IN THE COURT OF HONOURABLE PRIL DISTRICT JUDGE AT KADAPA

O.S No. 16/2015

Pilli Mahesh ... Plaintiff
Vs.
1. C. Sidda Reddy
2. C. Sujata …Defendants
CHIEF-EXAMINATION AFFIDAVIT OF D.W-1 (FIRST
DEFENDANT) FILED ON BEHALF DEFENDANTS UNDER
ORDER 18 RULE 4 (1) OF C.P.C.

I Chinthalapalle Sidda Reddy S/o Chinthalapalle Pedda Sidda

Reddy, aged about 40 years, Hindu, Sub-Engineer AP TRANSCO
current office at Sambepalli, Rayachoty Earst while Taluk, residing in
Nallaiahgaripalli village, Hamlet of Gondipalli, Pendlimarri Mandal,
Kadapa district, do hereby solemnly declare and state as follows:-

1. I am the deponent as DW-1 herein in this suit and that I

am the first defendant in this suit. The second defendant is my wife

2. The plaintiff filed this suit against us for declaration and

permanent injunction over the suit property. The plaintiff has no
right or title over the suit property and that the Tahsildar of Kadapa
did give possession certificate to plaintiff at any point of time.

3. The plaintiff is not a poor person. The plaintiff got 15

plots of house sites in Tilak Nagar in Chinnachowk area in Kadapa
City and sold those plots to so many persons for about 25 lakhs
starting from the year 2004 upto now. The wife of the plaintiff
named Smt.Manjuladevi is working as Junior Assistant in Housing
Board Corporation in Kadapa city. The wife of the plaintiff has been
helping to the plaintiff for grabbing 15 plots from the Government.
The plaintiff has become habitual grabber of Government house
sites by hook or crook and selling those plots to the needy persons
for large amount each cent worth about rupees one lakh. Thus the
plaintiff has been making large amounts of money by cheating the
public and Government with the active connivance and abetment of
his wife for making lakhs of rupees out of government house site.
 :: 2 ::

4. The Tahsildar of Kadapa gave Nivesa Stala Swadheena

Dhruveekarna Patram, in the name of my wife named Chintalapalle
Sujata on 20-08-2008 for 0.03 cents in plot No.81 S.No.392 in Tilak
Nagar, in Kadapa City pertaining to the suit schedule property. I and
my wife constructed two portions of house during 2012 year in the
name of my wife named Chintalapalle Sujata. The current meter was
fixed in my name, meter No.2111306119054, door No.37/1342 for
one portion of house and the other portion of the house meter was
fixed in the name of my wife (second defendant) named C. Sujata,
meter No.2111306119203 with door No.38/1342 for the suit
schedule property. We got video recording for Gruha Pravesa
Ceremony during 2013 year on 28-12-2013. We also printed Gruha
Pravesa invitation card for entering in to the suit house and
circulated that invitation card among our friends and relatives. We
took photos with regard to Gruha Pravesa ceremony with the friends
and relatives. We (defendants 1&2) spent about rupees fifteen lakhs
for constructions of two portions of house in the suit schedule
property. My self and my wife (second defendant) are the full-
fledged owners of the suit schedule property having two portions
house.

5. The plaintiff has no right or authority over the suit

schedule property. The plaintiff filed this false suit with cock and bull
pleadings for blackmailing us. The pleadings in the suit plaint are
totally false. The plaintiff did not construct suit house at any point of
time. We the defendants alone constructed the suit house during
2012 year and enjoying the suit house by leasing out to the tenants
from 2013 year upto now and that we are receiving the rents
Rs.3,500/- from the tenants for two portions of suit house.

6. The plaintiff is showing the plot of his wife as given to the

plaintiff. The family of the plaintiff was given one plot in the name of
wife of the plaintiff which is situated on the east of suit house of the
defendants. The plaintiff and his wife are not entitled to get two
house plots from the Government. The plaintiff was not given the
 :: 3 ::
plot No.81 by the Government. The plaintiff falsely shown the plot of
us as given to the plaintiff. The loan certificate is false and forged
one. The plaintiff did not spent even a single paise over the suit plot
No.81. The plaintiff spent his house loan amount on the plot allotted
to the wife of the plaintiff Smt.Manjuladevi which is situated on the
east of the suit house of us (defendants).

7. The plaintiff and his wife Smt.Manjuladevi are residing in

the house on the eastern side abutting to the suit house us. The
plaintiff did not file original possession certificate of suit property
plot No.81 in this suit since the Tahsildar of Kadapa did give
possession certificate for plat No.81 of suit property to the plaintiff.
We paid property tax to Kadapa Municipal Corporation towards the
suit house. We also got water taps connection to the suit house us.
We got electricity connection to the suit house. We the defendants
are paying property tax, water charges to the K.M.C in our name for
the suit house. We also paid electricity charges to the APSPDCL
regularly for the suit house of us.

8. The plaintiff is making alienation of Government sites by

executing various agreements in favour of so many persons by taking
lakhs of rupees from them. The plaintiff is liable to be prosecuted.
The plaintiff is practicing cheating for making wrongful gain by
cheating the innocent public and Government. I engaged Jelli
Chennayya S/o Nadipi Chennayya resident of Reddikottalu, in
Kasinayana Mandal, Badvel Taluk as Mason with five coolies for
supplying bricks and other material to the mason every day for the
construction my suit house during 2012 year. The Kadapa Municipal
Corporation assessed property tax of suit house in the name of my
wife Smt.Sujata who is second defendant with door No.37/1342-2-2-
1 since the possession certificate is in the name my wife (second
defendant). So my wife paid property tax and water tax to K.M.C
Kadapa to the suit house with the Door No.37-1342-2-2-1 regularly.
 :: 4 ::

9.THE FOLLOWING DOCKMENT MAY KINDLY BE MARKED

ON BEHALF OF THE DEFENDANTS AS EXBIT B-1 TO B-19:

1. EX. B-1 is possession Certificate dated 20-08-2008 issued in the

name of second defendant named Chintalapalle Sujata being the wife of
the first defendant by the Tahsildar of Kadapa.
2. EX. B-2 is Current charge demand notice of APSPDCL for meter
No.2111306119054 dated 20-12-2014 issued in the name of first
defendant for house No.37/1342-2-2-1 .
3. EX. B-3 is Current charges demand notice of APSPDCL for meter
No.2111306119203 dated 22-10-2014 door No.38/1342 in the name of
second defendant named C. Sujata being the wife of the first defendant.
4. EX. B-4 is property tax demand notice dated 23-10-2015 issued in
the name of second defendant for the suit house.
5. Ex.B-5 are six house tax receipts dated 24-07-2015 to 28-10-2015
issued in the name of second defendant by K.M.C for the suit house.
6. Ex. B-6 is proceeding’s dated 28-10-2015 issued by the commoner
of K.M.C for sanctioning water tap connecting to the suit house
7. Ex. B-7 are sixteen electricity demand notices issued in the name of
second defendant for the suit house.
8. Ex. B-8 are five electricity demand notice issued in the name of first
defendant for the suit house.
9. Ex. B-9 is the original property tax receipt dated 16-11-2018 for
paying Rs.2804/- for the suit house issued in the name of second
defendant.
10. Ex. B-10 is the original water tax receipt dated 16-11-2018 for
paying Rs.4200/- to the suit house by the second defendant.
11. Ex. B-11 is office copy Nutana Gruha Pravesha Ahvana Patrika dated
28-12-2013 relating to the suit house of the defendants.
12. Ex. B-12 are eight color photos taken on 28-12-2013 at suit house
at the time of Gruha Pravesham and Styanaraya Vratam.
13. Ex. B-13 is D.V.D having video coverage of the suit house at time of
Gruha Pravesham and Styanarana Vratam.
14. Ex. B-13 is property tax demand bills dated 24-04-2016 issued in
the name of D-2 for paying Rs.1348/- to the suit house.
15. Ex. B-15 is property tax receipt dated 31-03-2017 issued in the
name of D-2 for suit house.
 :: 5 ::
16. Ex.B-16 are eight electricity demand notices issued in the name of
D-2 for the suit house.
17. Ex. B-17 are five electricity receipts issued in the name of D-2 for
the suit house.
18. Ex. B-18 are twelve electricity demand notices issued in the name
of first defendant for the suit house.
19. Ex. B-19 are six electricity receipts issued in the name of the first
defendant for suit house.

10. Prayer: Therefore I pray that the Honourable court may be

pleased to dismiss the suit of the plaintiff with exemplary costs in the
interest of justice

Solemnly affirmed and signed before me on 19th day of

November, 2018 at Kadapa.

Filed by me Advocate

Advocate for the defendants

IN THE COURT OF HONOURABLE
PRIL DISTRICT JUDGE AT KADAPA

O.S No. 16/2015

Pilli Mahesh
... Plaintiff
Vs.

1. C. Sidda Reddy
2. C. Sujata
…Defendants

CHIEF-EXAMINATION
AFFIDAVIT OF D.W-1 (FIRST
DEFENDANT) FILED ON
BEHALF DEFENDANTS UNDER
ORDER 18 RULE 4 (1) OF C.P.C.

Filed by:

Sri. K. Venkata Reddy, B.Com., B.L.,

Advocate for the defendants,
Kadapa city.
IN THE COURT OF HONOURABLE PRIL DISTRICT JUDGE AT KADAPA
I.A No. /2018
In
O.S No. 16/2015
1. C. Sidda Reddy
2. C. Sujata … Petitioners/Defendants
Vs.
Pilli Mahesh ... Respondent/Plaintiff
AFFIDAVIT
I Chinthalapalle Sidda Reddy S/o Chinthalapalle Pedda Sidda
Reddy, aged about 40 years, Hindu, Sub-Engineer AP TRANSCO
current office at Sambepalli, Rayachoty Earst while Taluk, residing in
Nallaiahgaripalli village, Hamlet of Gondipalli, Pendlimarri Mandal,
Kadapa district, do hereby solemnly declare and state as follows:-
1. I am the first petitioner herein. The second petitioner is
my wife and that we are defendants in this suit. So I am filing this
petition on our behalf.

2. I humbly submit that suit is posted for our evidence. We

could not get the original records at the time filing our statement in
the Honourable court. We got the following document recently for
the purpose of filing in this suit as evidence for proving our defence.
We could not get the following documents at the time of filing our
written statement. So we are filing the following document now as
our evidence and that there is necessity to receive those documents
for marking on our behalf. We will suffer loss and injustice if our
documents are not received.

3. Therefore I pray that the Honourable court may be pleased

grant leave to us for receiving the following documents of us as
evidence for making in this suit in the intense of justice.

Solemnly affirmed and signed before me on 19th day of

November, 2018 at Kadapa.

Advocate
IN THE COURT OF HONOURABLE PRIL DISTRICT JUDGE AT KADAPA
I.A No. /2018
In
O.S No. 16/2015
1. Chinthalapalle Sidda Reddy S/o
Chinthalapalle Pedda Sidda Reddy, aged about 40 years,
Hindu, Sub-Engineer AP TRANSCO current office at
Sambepalli, Rayachoty Earst while Taluk, residing in
Nallaiahgaripalli village, Hamlet of Gondipalli,
Pendlimarri Mandal, Kadapa district
2. Chinthalapalle Sujata W/o. Chinthalapalle Sidda Reddy
aged about 35 years, Hindu, House wife,
residing in Nallaiahgaripalli village, Hamlet of Gondipalli,
Pendlimarri Mandal, Kadapa district
… Petitioners/Defendants
Vs.
Pilli Mahesh S/o Pilli Lakshanna, Hindu, aged about 48 years,
Un-employee, residing D.No.2-13-42-G, Chelamareddyalle,
H/o Chinna Chowk, Kadapa city ... Respondent/Plaintiff

PETITION FILED ON BEHALF OF THE PETITIONERS U/O 8

RULE 1-A (3) OF C.P.C

For the respond stated in the accompanying affidavit that the

Honourable court may be pleased grant leave for receiving the
following documents of the petitioner as evidence for making in this
suit in on behalf of the defendants in the intense of justice.

ADVOCATE FOR THE PETITIONERS

LIST OF DOCKMENT FILED:

1. The original property tax receipt dated 16-11-2018 for paying

Rs.2804/- for the suit house issued in the name of second
defendant.
2. The original water tax receipt dated 16-11-2018 for paying
Rs.4200/- to the suit house by the second defendant.
 :: 2 ::

3. The office copy Nutana Gruha Pravesha Ahvana Patrika dated

28-12-2013 relating to the suit house of the defendants.
4. The eight color photos taken on 28-12-2013 at suit house at
the time of Gruha Pravesham and Styanaraya Vratam.
5. The D.V.D having video coverage of the suit house at time of
Gruha Pravesham and Styanarana Vratam.
6. The property tax demand bills dated 24-04-2016 issued in the
name of D-2 for paying Rs.1348/- to the suit house.
7. The property tax receipt dated 31-03-2017 issued in the name
of D-2 for suit house.
8. The eight electricity demand notices issued in the name of D-2
for the suit house.
9. The five electricity receipts issued in the name of D-2 for the
suit house.
10. The twelve electricity demand notices issued in the name
of first defendant for the suit house.
11. The six electricity receipts issued in the name of the first
defendant for suit house.

ADVOCATE FOR THE PETITIONERS

IN THE COURT OF HONOURABLE
PRIL DISTRICT JUDGE AT KADAPA

I.A No. /2018

In
O.S No. 16/2015
1. C. Sidda Reddy
2. C. Sujata
… Petitioners/Defendants

Vs.

Pilli Mahesh
... Respondent/Plaintiff

PETITION FILED ON BEHALF

OF THE PETITIONERS U/O 8
RULE 1-A (3) OF C.P.C

Filed by:

Sri. K. Venkata Reddy, B.Com., B.L.,

Advocate for the petitioners,
Kadapa city.