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6. It is submitted that in the above regard that we are also interested in the
right to relief in respect of the common fact of usage of the Plaint B Schedule property for
ingress and egress and the threat of obstruction that the 1st defendant is causing in the same. In
this regard it is submitted that we also wanted to join the proceedings of the suit in O.S. 252 of
2016, but due logistical issues we could not all do so, and hence this petition. I further submit
that they are several electricity poles affixed by the APSPDCL, Tirupati many years ago in due
recognition of the ingress and egress of the residents of the locality of the plaint B Schedule land
which the 1st defendant is trying to influence the removal of the same. In this regard it is
submitted that if the 1st Defendant is successful in his endeavour, we all would be put to great
loss and suffering. In view of all of the above, we pray that the Hon'ble Court may be pleased to
permit us to join as the plaintiffs along with the already existing plaintiffs.
7. I further submit that we are filing relevant documents to prima facie prove
our status as the residents of Siva Jyothi Nagar, and interested parties in the easement rights of
ingress and egress of the petition/Plaint B Schedule property, by reserving our rights to file
additional documents/evidence in order to prove our contentions.
8. It is submitted that in view of the common question of fact and law, and
relief from the same series of acts with regard to ingress and egress of the plaint B Schedule
property, we humbly pray that the Hon'ble Court may be pleased to permit us to join as the
plaintiffs along with the already existing plaintiffs or else, the petitioners/third parties herein
would be put to irreparable loss, hardship and damage, and would lead to multiplicity of
proceedings.
DEPONENT
Solemnly affirmed and signed before me at Tirupati on
09-10-2017 Advocate Attester