in favour my client in respect of the Ground floor house, as per
the term and conditions of the said agreement my client have agreed to pay the
balance amount of Rs: 30,00,000/- at the time of registration of the regular sale
deed to the said RCC Ground floor house, subsequently my client surpriseingly
came to know that you are not yet started any construction work on the said site
and you are also failed to purchased the said site from your vendee as atated in the
agreement of sale 02-03-2017 and you are also violated the terms and conditions of
the said agreement of sale dated 02-03-2017, subsecquently on so many occasions
my client demanded you to repay the said advance amount to him, but you are
repaid only Rs: 4,50,000/- and the remaining balance of Rs: 50,000/- is liable to be
repay to my client, for which, inspite repeeted demands made by my client you are
postponing the same on one prtext or the other,
E. ESWARA RAO Mobile No: 94402 37075,
V. DEMUDU BABU R/o H.No:218, M.I.G. 11, Phase. 111.
ADVICATES VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 06-05-2019
To,
Sri. Sunkara Suri Krishna,
S/o late Pedappanna
R/o Krishnapuram Village,
Padmanabham Mandal,
Visakhapatnam district.
1. Under instructions from my client Sri. Sunkara Ramu S/o late Pedappanna, resident of
Krishnapuram village, Padmanabham Mandal, Visakhapatnam district, I issue the following
notice to you as here under:-
3. That my client states that you and my clients are brothers and sons of Sunkara late
Pedappanna of Krishnapuram village, Padmanabham Mandal, Visakhapatnam District, you, your
father and my client are constituted a Hindu joint family members of Mithakshra school of law.
The said joint family possessed some properties in Krishnapuram village, the said joint family
properties are ancestral properties, the notice schedule lands are self acquired properties of
the father of you and my client and the notice schedule house is the ancestral property and all
the joint family members are have been enjoying the said house property.
4. My client further states that during the life time of the father of you and my client, all
the ancestral joint family properties were partitioned in between you and my client keeping the
self acquired landed properties and also joint family house property, I,.e,. notice schedule
properties which are spent for maintenance of the father of you and my client and he had been
enjoyed the said properties till his death, After his death the notice schedule properties are
devolved on you and my client and both of you are enjoying the same, being eldest person in
the family you have looking after the notice schedule properties and sharing the produce
between you and my client.
5. While so, recently due to hike in the value of the lands, you have developed an evil idea
to grab the legitimate share of my client in the notice schedule properties and making attempts
to alienate the notice schedule lands to some third parties without knowledge of my client. My
client comes to conclusion that it is not safe to my client to keep the notice schedule properties
in joint with you.
6. My client demanded you to partition the notice schedule properties in to two equal
shares and put my client in physical possession of the same, but you gave evasive replies and
asked my client to report whomsoever his likes.
6. Therefore, you are hereby called upon to partition the schedule mentioned properties in to
two equal shares and to allot one such share to my client within a week from the date of
receipt of this notice, failing which my client will be constrained to take appropriate legal action
in the court of law and in which case you will be held liable for all costs and consequences
thereof.
A D V O C A T E.
SCHEDULE
1. Item No: 1:- S. No: 41 in an extent of Ac: 0-13 cents of dry land known as
Manem Guddi, Bounded by:-
2. Item No: 2:- S. No: 100 in an extent of Ac: 0-15 cents of wet land
Bounded by:-
3. Item No: 3:- Slabbed house situated at near Sadhumatam in Krishnapuram village,
Padmanabham Mandal, Visakhapatnam district.
Bounded by:-
A D V O C A T E.
B. NARASIMHA MURTHY, B.Com B.L, Mobile No: 94408 91511,
ADVOCATE R/o D.No: 8-32-228/A,
KOTHA MAJJIPETA,
V. T. AGRAHARAM,
VIZIANAGARAM - 535 003,
--------------------------------------------------------------------------------------------
Date:- 05-03-2019
To,
1. THE MANGER,
State Bank of Indaia,
Centralised Pension Proceedings Center,
1st Floor, Scab Building,
S.B.I- L.H.O. Compound, KOTI,
Hyderabad- 500 095.
2. The Secretary,
Office of the Banking Ambudsman,
Reserve Bank of India,
Hyderabad.
5 This is therefore request the No; 3 of you to pay the amount of Rs:
39,300/- along with D.A. arrears together with reasonable interest thereon to
my client within a week from the date of receipt of this notice or else my
client will be constrained to take appropriate legal action in the court of law
in which case you will be held liable for costs and consequences thereof.
ADVOCATE.
ENCLOSURES:
1. Xerox copy of proceedings dated 23-11-2010 of No: 1of you along with
copy Annexure-I.
2. Xerox copy statement of account pertaining to my client in respect of his
account maintained by No:3 of you.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 24-01-2019
To,
1. Sri. Kandi Sanyasi naidu S/o late Pothu Naidu
R/o Akkivaram Village, Denkada Mandal, Vizianagaram district.
2. Sri. Kandi Ramu Naidu S/o late Pothu Naidu
R/o Akkivaram Village, Denkada Mandal, Vizianagaram district.
3. Sri. Kandi Thatu Naidu S/o Sanyasi Naidu,
R/o Akkivaram Village, Denkada Mandal, Vizianagaram district.
4. Sri. Gorle Sreeramulu S/o Appanna
R/o Akkivaram Village, Denkada Mandal, Vizianagaram district.
3. That during the life time of the said late Kandi Pothu Naidu being the
Karta of the joint family he used to manage the properties till his death on
behalf of all the family members of the joint family. After the death of said
Kandi Pothu Naidu, No: 1 of you being the senior male member in the joint
family is managing the entire properties on behalf of all the members in the
joint family. After the death of Kandi Pothu Naidu all the properties are in
joint possession and enjoyment of all the family members including my
clients. In the recent times my client came to know that the No: 1 to 3 of you
sold away the notice schedule property to the No: 4 of you without knowledge
of my clients and now the No: 4 of you started construction in the notice
schedule property without having absolute right over notice schedule
property. It is informed that the rights of my clients in the notice schedule
property cannot be transferred to No: 4 of you by virtue of the sale deed said
to have been executed No: 1 to 3 of you in favour of No: 4 of you. It is also
further informed that the No: 1 to 3 of you have no absolute rights in the
notice schedule property as it the joint family property in which my clients are
also having their right along with the NO: 1 to 3 of you and it is further
informed that the No: 4 of you cannot have absolute right in the notice
schedule property by virtue of sale deed obtained from the No; 1 to 3 of you
and as such the No; 4 cannot make any structure in the notice schedule
property ignoring the rights of my clients.
4. This is therefore to give you this notice to the No: 4 of you not to make
any construction in the notice schedule mentioned property and if you
proceeds further, it will be leads to further litigation and it will be not bind in
any way on the rights of my clients in the notice schedule property and you
will be also be liable to pay the costs of my clients in defending the rights of
my clients in the notice schedule property.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if
necessary.
NOTICE SCHEDULE
ADVOCATE
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
=======================================================
Date:- 26-03-2019.
To,
Sri. M.V.S.N.B. PRAVEEN KUMAR,
Advocate,
DOOR. No: 4-10-1, Anitha Nivas,
Dakkina Street, VIZIANAGARAM.
4. My client states that she has purchased the notice schedule property
by way of registered sale deed for a valuable consideration after verifying all
records concern and since the date purchase she has been in possession and
enjoyment of the same without interruption from anybody including her
vendors and the revenue authorities also recognized her title and possession
issued pattadhar passbook, title deed books in her favour and my client
further states that at the time of enter in to an agreement of sale all the above
said facts are brought in to notice of your client and on physical and
documentary verification made by your client and she has entered in to an
agreement of sale on 30-08-2016.
5. My client further states that she has agreed to sell the notice schedule
property for the purpose of her daughter’s marriage, for which, the time is
fixed for three months for registration of regular sale deed, but your client
failed to perform her part of contact within stipulated time being mentioned
the sale agreement. So my client borrowed huge amounts from third parties
on high rate of interest at that time, my client further informing you that when
your client is not abide by the terms of the sale agreement dated 30-08-2016
and when they are not abide to arrange the balance of total sale consideration
within the stipulated period of 3 months and when my client's purpose is not
served in selling the schedule property to your client under the agreement
dated 30-03-2016, thereby my client put to heavy loss, and all these things
were happened because of the conduct of your client. The above facts clearly
shows that your client is not ready to perform her part of contract with in the
stipulated time and thereby your client is violated the terms of the agreement
dated 30-08-2016 and further when your client is not performed her part of
contract under an agreement and under the above stated circumstances your
client can not asked refund of advance amount without seeking relief for
specific performance on the agreement of sale dated 30-08-2016 against my
client. It is to inform you that at the time of her daughters marriage my client
has insisted and requested your client to pay the balance of total sale
consideration and to get the registered sale deed in her favour or her
nominee, but in all occasions your client was not get ready and under the
above stated circumstances your client is not entitled for refund of the
advance amount under the sale agreement dated 30-08-2016.
6. My client further states that since the date of sale agreement she has
always time expressed her readiness and willingness to perform her part of
contract along with required documents, but your client never get ready to get
regular sale deed on the agreement of sale dated 30-08-2016, now itself my
client is ready and willing to perform her part of contract to execute the
registered sale deed in favour of your client or her nominee.
7. This is therefore advise your client not to lay false claims against my
client for asking refund of amount without seeking specific performance
under an agreement of sale dated 30-08-2016, for which your client is not
entitled, in case if she proceeds further, it will be at her own risk at peril and
further your client is liable to pay the costs that may be incurred by my client
in defending the case filed by your client.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
============================================
Date:-09-05-2019.
To,
Sri. CH. RAM BABU,
Advocate,
Flat-1, Floor No: 1, Daspalla Towers,,
Pandimetta Junction, Maharanipeta,
VISAKHAPATNAM-530 002.
REGISTERED REPLY NOTICE
1. Under instruction from my client Sri. S. P. Siva Rama Krishna, S/o
Satyannarayana, P.W.D Colony, Thatipudi Village, S. Kota Mandal,
Vizianagaram district, I am giving you the reply notice to your notice dated
10-04-2019 issued on behalf of Shri Syyad Shafi S/o S. A. Rajak, resident of
Visakhapatnam, as follows:-
2. It is not correct to state that my client in acquaintance with your client and
he requested your client to lend money and thus he took a sum of Rs:
1,20,000/- on 09-07-2016 for meeting his family expenses and discharged his
earlier loans obtained by my client and at the time of receiving the said sum,
executed on stamp bond evidencing the said transaction and promised to
repay the same to your client along with interest thereon at Rs.24% per
annum and when your client demanded my client to repay the same along
with interest, my client postponing its repayment on one pretext or the other
taking advantage of your client’s goodness are all invented for the purpose of
this notice.
3. It is to inform you that your client and my clients are room meets at
Hyderabad, during the year 2010 to 2014 when my client worked at
Hyderabad in Leman Videos, Add Agency, on demand of the said agency for
security purpose my client prepared two stamp Bond papers duly signed by
my client and one stamp paper was give to the said Add agency and another
stamp paper is kept in the room at Hyderabad, when my client vacated the
said room the remaining stamp paper was not traced, now my client
remembered that stamp paper was kept with your client and now your client
may fabricate the said demand note with the help of henchmen and got issued
this notice through you to get wrongful gain your client and to cause wrongful
loss to my client. My client further states that he never borrowed any amount
from your client and never executed any document on stamp bond in favour
of your client, as such my client is not liable to pay any amount as demanded
in your notice.
4. Therefore please advise your client to send a Xerox copy of the alleged
stamp bond to my client so as to enabling my client to send proper reply after
going through the same.
5. This is therefore request you to advise your client not to embark on
any useless and vexatious litigation and in spite of this reply, if he proceeds
further, it will be at his own risk and peril and your client will also liable to
pay the expenses to be incurred by my client in defending the case to be filed
by your client.
A D V O C A T E.
5. As per Law my clients are entitled to get half share in the schedule mentioned
properties as they are class -1 legal heirs of late Kondapalli Kanchamma who was
the 1st daughter of the said Kalisetti Sanyasappadu, therefore all the notice schedule
properties are liable for partition.
7. Therefore all of you are hereby called upon to partition the schedule
mentioned properties in to two equal shares and to allot half share to my clients
within a week from the date of receipt of this notice, failing which my clients will
be constrained to take appropriate legal action in the court of law and in which
case all of you will be held liable for all the costs and consequences thereof.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if
necessary.
NOTICE SCHEDULE
Vizianagaram district, Gajapathinagaram Sub Registration district, both dry and wet
land situated at Amativalsa Village, Bondapalli Mandal, to an total extent of Ac: 1-50 cents.
And house property:-
4. Item No: 1:- S. No: 2/1 in an extent of Ac: 1-16 cents of dry land known as
Lankavani Guddi Bounded by:-
East: Dry land of Paluri Appala Naidu
South: Dry land of Vankara Appa Rao
West: Dry land of Yandrapu Papala
North: Dry land of Kalisetti Suryanarayana,
5. Item No: 2:- S. No: 29/35 in an extent of Ac: 0-15 cents of wet land known as
Padupumadi, Bounded by:-
East: Wet land of Kalisetti Papa Rao,
South: Wet land of Kalisetti Laxmi,
West: Wet land of Kalisetti Suryanarayana,
North: Pedda Cheruvu,
6. Item No: 3:- S. No: 30/2 in an extent of Ac: 0-06 cents of wet land known as
Aaku madi, Bounded by:-
East: Wet land of N. Atchanna,
South: Wet land of Bali Satyannarayana,
West: Wet land of Bali Satyannarayana,
North: Wet land of Paluru Laxmi,
7. Item No: 4:- S. Vacant site known as Kallam to an extent of Ac: 0-14 cents
Bounded by:-
East: Gedda, Water Channel,
South: Gedda, Water Channel,
West: Thrashing floor of Paluri Ramana,
North: Vacant site of Seereddi Demudu,
8. Item No: 5 Slabbed house bearing Door No: 2-99 is situated at Ambativalsa village,
Bondapalli Mandal, Vizianagaram district.
Bounded by:-
East: Slabbed house of Kalisetti Surappadu,,
South: C. C. Road,
West: Vacant site of Routhu Pydi Naidu,
North: Slabbed house of Sirapurapu Appanna,
A D V O C A T E.
2. The allegations made in notice pera Nos: 2 to 5 are not known to my client
and they are absolutely false and invented by your client for the purpose of your
notice.
4. This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case.
A D V O C A T E.
B. NARASIMHA MURTHY, B.Com B.L, Mobile No: 94408 91511,
ADVOCATE R/o D.No: 8-32-228/A,
KOTHA MAJJIPETA,
V. T. AGRAHARAM,
VIZIANAGARAM - 535 003,
Date:- 10-02-2020
T0,
Sri. Bantupalli Parameswara Rao,
S/o Appala Naidu,
R/o B. Thallavalasa Village,
Padmanabham Mandal,
Visakhapatnam district.
1. Under instructions from my client Sri. Pasala Gangu Naidu S/o late
Demudu, resident of V. T Agraharam, Vizianagaram, I am giving you the
registered notice as here under.
4. You are therefore hereby called upon to pay the said amount due under the
above said promissory note to my client within a week from the date of receipt of
this notice, failing which my client will be constrained to file a suit against you for
recovery of the same, in which case you will be held liable for all costs and
consequences thereof.
Vizanagaram,
Date: 10-02-2020 ADVOCATE
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 10-02-2020.
T0,
Sri. Chukka Surya Rao
S/o late Pydi Naidu,
R/o Ganesh Nagar,
V. T. Agraharam,
VIZIANAGARAM.
4. You are therefore hereby called upon to pay the balance amount due under
the above said promissory note to my client within a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the same, in which case you will be held liable for all costs and
consequences thereof.
Vizanagaram,
Date: 10-02-2020. ADVOCATE
1. Under instructions from my client Sri. Duddipudi Veera Venkata Achari S/o
late Rama Rao, resident of Mokalapadu Village, Gantyada Mandal, Vizianagaram
district, I issue the following notice as under.
3. Subsequently the said Kotyada Govinda who is the 1 st executent of the said
promissory note was died in the year 2018 leaving behind him the 1 st of you as his
class-1 legal heir for his entire estate and during the life time of the said Kotyada
Govinda, my client demanded him and the No; 2 of you for repayment of the said
promissory note, but the husband of the No:1 of you and 2 nd of you are not repay
the said amount either towards principal or interest due to my client and
postponing the same on some pretext or the other, after death of Kotyada Govinda
my client demanded both of you through village elders for repayment of the said
amount due under the above said promissory note, but both of you are promised to
settle the matter before the village elders, but till today they have not chose to
repay the said amount either towards principal or interest due to my client and
postponing the same on some pretext or the other. My client further states that the
No: 1 of you is liable to pay the said amount from the estate of the deceased
Kotyada Govinda as his legal heirs and the No: 2 of you personally liable to pay
the said amount with subsequent interest and costs.
4. This is therefore all of you are hereby called upon to pay the said amount
due under the above said promissory notes to my client within a week from the
date of receipt of this notice, failing which my client will be constrained to file a
suit against all of you for recovery of the same, in which case you will be held
liable for all costs and consequences thereof.
ADVOCATE
AFFIDAVIT
It is submit that we and Siriki Thrinadha Rao s/o late Sanyasi Naidu, are the
owners of the landed property situated in survey No; 65/3 to an extent of Ac. 0-59 cents of
dry land of Karakavalsa village H/o Ramavaram panchayet of Gantyada Mandal
Vizianagaram district. We purchased the above said land from 1. Sri. Manchukonda Peda
Venkata Rayulu, 2. Manchukonda Venkata Sattayya, 3. Manchukonda Venkata Ramana
of Kodivarigalli Veedhi, Vizianagaram town, by way of registered agreement of sale- cum-
General Power of Attorney document No: 2263/2017 dated 14-06-2017, since then we have
been in possession and enjoyment of the said Now we applied for land conversion from
agricultural land in to non agricultural land in the name of Siriki Thrinadha Rao s/o late
Sanyasi Naidu before the Revenue Authorities, for which we have no objection to issue land
conversion from agricultural land in to non agricultural land and we will not raise any
objection or problem before the Revenue Authorities.
The above said facts are true and correct. Hence this affidavit.
DEPONENTS
AFFIDAVIT
I Siriki Thrinadha Rao s/o late Sanyasi Naidu, Hindu, age 46 years, 2. Smt. Korupolu
Yerni Naga Krishna Mutyamamma, Hindu, age 42 years, resident of Kanapaka,
Vaizianagaram town, 3. Siriki Rama Rao s/o late Sanyasi Naidu, Hindu age 56 years, R.
Vasantha village, Gantyada Mandal, Vizianagaram district, 4. Smt. Sunkara Ramanamma
w/o Pentam Naidu, Hindu, age 40 years, Narava village, Gantyada Mandal, Vizianagaram
district, do hereby solemnly affirm state on oath as follows:-
We all above named persons have purchased the landed property situated in survey
No; 65/3 to an extent of Ac. 0-59 cents of dry land of Karakavalsa village H/o Ramavaram
panchayet of Gantyada Mandal, from 1. Sri. Manchukonda Peda Venkata Rayulu, 2.
Manchukonda Venkata Sattayya, 3. Manchukonda Venkata Ramana of Kodivarigalli
Veedhi, Vizianagaram town, by way of registered agreement of sale- cum- General Power
of Attorney on 14-06-2017, since then we have been in possession and enjoyment of the said
lend, now we want to convert the said agricultural land in to residential area, for which we
have applied for the conversion before the concern Revenue Authorities. The above
particulars are true to the best our knowledge and belief. Hence this affidavit.
DEPONENTS
th
Solemnly affirmed before me on this 20 day of November, 2018, at Vizianagaram.
M. PRABHAKARA RAO Mobile No:9440762096
V. DEMUDU BABU Mobile No: 94402 37075,
ADVOCATE R/o H.No:218, M.I.G.11,Phase.111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
Date:- 22-06-2016.
TO,
1. Sri. Burra Syam Sunder
S/o late Ramalinga Sastri
R/o Door No:2-186-1, F.F-3,
Ramavarappadu Village,
Vijayawada, Krishna district.
2. Smt. Burra Aruna Laxmi
W/o Syam Sunder
R/o Door No:2-186-1, F.F-3,
Ramavarappadu Village,
Vijayawada, Krishna district.
REGISTRED LAWYER’S NOTICE
1. Under the instructions from my client Sri. Pathivada Sandeep Naidu S/o Appalanarayana,
R/o Akulapeta Village, Denkada Mandal, Vizianagaram district. we issue the following notice as
here under.
2. For your necessities both of you are executed an agreement of sale on 23-08-2018 in
favour of my client agreeing to sell away the notice schedule dry land to an extent of Ac.0-30
cents at the rate of Rs:3,00,000/- (Rupees three lakhs only) per one cent, which is purchased by
both you on 30-09-2010 from Smt. Pentakoti Ammajamma @ Goggi Radhamma, by virtue of a
registered sale deed vide document No; 3284 / 2010, situated in survey No; 11 / 1(P) of
Boddavalsa Village and out of the total sale consideration both of you have received Rs:
20,00,000-00 (Rupees twenty lakhs only) from my client as an advance on the date of sale
agreement dated 23-08-20018 and both of you further agreed to register the regular sale deed
within three months after receiving the balance of sale consideration at the time of registration
of the regular sale deed at his expenses and also to deliver the possession of the said land to my
clients.
3. Subsequent to the sale agreement my client has expressed his readiness before both of
you to perform his part contract after securing the required amount for paying balance of sale
consideration and registration expenses, but both of you have postponed the same on some
pretext or the other. Even last month also my client is requested you on so many occasions
before elders to come and register the sale deed in his favour to the actual extent thus found
on ground, but you have postponed the matter for the reason best known to you.
4. My client further states that he reliably came to know that out of the total extent of Ac.
0-30 cents, the Government acquired to an extent of Ac.0-04 cents from you for the purpose of
extension of N.H-43 road.
5. This is therefore demanding both of you to register the regular sale deed in favour of my
clients to the actual extent thus found on ground after surveying the notice schedule land and
deliver the possession thereof to my client after receiving the balance of sale consideration with
in fifteen days from the date of receipt of this notice, or else my clients will be constrained to
take appropriate legal action in the court of law for necessary remedies, in which case you will
be held liable for all costs and consequences thereof.
Vizanagaram,
Date: 19-11-2018. ADVOCATE
NOTICE SCHEDULE
Vizianagaram district, Bhogapuram Sub Registration district, dry land situated at Boddavalsa
Village, Denkada Mandal, bearing survey no: 11/1 (P) to an extent of Ac: 0-30 cents.
ADVOCATE
Under the instruction of the client Smt. Challa Srinamma w/o Jogi Naidu
R/o B. Rajeru Village, Bondapalli Mandal, Vizianagaram district. I issue the
following notice as under:-
My client filed a suit against you and your mother by name Smt. Kilaparthi
Simhachalem w/o late Satyam, for recovery of the amount due under the suit
promissory note, i.e., O.S NO: 87/2016 on the file of the Honorable Junior Civil
judge’s court at Gajapathinagaram, the said suit was decreed on 21-06-2018, as per
the decree you and your mother has to pay an amount of Rs.1,44,525/- together
with subsequent interest at @ 12% P.A from the date of the suit till decree and
subsequent interest at @ 6% P.A from the date of the decree till realization on
principal amount of Rs: 94,000/- and also payable an amount of Rs:9,871/- towards
costs of the suit. My client further states that she filed an I A 255/2016 along with
the suit under order 38 rule 5 C.P.C. for attachment of the petition schedule lands
and in the said application attachment was ordered and the same was made
absolute on 15-02-2017, but after passing of the decree my client came to know
that both of your are sold away the petition schedule lands prior to filing of the said
application, hence my client cannot proceed against the petition schedule
properties, after passing of the said decree repeated demands made by my client
both you are fail to pay the said amount due under the above decree so for, you are
doing business and also having both movable and other immovable properties in
your village. Even though you are having capacity to pay the said amount you
evading the payment with a view to delay the proceedings.
Therefore you are hereby called up on to pay the said entire suit amount with
interest as directed by the Honorable court to my client, within a week from the
date of receipt of this notice, failing which my client will be constrained to file
Execution Petition agonist you only by way of arrest for recovery of the amount
due under the above said decree, in such a case you will be held libel for the costs
and consequences thereon.
Vizianagaram,
Date: 12-11-2018. ADVOCATE.
1. Under the instructions of my client Boni Bharathi D/o late Ramayya R/o
Kirthuparthi Village, Gantyada Mandal, Vizianagaram district. I issue the
following notice as under:-
2. My client filed a suit against you for recovery of the amount due under the
suit promissory note, i.e., O.S NO: 373/2017 on the file of the Honorable Principal
Junior Civil judge’s court at Vizianagaram, the said suit was settled before the
DLSA, Viziqanagaram and award was passed on 14-07-2018, as per award you are
agreed to pay an amount of Rs. 10,000/-to my client towards full and final
satisfaction of the suit claim and you further agreed to pay the said Rs; 10,000/- in
two installments each Rs:5,000/- in which the 1 st installment is payable by you on
or before the end of July, 2018 and the remaining balance of Rs: 5,000/- is payable
by you on or before end of the month August, 2018, failing which, my client is at
liberty to recovery the entire suit amount by way of execution, after passing of the
said award repeated demands made by my client you have paid only Rs: 5,000/-
towards 1st installment thereafter you have fail to pay the balance amount due
under the above said award so for, hence my client is entitle for the entire suit
claim after deducting payment of the 1st installment of Rs: 5,000/-.You are having
both movable and immovable properties in your village. Even though you are
having capacity to pay the said amount, you evading the payment with a view to
delay the proceedings.
3. Therefore you are hereby called up on to pay the said entire suit amount as
directed by the Honorable court to my client, within a week from the date of
receipt of this notice, failing which my client will be constrained to file Execution
petition agonist you by way of arrest for recovery of the amount due under the
above said award, in such a case you will be held libel for the costs and
consequences thereon.
Vizianagaram,
Date: 29-10-2018. ADVOCATE.
AFFIDAVIT
I, Varri Devudamma w/o late Simhadri, Hindu, aged about 64 years, housewife,
resident of Madanapuram Village, Gantyada Mandal, Vizianagaram district, do hereby
solemnly affirm state on oath as follows:-
The lands situated in Madanapuram and Bonanagi villages in Gantyada Revenue
Mandal, which are shown in the “A” to “B” schedule are the lands succeeded from my
husband by name Varri Simhadri who died intestate on 09-05-2002, leaving behind him
myself and my two sons by namely 1) Varri Demudu Babu, 2). Varri Venkata Kannam
Naidu as his class-1 legal heirs and out of which some of those lands are ancestral
properties and self acquired properties of my husband Varri Simhadri and myself. I
further submit that the lands mentioned in “C” schedule are succeeded through my mother
by name Mukala Pydithalli and all the lands are in possession and enjoyment of myself and
my two sons. Hence I am hereby declare that I have no objection to issue Pattadar pass
Book and Title deed Books in favour of my two sons in respect of the lands covered by “A”
and “B” schedule. I further submit that to issue Pattadar Pass Book and Title deed Book in
my favour in respect of the lands described in “C” schedule which are situated in Bonangi
Revenue village, for which my two sons have no objection. Hence this affidavit.
“A”SCHEDULE to V. DEMUDU BABU
S. No: Survey No: Extent: Nature of land:1.
1. 148-8 0-11 cents Wet land
2. 148-11 0-05 cents Wet land
3. 147-22(P) 0-19 cents Wet land
4. 147-11 0-15 cents Wet land
5. 141-3 (P) 0-08 cents Wet land
6. 142-1 0-11 cents Wet land
7. 142-11 0-07 cents Wet land
8. 142-15 0-07 cents Wet land
9. 139-22 0-13 cents Wet land
10. 100-6(P) 0-15 cents Dry land
11. 100-16(P) 0-15 cents Dry land
12. 75-8 (P) 0-38 cents Dry land
13. 76-4 (P) 0-12 1/2 cents Dry land
14. 74-4 (P) 0-22 cents Dry land
15. 74-3 (P) 0-03 cents Dry land
16. 65-20(P) 0-34 1/2 cents Dry land
Total Extent : 2-36 cents
--------------------------------------------------------------------
“B”SCHEDULE TO V. VENKATA KANNAM NAIDU
S. No: Survey No: Extent: Nature of land:1.
From, To,
The Project Director, Sri. T. Mutyala Naidu,
D. R. D. A, Velugu, Advocate,
VIZIANAGARAM, GAJAPATHINAGARAM.
REPLY NOTICE
Vizianagaram,
Date: 16-08-2018.
PROJECT DIRECTOR
D. R. D. A. VELUGU,
VIZIANAGARAM.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 14-08-2018.
T0,
Sri. Boddula Maheswara Rao @ Mahesh,
S/o Ramu Naidu,
R/o Dwarapudi Village,
Vizianagaram Mandal /District.
1. Under the instructions from my client Sri. Guruvu Rama Krishna S/o
Govinda Rao, residing at Door No:17-133/1, Arundathi Nagar, Near Goodsshad,
Vizianagaram. I issue the following notice as under.
2. You have borrowed an amount of Rs: 2,00,000-00 (Rupees two lakhs only)
from my client on 10-09-2015 ( Tenth, September, two thousand and fifteen) for
the purpose of clearing your sundry debts and in evidence thereof you have
executed two demand promissory notes each Rs:1,00,000/- in favor of my client
on the same day i,.e,. on 10-09-2015 and agreeing to repay the same together with
interest @ 24% p.a. either to my client or to his order, in spite of repeated demands
made by my client for repayment of the amount due under the above said two
promissory notes, but you did not chose to repay the said amount either towards
principal or interest due under the above said pronotes, and postponing the same on
some on some pretext or the other.
3. Therefore you are hereby called up on to pay the said amount due to my
client within a week from the date of receipt of this notice, failing which my client
will be constrained to file a suit against you for recovery of the amount due under
the above said pronotes with subsequent interest and costs thereon.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 15-06-2018
To,
1. Smt. Poluparthi Sanyasamma, w/o late Satyam
R/o Pedavemali Village, Gantyada Mandal, Vizianagaram district.
2. Sri. Poluparthi Verri Naidu S/o late Satyam, rest ---do---,
3. Sri. Poluparthi Demudu S/o late Satyam, rest ---do---,
4. Smt. Rongali Gowri Simahachalem w/o Ravi, D/o late Satyam,
R/o Korukonda Village, Vizianagaram Mandal/district.
5. Smt. Poluparthi Satyavathi w/o late Thatha,
R/o Pedavemali Village, Gantyada Mandal, Vizianagaram district.
6. Sri. Poluparthi Yerri Naidu S/o late Thatha, rest ---do---,
7. Sri. Poluparthi Thammanna S/o late Thatha, rest ---do---,
8. Sri. Poluparthi Naramma S/o late Thatha, rest ---do---,
9. Sri. Poluparthi Yeruku Naidu s/o late Appala Naidu, rest ---do---,
REGISTRED LAWYER’S NOTICE
7. Under the instructions of my client Sri Poluparthi Kannam Naidu s/o late Appala Naidu,
resident of Pedavemali Village, Gantyada Mandal, Vizianagaram district, I issue the following
notice to all of you as here under:-
8. The No: 9 of you, one Poluparthi Satyam and one Poluparthi Thatha and my client are the
children of the one Poluparthi Appala Naidu through his wife Poluparthi Chinnamma, The said
Poluparthi Appala Naidu succeeded the landed properties from his ancestors both wet and dry
lands situated at Pedavemali Village of Gantyada Mandal to an extent of nearly Ac.7-00 cents.
The said Poluparthi Appala Naidu died intestate at about 8 years back leaving behind him, his
wife and his four sons as his class-1 legal heirs and his elder son by name Poluparthi Satyam
died at about 8 years back subsequent to the death of his father leaving behind him his wife and
children the No; 1 to 4 of you as his class-1 legal heirs. There after his 2 nd son by name
Poluparthi Thatha died at about 6 years backs leaving behind him his wife and children the No: 5
to 8 of you as his class-1 legal heirs, and as such all the above members are constituted a Hindu
joint family under Mithakshra school of law.
9. That during the life time of the said late Poluparthi Appala Naidu, being the Karta of a
joint family he used to manage all the properties till his death on behalf of all the family
members. After the death of said Poluparthi Appala Naidu, his wife Poluparthi Chinnamma,
being the elder member she used to manage the entire properties on behalf of all the members in
the joint family till her death. The said Poluparthi Chinnamma died at about 1 ½ years back,
After the death of Poluparthi Chinnamma, all the properties are in joint possession and
enjoyment of all the family members,( i,.e,. all of you and my client ). In the recent times the
No:9 of you is acting detrimental to the rights of my client in the joint family properties and to
avoid to give the share of my client in the income derived from the joint family properties and
therefore my client felt that it is not safe for him to keep the joint family properties in joint herein
after.
4. During the last week of May, 2018, my client has demanded the all of you to partition the
schedule mentioned properties in to four equal shares and to allot one such share to my client for
which all of you admitted the liability and postponing the same on some pretext or the other.
5. As per Law my client is entitled to get ¼ th share in the schedule mentioned properties as
he is the youngest son of the said Poluparthi Appala Naidu, and out of the remaining three shares
the No: 1 to 4 of you are entitle for 1/4th share as they are class-1 legal heirs of the deceased
Poluparthi Satyam who was the elder son of the said Poluparthi Appala Naidu and the No: 5 to 8
of you are entitle for 1/4th share as they are the class-1 legal heirs of the deceased Poluparthi
Thatha, and No; 9 of you who is the 3 rd son of the said Poluparthi Appala Naidu is entitle for
1/4th share as one of class-1 legal heir of Poluparthi Appala Naidu, therefore all of you are liable
to partition the schedule lands and to allot 1/4th share to my client.
7. Therefore all of you are hereby called upon to partition the schedule mentioned properties
in to four equal shares and to allot one such share to my client within a week from the date of
receipt of this notice, failing which my client will be constrained to take appropriate legal action
in the court of law and in which case all of you will be held liable for all the costs and
consequences thereof.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE LANDS
District:- Vizianagaraam Mandal:_ Gantyada,
Sub Registrar division:- Vizianagaram (west), Village:- Pedavemali Village.
Date:- 11-06-2018
To,
Sri. Gara Rama Satyam,
S/o Appalasatyam,
R/o Puritipenta New Railway Colony,
Gajapathinagaram Mandal,
Vizianagaram district.
REGISTERED LAWYER`S NOTICE
1. Under instructions from my client Sri. Bodaballa Yernaidu S/o Kota Appa
Rao, resident of Kottam Village, S. Kota Mandal, Vizianagaram district. I issue the
following notice as here under:-
2. My client is doing construction works and during his course of his business
he agreed to construct R.C.C Slabbed house (G+2) in a vacant site situated in
survey No; 53/1 part to an extent of 220 square yards in Kilash Nagar lay-out of
Karakavalsa Village, Ramavaram Panchayath, of Gantyada Mandal, Vizianagaram
district, belongs to one Mariserla Prasanna Laxmi vide agreement dated 22-04-
2017, as per the terms and conditions of the said agreement my client is
constructing R.C.C Group house(G+2) in the said vacant site.
Knowing about the construction of RCC group house (G+2) in afore said
vacant site, you approached my client requested to sell a Flat (G-2) in the said
building at the rate of total sale consideration of RS: 13,00,000/- (Rupees Thirteen
lakhs only) and out of which you have paid Rs:1,00,000/- (Rupees one lakh only)
to my client towards advance of sale consideration and on 22-04-2017 my client
has executed an agreement of sale in your favour in respect of the G-2 Flat, as per
the term and conditions of the said agreement you have pay the balance amount of
Rs: 12,00,000/- shall be payable to my client stage to stage depending upon the
construction of work, now my client has completed the construction work up to
70% and he invested huge amounts and on so many previous occasions my client
has demanded you to pay the balance amount to my client of 70% in total sale
consideration, but on all occasions you have put deaf ear. As per the agreement
date 22-04-2017 you are bound to pay an amount of Rs: 9,00,000/ and odd.
4. This is therefore demanding you to pay the amount of Rs: 9,00,000/- within
a week from the date of this notice otherwise my client is at liberty to withdraw
from contract of the agreement dated 22-04-2017 and he will proceed further on
his way to relies his amounts which was invested by him on the construction of G-
2 Flat. Take notice that incase of you are not going to pay Rs: 9,00,000/- and odd
within a week from the date of this notice, the agreement dated 22-04-2017 shall
cancelled.
Vizianagaram,
Date: 12-06-2018. ADVOCATE
. Working address;-
Sri. Gara Rama Satyam, S/o Appalasatyam, working as Lecturer in Botany, Aditya
Junir Collage, Bodasingipate, Gajapathinagaram, Vizianagaram district.
10. Under the instructions of my clients 1. Smt. Papayyamma w/o late Pothu Naidu, 2. Ganta
Lakshmi w/o late Adinarayana, D/o late Kandi Pothu Naidu,3. Smt. Gedda Padma w/o
Suryanarayana D/o late Kandi Pothu Naidu, 4. Sri Kandi Thatu s/o late Pothu Naidu, and 5.
Kandi Venkata Rao, s/o late Potu Naidu, all are resident of Mopada Village, Denkada Mandal,
Vizianagaram district, I issue the following notice to all of you as here under:-
11. That my clients No: 2 to 5 are the children of Kandi Pothu Naidu through his 2 nd wife
Kandi Papayyamma, who is the NO: 1 of my clients and all of you are also the children of the
said Kandi Pothu Naidu through his 1st wife by name Narayanamma. The said Kandi Pothu
Naidu succeeded the landed properties both wet and dry lands situated at Akkivaram Villages of
Denkada Mandal to an extent of Ac. 7-00 cents approximately. The said Pothu Naidu died
intestate at about nearly 30 years back leaving behind him the all of you and my clients are as the
class 1 Legal heirs for his entire estate.
3. That during the life time of the said late Kandi Pothu Naidu beingthe Karta of the joint
family he used to manage the properties till his death on behalf of all the family members. After
the death of said Kandi Pothu Naidu, No: 1 of you being the senior male member in the joint
family is managing the entire properties on behalf of all the members in the joint family. After
the death of Kandi Pothu Naidu all the properties are in joint possession and enjoyment of all the
family members. In the recent times the No:1 of you is acting detrimental to the rights of my
clients in the joint family properties and to avoid to give their share in the income derived from
the joint family properties and therefore my clients felt that it is not safe for them to keep the
joint family properties in joint herein after.
5. That my clients have demanded all of you to partition the schedule mentioned properties in
two equal shares and to allot one such share to my clients for which all of you admitted the
liability and postponing the same on some pretext or the other.
6. As per Law and procedure laid down under the Act, my clients are entitled to get half share
over the schedule mentioned properties and other properties besides in the schedule properties
and all of you are liable to partition the schedule lands and to allot half share to my clients.
7. Therefore all of you are hereby called upon to partition the schedule mentioned properties
in to two equal shares and to allot one such share to my clients within a week from the date of
receipt of this notice, failing which my client will be constrained to take appropriate legal action
in the court of law and in which case all of you will be held liable for all the costs and
consequences thereof incidental thereto.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE LANDS
District:- Vizianagaraam Mandal:_ Denkada,
Sub Registrar division:- Bhogapuram, Village:- Akkivaram Village.
4. Sri. Mopada Pentayya S/o late Ramu Naidu, all are resident of
Ambativalsa Village, Bondapalli Mandal, Vizianagaram district.
1. The No: 1 of you is the mother of the No: 2 to 4 of you and No:1 of you and
one Kondapalli Kanchamma who is the wife of my 1 st client and mother of 2nd and
3rd clients and another deceased unmarried lady by name K. Suramma are the only
daughters of Kalisetti Sanyasappadu through his wife Kalisetti Chinnamma, The
said Kalisetti Sanyasappadu died about 16 years back leaving behind him his three
daughter as his class-1 legal heirs. Prior to his death his wife and his 2 nd daughter
by name Kalisetti Suramma was died at about 25 years backs, during his life time
the said Kalisetti Sanyasappadu purchased landed property to an extent of Ac. 1-16
cents from Paluri Bangari Naidu s/o Suri Naidu, of Ambativalsa Village, which is
in joint possession and enjoyment of all the joint family members i.e., the my
clients and all of you and the said Kalisetti Sanyasappadu succeeded land to an
extent of nearly Ac.0-34 cents i,.e., the Item No: 2 to 4 of notice schedule
properties from his ancestors both wet and dry lands situated at Ambativalsa
Village of Bondapalli Mandal.
2. That during the life time of the said Kalisetti Sanyasappadu, being the Karta
of a joint family he used to manage all the properties till his death on behalf of all
the family members. After the death of said Kalisetti Sanyasappadu, his wife
Poluparthi Chinnamma, being the elder member she used to manage the entire
properties on behalf of all the members in the joint family till her death. The said
Poluparthi Chinnamma died at about 1 ½ years back, After the death of Poluparthi
Chinnamma, all the properties are in joint possession and enjoyment of all the
family members,( i,.e,. all of you and my client ). In the recent times all of acting
detrimental to the rights of my clients in the joint family properties and to avoid to
give the share of my clients in the income derived from the joint family properties
and therefore my clients felt that it is not safe for him to keep the joint family
properties in joint herein after.
4. During the last week of October, 2019, my clients has demanded the all of you
to partition the schedule mentioned properties in to two equal shares and to allot
one such share to my clients for which all of you admitted and postponing the same
on some pretext or the other.
5. As per Law my client is entitled to get half share in the schedule mentioned
properties as they are class -1 legal heirs late Kondapalli Kanchamma who was the
1st daughter of the said Kalisetti Sanyasappadu, therefore all of you are liable to
partition the schedule lands and to allot half share to my clients.
7. Therefore all of you are hereby called upon to partition the schedule
mentioned properties in to two equal shares and to allot half share to my clients
within a week from the date of receipt of this notice, failing which my client will
be constrained to take appropriate legal action in the court of law and in which
case all of you will be held liable for all the costs and consequences thereof.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if
necessary.
SCHEDULE LANDS
District:- Vizianagaraam, Mandal: Bondapalli Mandal, Ambativalsa Village,
Sub Registrar division:- Vizianagaram (west), Village:- Ambativalsa Village.
Date:- 20-07-2019
REGISTERED NOTICE WITH ACK DUE
To,
Sri. Lagudu Ravi,
S/o Satyannarayana,
Pollanki Village,
Penta Sreerampuram post,
Gantyada Mandal,
Vizianagaram district.
A D V O C A T E.
4. Therefore please advise your client to send a Xerox copy of the alleged
pronote to my client so as to enabling my client to send proper reply after going
through the same.
5. This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case. my client will also file criminal
case against your client for giving notice on false and baseless allegations.
A D V O C A T E.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE LANDS
District:- Vizianagaram Mandal:_ Poosapatirega Village,
Sub Registrar Office:- Bhogapuram,
Village:- Govindapuram Village, .
Survey No: Extant: Nature of: Boundaries:-
Cents, Property:-
1. Under the instructions from my client Sri. Latchireddi Sanyasi Naidu, S/o
late Narayana, resident of Madanapuram Village, Gantyada Mandal, Vizianagaram
district, I issue the following notice as here under.
3. This is therefore you are hereby called upon to pay the said amount due
under the above said promissory note to my client with in a week from the date of
receipt of this notice, failing which my client will be constrained to file a suit
against you for recovery of the same, in which case you will be held liable for all
costs and consequences thereof.
A D V O C A T E.
B. NARASIMHA MURTHY, B.Com B.L, Mobile No: 94408 91511,
ADVOCATE R/o D.No: 8-32-228/A,
KOTHA MAJJIPETA,
V. T. AGRAHARAM,
VIZIANAGARAM - 535 003,
Date:- 16-10-2017.
TO,
Sri. Medisetty Mahalaxmi Kanaka Raju
S/o Pentayya,
Proprietor Dream Land Developers,
Flat No: 8, Rao Towers,
Narasimha Nagar, N H : 5,
Visakhapatnam -530 016.
1. Under the instruction of the client Smt. Reddipalli Joythi w/o Jagadeesh
Babu R/o Reddipalli Village, Padmanabham Mandal, Vizianagaram district. I issue
the following notice as under:-
2. My client filed a suit against you for recovery of the amount due under the
suit promissory note, i.e., O.S NO: 458/2014, on the file of the Honorable Senior
Civil judge’s court Parvathipuram, Camp court at Vizianagaram, the said suit was
settled before the DLSA, Viziqanagaram and award was passed on 11-02-2017, as
per award you are agreed to pay an amount of Rs. 50,000/-to my client towards full
and final satisfaction of the suit claim and you are further agreed to pay the said
Rs;50,000/- on or before 5th April,2017, failing which, my client is at liberty to
recovery the entire suit amount by way of execution, after passing of the said
award repeated demands made by my client, you are fail to pay the said amount
due under the above said award so for, you are doing business and also having both
movable and immovable properties in your village. Even though you are having
capacity to pay the said amount, you evading the payment with a view to delay the
proceedings.
3. Therefore you are hereby called up on to pay the said entire suit amount as
directed by the Honorable court to my client, with in a week from the date of
receipt of this notice, failing which my client will be constrained to file Execution
petition agonist you by way of arrest for recovery of the amount due under the
above said decree, in such a case you will be held libel for the costs and
consequences their on.
Vizianagaram,
Date: 08-11-2018. ADVOCATE.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
To,
1. Sri. Boora Ramu S/o Adayya, R/0 Udikalapeta Village,
H/o Peda Thadivada, Denkada Mandal, Vizianagaram district.
2. Sri. Boora Pydappadu S/o Gangulu, R/0 Udikalapeta Village,
H/o Peda Thadivada, Denkada Mandal, Vizianagaram district.
3. Sri. Boora Ramana S/o Adinarayana, R/0 Gantyada Village &
Mandal, Vizianagaram district.
4. Smt. Paleturu Appalanarasamma w/o Aappanna,
R/0 Gantyada Village & Mandal, Vizianagaram district.
REGISTARED LAWYER`S NOTICE
1. Under the instruction of the client Sri. Volle Venkata Ramana S/o Peda
Satyanarayana R/o Chandrampeta Village, Nellimarala Mandal, Vizianagaram
district. I issue the following notice as here under:-
2. My client filed a suit against all of you for specific performance of the
agreement of sale to execute registered sale deed in favour of my client or his
nominee, after receiving the balance of sale consideration of Rs: 18,00,000/- from
my client and put him in possession of the plaint schedule land after evicting all of
you, or in alternative all of you are directed to refund the advance amount of Rs:
5,00,000/- together with subsequent interest at 24% p.a., from the date of the suit
till realization and for costs.
3. My client states that the above suit i.e., O.S No: 43/2015, on the file of the
Honorable Addl. District and Sessions Judge-cum- Special Court for SC & ST
Cases, (POA) Act. at Vizianagaram, was decreed on 19-04-2017, as per the decree,
all of you are directing to execute a registered sale deed in favour of my client or
his nominee after receiving the balance of consideration of Rs: 18,00,00/-from my
client and put him in possession with in two months from the date of decree or else
my client can take recourse of law to get the sale deed executed through court, and
also my client is directed to deposit the balance of sale consideration of
Rs:18,00,000/- with in one month from the date of the decree, and my client
obtained permission from the court to extend time till 09-06-2017 in I.A 408/2017
dated 1-6-2017 for depositing the said balance of sale consideration of
Rs:18,00,000/-, and all of you are further directed to pay a sum of Rs: 1,16,709/- to
my client towards costs of the suit.
4. My client further states that after passing of the said decree my client
deposited the said balance of sale consideration of Rs: 18,00,000/- in to the court
on 08-06-2017 vide challana No: , after passing of the decree despite of
repeated demands made by my client to take registered sale deed in his favour, but
all of you are not complied the order of the Honourable court so for.
5. Therefore all of you are here by called up on to execute registered sale
deed in favour of my client or his nominee, after receiving the balance of sale
consideration of Rs: 18,00,000/- from the court and put him in possession of the
plaint schedule land after evicting all of you and to pay a sum of Rs: 1,16,709/- to
my client towards costs of the suit.
izianagaram,
Date: 13-07-2017. ADVOCATE.
2. The allegations made in your notice that my client have well acquainted to
you client and that my client borrowed and your client paid a sum of Rs: 60,000/-in
cash from your client on 10-10-2016 as hand lone in presence of one Ms. G. Anita
Devi and Sri T. Murali of Vizianagaram with an understanding that my client will
be repay the said amount with in six months with interest @ 24/- per annum on the
said amount, and despite repeated demands made by your client, my client issued a
cheque bearing No; 960925 dated 26-02-2017 for Rs; 60,000/- drawn on Andhra
Bank, payble at Vizianagaram, in favour of your client towards part discharge of
the said due amount and your client presented the above said cheque bearing No;
960925 dated 26-02-2017 for Rs; 60,000/- drawn on Andhra Bank, payable at
Vizianagaram, in his account in ICICI Bank, Vizianagarm for collection and the
said was returned to him on 22-5-2017 unpaid, stating that the cheque was
dishonored due to funds insufficient in my client’s account, vide return memo
dated 22-05-2017 issued by the ICICI, Bank, Vizianagaram, and my client issued
the said cheque towards discharge of debt amount and knowing fully well that the
said cheque will never honour and my client willfully and wantonly issued the
cheque to your client to deceive and defraud him and thereby to get wrongful gains
and my client is liable to pay the cheque amount of Rs: 60,000/- to your client
along with remaining due amount are all false and invented by your client for the
purpose of your notice.
3. It is to state that my client has no direct acquaintance with your client, your
client’s mother and my client’s husband are entered in to an development
agreement on 02-05-2013 in which my client’s husband by name Bodaballa Yerri
Naidu agreed to construction of flats on the house site belongs to your client’s
mother, as per the said agreement, my client’s husband has to be construct six flats
on the said site, after construction of the said flats, as per the development
agreement my client’s husband had handed over two flats to your client’s mother
and in which your client’s mother also sold away one flat wherein my client’s
husband put his signature as an executants, the remaining four flats were sold away
by my client to third party wherein your client’s mother also put her signature as
one of the executants and all the above flats are delivered the possession to the
respective vendees, it is further states that when your client’s mother issued a legal
notice and brought the issue before the elders with regarding to her in completion
of work, and in the said settlement the husband of my client agreed to pay an
amount of Rs; 2,10,000/-to your client’s mother towards incomplete some external
minor works of her flats as valued by the elders and in which your client’s mother
and your client agreed to complete the balance work of her two flats, and on the
same day my client’s husband issued a cheque for Rs:50,000/- towards part of the
above settlement amount of Rs:2,10,000/-the same was dishonored on 26-02-2016
the said fact intimated by your client to my client’s husband, then my client’s
husband arranged the said cheque amount in cash and paid to your client’s mother
in presence of your client, for the remaining balance of the settlement of Rs:
1,60,000/- which is payable by my client’s husband has not paid with in time, there
after on demand of your client’s mother, my client’s husband executed a
promissory note for Rs: 1,50,000/- on 15-02-2017 by his own hand writing by
leaving the gaps at lenders’ address, and she also received on blank cheque with
mentioning the date towards security for the above said balance amount. There
after my client’s husband gave two cheques i,.e,. one is for Rs; 60,000/-dated 26-
02-2017 belongs to my client drawn on Andhra Bank, and another cheque for
Rs:1,00,000/- issued by my client’s husband to your client’s mother with out
mentioning the drawer’s name, but your client honored the said cheque for Rs:
1,00,000/- on 06-03-2017, but my client’s cheque is not honored due to insufficient
funds in her account as she is not arranged the said amount, because, the reason
behind that your client’s mother is fail to return back the said promissory note and
cheque dated 15-02-2017 for Rs;1,50,000/- which were obtained by your client and
his mother as security for the balance of settlement amount, and again your client
and his mother insisted my client and her husband to pay the noticed cheque
amount of Rs:60,000/- then they return back the said promissory note and cheque
dated 15-02-2017 for Rs;1,50,000/- which were obtained by your client and his
mother as security, for which my clients husband paid Rs;30,000/- by NEFT UTR
No: SBIN 717492899072 to your client’s account towards part payment of the
above said cheque, and as on account the remaining balance of Rs:30,000/- is
ready to pay which is payable by my client’s husband, hence my client is no where
consent to the said transactions held between your client, his mother and my
client’s husband.
My client further states that suppressing all the above facts and gave
instructions to you by laying false theory and got issued legal notice basing the
cheque dated 26-02-2017 belongs to my client by presenting your client’s account
instead of his mother by creating false purpose and misusing the same.
4. My client further state that it is absolutely false that my received hand lone of
Rs: 60,000/-from your client in presence of your client henchmen one Anitha Devi
and T. Murali, as stated in your notice and they are not known to my client, as such
my client is not liable to pay amount as demanded in your notice. My client further
states that she never issued any cheque to your client as stated by your client,
taking advantage of the cheque kept in your client’s mother, your client got issued
this notice through you with all false and untenable allegatitions.
6. This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 18-12-2017.
To,
THE TASHEELDHAR,
PADMANABHAM MANDAL
VISAKHAPATNAM DISTRICT.
1. Under the instructions from my client Sri. Thogurothu Krishna s/o late Somulu
of Routhulapalem Village, Revidi Panchayet, Padmanabham Mandal,
Visakhapatnam district, presently residing at Chelluru Village, Vizianagaram
Mandal / district, I am issuing the registered lawyer’s notice as here under.
2. It is to inform you that my client Thogurothu Krishna s/o late Somulu, has
filed a suit in O.S No: 921 /2017 on the file the Principal Senior Civil Judge’s Court
at Visakahapatnam, against the defendants i,.e,. 1. Sarika Narayanamma, 2.
Thogurothu Thoudu, 3. Bantupalli Chinathalli, and 4. Thogurothu Guru Naidu, for
partition of the following lands situated in survey Nos: 155/4, 153/26, 171/14,
171/11, 170/16, 155/11, 170/11 to an extents Ac. 0.36 cents, Ac.0.12 cents, Ac.0.64
cents, Ac. 0.25 cents, Ac. 0.53 cents, Ac. 0.31 cents, and Ac. 0.22 cents respectively
of Routhulapalem Village, H/o Revidi village, Padmanabham Mandal, the above
said properties are the ancestral and joint family properties of both the plaintiff and
the defendants in the above said suit.
3. It is further inform you that my client reliably came to know that during the
pendency of the above suit, the 4th defendant by name Thogurothu Guru Naidu s/o
late Somulu, who is younger brother of my client is approached your authority to
incorporate his name in all the revenue records in online system with regarding to
the above said landed properties with out having any exclusive right, title,
possession and enjoyment of the above said lands.
4. Therefore, I hereby request you not to issue or alter any revenue records in
favour of the above said Thogurothu Guru Naidu s/o late Somulu, of Routhulapalem
village, H/o Revidi, Padmanabham Mandal, with out conducting any enquiry, in
respect of the above said lands situated in survey Nos: 155/4, 153/26, 171/14,
171/11, 170/16, 155/11, 170/11 to an extents Ac. 0.36 cents, Ac.0.12 cents, Ac.0.64
cents, Ac. 0.25 cents, Ac. 0.53 cents, Ac. 0.31 cents, and Ac. 0.22 cents respectively
of Routhulapalem Village, H/o Revidi village, Padmanabham Mandal, else my client
will take necessary steps in a court of law.
4. This is therefore request you not to entertain any application or petition filed
by the Thogurothu Guru Naidu s/o late Somulu, for mutation of his name in all the
revenue records and to getting Pattadhar pass books and title deeds in respect of the
above said lands situated in survey Nos: 155/4, 153/26, 171/14, 171/11, 170/16,
155/11, 170/11 to an extents Ac. 0.36 cents, Ac.0.12 cents, Ac.0.64 cents, Ac. 0.25
cents, Ac. 0.53 cents, Ac. 0.31 cents, and Ac. 0.22 cents respectively of
Routhulapalem Village, H/o Revidi village, Padmanabham Mandal, with out having
any exclusive right and possession over the said lands.Now my client reliably came
to know that one Badukonda Pydithalli S/o late Appalaswamy of Mopada Village,
Denkada Mandal, is approached your authority to incorporate his name in all the
revenue records in online system with regarding to the above said land with out
having any right, title, possession and enjoyment of the said land.
4. Therefore I hereby request you not to issue or alter any revenue records in
favour of the above said Badukonda Pydithalli S/o late Appalaswamy of Mopada
Village, Denkada Mandal, with out conducting any enquiry, in respect of the above
said lands, else my client will take necessary steps in a court of law.
ADVOCATE.
1. Under the instructions from my client Smt. Pinninti Ramayyamma W/o Ramulu
of Maddipeta Village, H/o Gudivada Panchayet, Bhogapuram Mandal,
Vizianagaram district, I am issuing the registered lawyer’s notice as here under.
2. It is to inform you that the father of my client Chilla Yellanna S/o late
Ramaswamy of Maddipeta Village, H/o Gudivada panchayet, had bequeathed his
properties such as two thatched houses Nos: 5-1 and 5-2 and Ac.3-00 cents of dry
land situated in survey No: 51/10 of Gudivada village by virtue of Registered will
dated:15-11-1990 in favour of my client and her brother by name Chilla Appala
Raju. It is further informed you that out of the total extent of Ac: 3-00 cents of dry
land, my father bequeathed in her favour to an extent of Ac: 0-50 cents and the
remaining Ac:2-50 cents and the two thatched houses were given to my client
brother Chilla Appala Raju. It is further informed that after execution of the
registered will dated 15-11-1990, the father of my client Chilla Yellanna died, and
after his death the properties described in the will came to the possession of my
client and her brother Chilla Appala raju.
3. While the matter stood thus my client has sold away her Ac: 0-50 cents of dry
land in survey No: 51/10 (P) to others by virtue of registered sale deed. Thereafter
my client purchased the dry land to an extent of Ac: 1-92 cents (which includes the
portion of Ac:1-50 cents acquired by Chilla Appala raju through registered will )
situated in survey No; 51/10 (P) of Gudivada village from her brother Chilla Appala
Raju by virtue of registered sale deed dated: 02-11-2006 and the said property of Ac:
1-92 cents is under the cultivation and enjoyment of my client from the date of its
purchase.
4. It is further informed that basing on the registered sale deed executed by the
Chilla Appala Raju, the then M.R.O, Bhogapuram, issued Pattadhar Pass book and
title deed bearing No; 444 in respect of the dry land survey No; 51/10 (P) to an
extent of Ac:1-92 cents, and my client has been paying land revenue to the Revenue
Authorities from time to time in respect of the said land.
. It is further inform you that one Chilla Yerrayya s/o Ellanna, who is also
brother of my client is filed a petition before you for getting Pattadhar pass books
and title deeds in respect of the land Ac:1-92 cents in survey No; 51/10 of Gudivada
Village, which is some portion of the land purchased by my client from her brother
Chilla Appala Raju by virtue of registered sale deed dated 02-11-2006, on basing on
false documents.
4. This is therefore request you not to entertain any application or petition filed
by Chilla Yerrayya s/o Ellanna of Gudivada village, claiming for issuance of
Pattadhar pass books and title deeds in respect of the land Ac:1-92 cents situated in
survey No; 51/10 P of Gudivada Village, with out hearing of client or else my client
will be constrained to take appropriate legal action in the court of law against you
and Chilla Yerrayya for necessary relief’s, in which case you and Chilla Yerrayya
are held liable for all costs and consequences thereof.
ADVOCATE.
1. Under the instructions from my client Smt. Gedda Rajamma W/o Pydithalli
of Mopada Village, Denkada Mandal, Vizianagaram district, I informed you the
following few facts for your kind notice.
2. My client Gedda Rajamma W/o Pydithalli, is the absolute owner of the dry
land situated in survey No: 52 / 2 of Mopada Village, Denkada Mandal,
Vizianagaram district, to an extent of Ac.0-17 cents, which is devolved from her
father, since than she has been in peaceful possession and enjoyment of the same
since her fathers time, and the entire revenue records are also stands in her name and
the revenue authority also issued Pattadar pass book and Title deed in her name with
regarding to the above said land.
3. Now my client reliably came to know that one Badukonda Pydithalli S/o late
Appalaswamy of Mopada Village, Denkada Mandal, is approached your authority to
incorporate his name in all the revenue records in online system with regarding to
the above said land with out having any right, title, possession and enjoyment of the
said land.
4. Therefore I hereby request you not to issue or alter any revenue records in
favour of the above said Badukonda Pydithalli S/o late Appalaswamy of Mopada
Village, Denkada Mandal, with out conducting any enquiry, in respect of the above
said lands, else my client will take necessary steps in a court of law.
ADVOCATE
.
Encloses:- Xerox copies of the Pattadar pass book and Title deed book are
herewith enclosed for your kind perusal.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:-23-03-2018.
T0,
Sri. Raghumanda Rama Rao
S/o late Ramu,
R/o Kirthuparthi Village,
Gantyada Mandal,
Vizianagaram district.
1. Under the instructions from my client Sri. Aluru Sanyasi S/o Sanjeevu,
resident of Kirthuparthi Village, Gantyada Mandal, Vizianagaram district, I issue
the following notice as here under.
3. This is therefore you are hereby called upon to pay the said amount due under
the above said promissory note to my client with in a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the amount due, in which case you will be held liable for all costs
and consequences thereof.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L, Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:-17-02-2017.
T0,
Sri. Boni Simhadrappadu,
S/o late Pydithalli,
R/o Kirthuparthi Village,
Gantyada Mandal,
Vizianagaram district.
1. Under the instructions from my client Smt. Boni Bharathi D/o late Ramayya,
resident of Kirthuparthi Village, Gantyada Mandal, Vizianagaram district, I issue
the following notice as here under.
2. That on 26-08-2015 (Twenty sixth, August, two thousand fifteen) you have
borrowed an amount of Rs: 13,600-00 (Rupees thirteen thousand and six hundred
only) from my client for the purpose of sundry expenses, and in evidence their of
you had executed a promissory note in favour of my client on the same day
agreeing to repay the same together with subsequent interest thereon @ 24% per.
annum. on demand, either to my client or to her order, in spite of repeated demands
made by my client to repay the said amount due under the above said promissory
note, but you did not chose to repay the said amount either towards principal or
interest due to my client and postponing the same on some pretext or the other.
3. This is therefore you are hereby called upon to pay the said amount due under
the above said promissory note to my client with in a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the amount due, in which case you will be held liable for all costs
and consequences thereof.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:-17-02-2017.
T0,
Sri. Songa Gowri Sanker
S/o Prakash,
R/o Kirthuparthi Village,
Gantyada Mandal,
Vizianagaram district.
1. Under the instructions from my client Smt. Boni Bharathi D/o late Ramayya,
resident of Kirthuparthi Village, Gantyada Mandal, Vizianagaram district, I issue
the following notice as here under.
2. That on 24-06-2014 (Twenty four, June, two thousand fourteen) you have
borrowed an amount of Rs: 11,000-00 (Rupees eleven thousand only) from my
client for the purpose of your sundry expenses, and in evidence their of you had
executed a promissory note in favour of my client on the same day agreeing to
repay the same together with subsequent interest thereon @ 24% per. annum. on
demand, either to my client or to her order, in spite of repeated demands made by
my client to repay the said amount due under the above said promissory note, but
you did not chose to repay the said amount either towards principal or interest due
to my client and postponing the same on some pretext or the other.
3. This is therefore you are hereby called upon to pay the said amount due under
the above said promissory note to my client with in a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the amount due, in which case you will be held liable for all costs
and consequences thereof.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:-23-03-2018.
T0,
Smt. Songa Simhachalem
w/o Prakash,
R/o Kirthuparthi Village,
Gantyada Mandal,
Vizianagaram district.
1. Under the instructions from my client Smt. Boni Bharathi D/o late Ramayya,
resident of Kirthuparthi Village, Gantyada Mandal, Vizianagaram district, I issue
the following notice as here under.
2. That on 24-06-2017 (Twenty four, June, two thousand seventeen) you have
borrowed an amount of Rs: 7,800-00 (Rupees seven thousand and eight hundred
only) from my client for the purpose of your sundry expenses, and in evidence
their of you had executed a promissory note in favour of my client on the same day
agreeing to repay the same together with subsequent interest thereon @ 24% per.
annum. on demand, either to my client or to her order, in spite of repeated demands
made by my client to repay the said amount due under the above said promissory
note, but you did not chose to repay the said amount either towards principal or
interest due to my client and postponing the same on some pretext or the other.
3. This is therefore you are hereby called upon to pay the said amount due under
the above said promissory note to my client with in a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the amount due, in which case you will be held liable for all costs
and consequences thereof.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:-17-02-2017.
T0,
Sri. Kondapalli Mutyalu
S/o late Thatha,
R/o Kirthuparthi Village,
Gantyada Mandal,
Vizianagaram district.
1. Under the instructions from my client Smt. Boni Bharathi D/o late Ramayya,
resident of Kirthuparthi Village, Gantyada Mandal, Vizianagaram district, I issue
the following notice as here under.
3. This is therefore you are hereby called upon to pay the said amount due under
the above said promissory note to my client with in a week from the date of receipt
of this notice, failing which my client will be constrained to file a suit against you
for recovery of the amount due, in which case you will be held liable for all costs
and consequences thereof.
A D V O C A T E.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 01-07-2016
To,
1. Smt. Sarika Narayanamma,
W/o Surayya
Routhulapalem Village, H/o Ravidi Village,
Padmanabham Mandal,
Visakhapatnam district
2. Sri. Thogurothu Thavudu,
S/o late Somulu
Present resident of M. Kothavalsa Village,
Jami Mandal, Vizianagaram district.
3. Smt. Bantupalli Chinathalli
W/o Chittibabu rest –do--
4. Sri. Thogurothu Guru Naidu
S/o late Somulu
Routhulapalem Village, H/o Ravidi Village,
Padmanabham Mandal,
Visakhapatnam district
REGISTRED LAWYER’S NOTICE
1. Under the instructions of my client Sri. Thogurothu Krishna s/o late Somulu, resident of
Routhulapalem Village, H/o Ravidi Village, Padmanabham Mandal, Visakhapatnam
district, present residing at Challuru Village, Vizianagaram Mandal/ district, I issue the
following notice to all of you as here under:-
2.That my client is the permanent resident of Routhulapalem Village, H/o Ravidi Village,
Padmanabham Mandal, Visakhapatnam district, present residing at Challuru Village,
Vizianagaram Mandal/ district, as he is working in jute mill at V.T Agraharam,
Vizianagaram, and he is the son of the late Thogurothu Somulu, the said Somulu died about
3 ½ years back and during his life time he was acquired ancestral properties and also earned
some land individually of the notice schedule properties and died leaving behind him my
client and 1 to 4 of you and all of you are the class 1 Legal hairs of the deceased Thogurothu
Somulu.
3.. That No:1 of you is the eldest daughter, No:2 of you is the eldest son, No: 3 of you is the
youngest daughter, and No: 4 of you is the younger son, and my client is the second son of the
deceased Thogurothu Somulu.
4. That during the life time of late Thogurothu Somulu being Karta of a family used to
manage the entire family and the properties till his death. After his death of the said Thogurothu
Somulu, No: 4 of you is managing the entire family properties as he is accompanying our father
till his death at Routhulapalem Village, after death of our father all the properties are in joint
possession and enjoyment of my client and now No: 2 and 4 of you are acting detrimental to give
share of my client from the produces derived from our lands and that it not safe to my client to
keep the lands in jointly, so my client is having 1/3 rd share in the said properties along with No: 2
& 4 of you. No: 1 & 3 of you are married daughters; during the life time of our father late
Somulu performed their marriages by presenting sufficient amounts and valuable properties as
such they shown as nominal parties.
5. That my client many times demanded you to partition the schedule mentioned properties in
3 equal shares and to allot one such share to my client for which No: 2 and 4 of you admitting
the liability and postponing the same some pretext or the other.
6. As per Law and procedure laid down under the Act, my client is entitled to get 1/3 rd share
over the schedule mentioned properties and other properties besides the schedule properties, as
such No: 2 & 4 of you are liable to partition the same and to allot one such share to my client.
7. Therefore No: 2 and 4 of you are hereby called upon to partition the schedule mentioned
properties in to three equal shares and to allot one such share to my client within week days from
the date of receipt of this notice, failing which my client will be constrained to approach a court
of law for appropriate legal action and in which case No: 2 and 4 of you will be held liable and
responsible for all the costs and consequences thereof incidental thereto.
A D V O C A T E.
NB:- A similar copy of this notice is retained in my office for further action if necessary.
SCHEDULE LANDS
1. Under instructions of my client Sri. Earla Ravi Raju S/o Sanyasi, resident of
House No: 57, L. B. Colony, Cantonment, Vizianagaram. I issue the following
notice to you as here under:
2. That on 16th April, 2015, my client and you along with your wife entered in to
an agreement for construction of RCC house, in which my client is agreed to
construct RCC Slab house in 150 square yards situated at Sri Lakshmi Nager,
Duppada Village, in Vizianagaram Mandel/district, comprised in survey No: 50/1,2
and 4 part, as per the construction agreement my client constructed the said RCC
Slab house up to slab level by receiving cash in part, after that for the lone purpose
you asked my client to cancel the said agreement and both are agreed and cancel the
same, then my client constructed the other finishing works, at the time of completion
of woke, the balance construction value of Rs:2,38,000-00 (Rupees two lakhs and
thirty eight thousand only) is payable by you to my client, for which you have issued
a cheque bearing No: 807698, dated: 03-05-2016 for Rs:2,38,000-00 drown on State
Bank of India, Vizianagaram, towards balance amount due under the construction
work.
3. My client presented the said cheque for collection through his banker AXIS
Bank, Vizianagaram, but the said cheque was returned unpaid with an endorsement
“FUNDS INSUFFICIENT” vide memo dated; 20-05-2016 of State Bank of India,
Vizianagaram, the same was served to my client through his banker, having
knowledge about the consequences in case of dishonor of cheque, and you issued the
above said cheque to my client only to harass my client and to avoid the payment of
the said promissory note. Thus you are libel for the punishment for the offence under
section 138 &142 of N. I. Act, and for civil and criminal actions that may be taken
by my client.
4. Therefore you are here by called upon to pay the said amount with interest
@24% per annum with in 15 days from the date of receipt of this notice failing
which my client will be constrained to approach to a court of law in both civil and
criminal action and which case, you will held liable and responsible for all costs and
consequences thereof.
A D V O C A T E.
2. My client Vakada Atchiyyamma W/o Adinarayana, filed a suit i.,e. O.S. No:
236/2014 before the Honourable Senior Civil judge Court at Vizianagaram for
partition of the plaint schedule properties in respect of their joint family properties
against defendants who are her mother and the legal representatives of her deceased
brothers, and the same is pending before Honourable court the said suit is stands
posted to Dt. 12-04-2016. and My client also filed a petition in I.A No: /2014 in
the above said suit for grant of ad-Interim Injunction restraining the defendants not
to alienate plaint schedule joint family properties till pending disposal of the suit, the
said petition is also is pending, the plaint schedule properties are situated in
Boorapeta Village H/o Savaravilli of Bhogapuram Mandal.
3. Now my client reliably came to know that the defendants in the above suit
i.,e. Smt. Boora Ramayyamma and others have been making preparations to register
some of the above suit schedule properties in favour of one Sidagam Raju s/o
Pentayya of Akkivaram Village, Bhogapuram Mandal, or any other third parties.
ADVOCATE.
Enclosers:- A copy of plaint in OS No: 236/2014, suit schedule, and copy of
injunction petition are here with enclosed for your kind perusal.
V. DEMUDUBABU M.A, B.L,. Mobile No: 94402 37075,
ADVOCATE, R/o H.No:218, M.I.G. 11, Phase. 111.
VUDA COLONY, CANTONMENT,
VIZIANAGARAM - 535 003,
==================================================
Date:- 07-12-2015.
To,
Sri. Nanduri Ramesh,
Advocate,
Plot No: 24, Sai Nagar, Thotapalem,
Opp: Gayatri College, Vizianagaram.
1. Under instruction from my client Sri. B. Bala Nageswara Rao, S/o late
Krishna Murthy, Gollalapeta Village, Vizianagaram Mandal/district, I am giving
you the reply notice to your notice dated 12-05-2020 issued on behalf of
Surakattula Hemalatha w/o late Venkata Ramana Murthy, R/o Pradeepnagar,
Vizianagaram, as here under:-
2. The allegations made in your notice that my client and one Garikimukkala
Suvrna Raju have borrowed an amount of Rs:5,00,000/- from your client on 11-10-
2017 and executed a demand promissory note on the even date, and agreed to
return with an interest at the rate of Rs.24% P.A. on demand either to your client or
to her order, and in spite repeated demands made by your client, my client and the
said G. Suverna Raju have failed to discharge the amount due under the
promissory note etc,. are all absolutely false and invented by your client for the
purpose of your notice.
3. It is to inform you that my client and No;1 of your notice are approached
your client and asked her to lend an amount of Rs.5,00,000/,- than, your client
withdrawn an amount of Rs: 3,00,000/- from her banker and paid to my client and
No:1 of your notice and there after again paid an amount of Rs: 50,000/- to them,
in totaling of Rs: 3,50,000/- and inevidence of thereof your client obtained a blank
promissory note which is duely signed by them. It is further informed that my
client and No:1 of your notice that they have regularly paid interest thereon on
monthly basis to your client, and subsequently my client and No: 1 of your notice
are repaid an amount of Rs:1,50,000/- to your client through one Suresh (car
driver) who mediater of this transation towards part payment. It is further informed
you that my client and No:1 of your notice are agree to repay the balance amount
of Rs; 2,00,000/- with in six months due under said promissory note dated 11-10-
2017.
6. This is therefore request you to advise your client not to embark on any useless
and vexatious litigation and in spite of this reply, if she proceeds further, it will be
at her own risk and peril and your client will also liable to pay the expenses to be
incurred by my client in defending the case.
A D V O C A T E.
To,
The Chairman,
Lokayouktha,
Andhra Pradesh,
Hyderabad,
Respected Sir,
Sub :- Complaint with regarding to violation of directions
of given in letter No: 5599/2013/B1/Lok/1/2013
dated: 02-01-2014 of Lokayouktha, Andhra
Pradesh, Hyderabad - regarding:-
I Janni Kannamma w/o Ganaga Raju residing at Ammapalem
village, Srungavarapukota Mandal, Vizianagaram district, submitting the
following few lines for your consideration.
I further submit that one Smt. Palli Ushasri w/o Mohana Rao,
who is resident of Perumali Village, Rajam Mandal, Srikakulam district,
and who is temporarily residing at Srungavarapukota villag,
Vizianagaram district, and where her husband Palli Mohana Rao
working as contract lecturer in Government Degree College, S. Kota. I
further submit that originally her birth plaice is Ammapalem village, S.
Kota Mandal, and at about six years back she was given in marriage to
Palli Mohana Rao, who is resident of Perumali village, of Srikakulam
district and where her in laws families are residing.
I further submit that suppressing the above facts, she approached
your Authority vide complaint No: 5599/2013/B1/Lok/1/2013
requesting your Authority to give directions to Project Director, I.C.D.S,
Vizianagaram cosidaring her name for the post of Anganavadi worker
( Karya Kartha) as if she is the permanent resident of Ammapalem
village, S. kota Mandal, considering her complaint your Honourable
Authority issued directions vide letter bearing No:
5599/2013/B1/Lok/1/2013 to the Project Director, I.C.D.S,
Vizianagaram to appoint the said P. Ushasri w/o Mohana Rao as a
Anganavadi worker (Karya Kartha) for the village of Ammapalem,
(Mulaboddavara Panchayat) on a temporary basis and in which your
Honour has further stated that subsequent to her appointment that if in
found that any wrong information and fake documents are submitted by
the said P. Ushasri, her appointment will be terminated with out giving
any prior notice, and further directed to launch criminal action against
her.
It is further submit that basing on the directions vide letter No:
5599/2013/B1/Lok/1/2013, dated: 02-01-2014, the Project Director,
I.C.D.S. Vizianagaram temporarily appointed the said Palli Ushasri w/o
Mohana Rao as an Anganavadi worker (Karya Kartha) for the village of
Ammapalem, (Mulaboddavara Panchayat) S. Kota Mandal,
Vizianagaram district.
1. Under instruction from my client Sri. Tummupalli Appa Rao S/o Ramulu,
resident of Kotha Duppada, Vizianagaram, I am giving you the reply notice to your
notice dated 05-06-2015 issued on behalf of Vankara Ramanamma w/o Adi of
Kanapaka, Vizianagaram, as here under:-
2. The allegations made in your notice that my client had borrowed an amount
of Rs.3,00,000/- from your client on 08-06-2014 and executed a demand
promissory note , and agreed to return with interest at the rate of Rs.24% P.A. on
demand either to your client or to her order, and repeated demands made by your
client, my client issued cheque bearing No: 696966 dated 28-05-2015 for
Rs:3,00,000/-of Andhra Bank, Cantonment, Vizianagaram, drawn in favour of
your client towards pracial of the principal and interest due under the above said
promissory note and my client assure that sufficient amounts are kept in his
account and believing the same your client presented the said cheque for collection
through her banker Allahabad Bank, Vizianagaram on 28-06-2015 and the said
cheque was returned unpaid with an endorsement “FUNDS INSUFFICIENT” vide
memo dated; 01-06-2015 of your client’s Bank, and at the time issuing of cheque
my client assured to your client that he would maintain sufficient funds in his
account to meet the cheque amount, but proved otherwise, thus my client is bound
to pay the aforesaid cheque amount and in default my client is libel for the criminal
actions for the offence under section 138 &142 of N. I. Act, etc,. are all absolutely
false and invented by your client for the purpose of your notice.
My client state that my client has no acquaintance with your client and he
never seen your client, and he is an employee in S C society, Vizianagaram and he
has no necessity to borrow such huge amount of Rs.3,00,000/-from your client, and
further state that your client never meet my client to lend amount due under the
alleged promissory note and my client never issued any cheque to your client as
stated in your notice, as such my client is not liable to pay any amount as
demanded in your notice.
My client further states that at about three years bake he had borrowed an
amount of Rs. 50,000/- from one Sankara Rao who is working as APSP constable
in Vizianagaram, at the time of borrowing of said amount the said Sankara Rao
received two blank cheques from my client, My client further states that he might
have issued this notice in the name of your client with all false allegations.
Therefore please advise your client to send a Xerox copy of the alleged
pronote to my client so as to enable my client to send proper reply after going
through the same.
This is therefore request you to advise your client not to embark on any
useless and vexatious litigation and in spite of this reply, if he proceeds further, it
will be at his own risk and peril and your client will also liable to pay the expenses
to be incurred by my client in defending the case.
A D V O C A T E.
B. NARISIMHA MURTHY A, B.L,. Station:- Vizianagaram,
ADVOCATE, Date:- 26-11-2013
H.No:8-32-228, KOTHAMAJJIPETA.
V. T. AGRAHARAM,
VIZIANAGARAM-535 003, Ph No: 9440891511.
To,
THE DIVISINAL ENGINEER,
A. P. HOUSEING CORPORATION,
GAJAPATHINAGARAM DIVISION,
VIZIANAGARAM DIST.
Sir,
Sub:- Suit filed by Varri Narasimham against Somu Laxmana and two
others in O.S. No: 286/2013 for granting permanent injunction on the
file of the Principal Junior Civil Judge at Vizianagaram, in I.A
No:999/2013 field and granted Temporary Injunction in respect of the
suit schedule property – Regd:---
In this connection I request you not to sanction any type of loan to the
defendants and their men in the above suit in respect of the land in survey
No;98/2 of Madanapuram Village, in case if the defendants approached for
sanction of loan by your department for constriction of house.
Yours faithfully