IN THE COURT OF FIFTH ADDL DISTRICT JUDGE AT RAYACHOTY

E.P No.25/2018
In
O.S No. 9/2014
Vankiripalli Chinna Hussain … Petitioner
Vs.
1. Shaik Nissar Ahammad
2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan … Respondents
CHIEF-EXAMINATION AFFIDAVIT OF RW-1 (SECOND
RESPONDENTs FILED ON BEHALF OF THE RESPONDENTS U/O
18 RULE 4 (1) OF C.P.C
I, Shaik Ghouse Mohidin, S/o. Shaik Mohaboob Sahed, Aged
about 65 years, Senior citizen, Muslim, Business, residing in the house
bearing door No:-65/16, Nayab sab Street, Rayachoty Town post and
Mandal, Kadapa District, Do hereby solemnly affirm and state as
follows:-

1. I am the second respondent in E.P no.25/2018 and

second defendant in O.S no.9/2014.

2. The petitioner field this EP No.25/2018 for realization of

Rs.47,24,910/-. We the respondents have no cash of Rs.
Rs.47,24,910/- with us for paying to the petitioner. The petitioner
knows pretty well that we the respondents have no capacity or
sufficient means to pay Rs.47,24,910/- to the petitioner. The
advocate for the petitioner gave legal notice dated 17-01-2018 for
the EP amount. Our advocate gave reply notice on 27-01-2018 to
the counsel of the petitioner by stating that we have no capacity
and means to pay the EP amount to the petitioner and requested
the petitioner to take some extent property from the property that
we are going to get from the respondents in EP No.9/2018 in O.S
No.1/2014 on the file of this Honourable court.
 :: 2 ::

3. We got registered sale Ex. A-1 to the extent of Acs 2.46 in

S.No.430/1 towards our EP No.9/2018 amount of Rs.2,58,83,000/-
from the respondents in E.P No.9/2018 for discharge of EP
No.9/2018 amount of Rs.2,58,83,000/- of us.

4. We the respondents are ready and willing to execute sale

deed in favour of the petitioner to the extent of 17 ½ sarams of
house site out of Acs 2.46 in S.No.430/1 for discharge of the E.P
amount as we have taken registered sale deed Ex.A-1 for Acs.2.46
for discharge for EP No.9/2018 amount Rs.2,58,83,000/-. In fact we
are unable to discharge EP No.25/2018 amount by paying cash since
we have no cash or means to pay to the petitioner.

5. The petitioner filed false affidavit for defaming and black

mailing us. This EP is not maintainable and liable to be dismissed for
detaining us in civil prison since we have no means to discharge the
EP amount of the petitioner. I am aged about 65 years and that I am
a senior citizen and that I am not liable for arrest and detention as
per principle of law in force.

6. THE FOLLOWING DOCUMENTS MY KINDLY BE

MARKED ON OUR BEHALF OF EX. B-1 TO B-4:

1. Ex.B-1 is served copy of legal notice dated 17-01-2018 issued

by the advocate of the petitioner to the respondents.
2. Ex.B-2 is office copy of the reply notice dated 17-01-2018
issued on behalf of the respondents to the advocate for the
petitioner.
3. Ex.B-3 is postal receipt dated 27-01-2018 addressed to the
advocate of the petitioner.
4. Ex.B-4 is postal acknowledgement dated 03-02-2018 signed by
the counsel of the petitioner.
 :: 3 ::

7. PRAYER: Therefore I pray that the Honourable court may be

pleased to dismiss this EP in the interest of justice

Solemnly affirmed and signed before me on 28th day of December 2018

at Kadapa

Advocate

LIST OF DOCUMENTS FILED:

1. Served copy of legal notice dated 17-01-2018 issued by the

advocate of the petitioner to the respondents.
2. Office copy of the reply notice dated 17-01-2018 issued on
behalf of the respondents to the advocate for the petitioner.
3. Postal receipt dated 27-01-2018 addressed toa the advocate of
the petitioner.
4. Postal acknowledgement dated 03-02-2018 signed by the
counsel of the petitioner.

Filed by me

Advocate for the respondents

 IN THE COURT OF FIFTH ADDL
DISTRICT JUDGE AT RAYACHOTY

E.P No.25/2018
In
O.S No. 9/2014
Vankiripalli Chinna Hussain
… Petitioner
Vs.

1. Shaik Nissar Ahammad

2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan

… Respondents

CHIEF-EXAMINATION
AFFIDAVIT OF RW-1 (SECOND
RESPONDENTs FILED ON
BEHALF OF THE RESPONDENTS
U/O 18 RULE 4 (1) OF C.P.C

Filed by:

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

Advocate for the respondents,
Kadapa
IN THE COURT OF FIFTH ADDL DISTRICT JUDGE AT RAYACHOTY
E.P No.26/2018
In
O.S No. 10/2014
1. Veeraballi Mallikarjuna
2. Vankiriaplli Rizwan basha
3. Syed Sadaq Ali … Petitioners
Vs.
1. Shaik Nissar Ahammad
2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan … Respondents
CHIEF-EXAMINATION AFFIDAVIT OF RW-1 (SECOND
RESPONDENTs FILED ON BEHALF OF THE RESPONDENTS U/O
18 RULE 4 (1) OF C.P.C
I, Shaik Ghouse Mohidin, S/o. Shaik Mohaboob Sahed, Aged
about 65 years, Senior citizen, Muslim, Business, residing in the house
bearing door No:-65/16, Nayab sab Street, Rayachoty Town post and
Mandal, Kadapa District, Do hereby solemnly affirm and state as
follows:-

1. I am the second respondent in E.P No.26/2018 and

second defendant in O.S No.10/2014.

2. The petitioner field this EP No.26/2018 for realization of

Rs.21,72,885/- from us. We the respondents have no cash or
sufficient means to discharge that E.P amount. We are ready to
execute sale deed in favour of the petitioners to the extent of 8 ¾
sarams in S.No 430/1 out Acs 2.46 for discharge of this E.P amount
as we got Acs 2.46 in S.No.430/1 for discharging our E.P No.9/2018
amount of Rs.2,58,83,000/- .
3. We the respondents have no cash of Rs.21,72,885/- with
us for paying to the petitioner. The petitioner knows pretty well that
we the respondents have no capacity or sufficient means to pay
Rs.21,72,885/- to the petitioners. The advocate for the petitioners
gave legal notice dated 17-01-2018 for the EP amount. Our
advocate gave reply notice on 27-01-2018 to the counsel of the
 :: 2 ::

petitioners by stating that we have no capacity and means to pay

the EP amount to the petitioner and requested the petitioners to
take some extent property from the property that we are going to
get from the respondents in EP No.9/2018 in O.S No.1/2014 on the
file of this Honourable court.
4. We got registered sale Ex. A-1 to the extent of Acs 2.46 in
S.No.430/1 towards our EP No.9/2018 amount of Rs.2,58,83,000/-
from the respondents in E.P No.9/2018 for discharge of EP
No.9/2018 amount of Rs.2,58,83,000/- of us.

5. We the respondents are ready and willing to execute sale

deed in favour of the petitioners to the extent of 8 ¾ sarams of
house site out of Acs 2.46 in S.No.430/1 for discharge of the E.P
amount as we have taken registered sale deed Ex.A-1 for Acs.2.46
for discharge of our EP No.9/2018 amount Rs.2,58,83,000/-. In fact
we are unable to discharge EP No.26/2018 amount by paying cash
since we have no cash or means to pay to the petitioners.

6. The petitioners filed false affidavit for defaming and black

mailing us. This EP is not maintainable and liable to be dismissed for
detaining us in civil prison since we have no means to discharge the
EP amount of the petitioners. I am aged about 65 years and that I am
a senior citizen and that I am not liable for arrest and detention as
per principle of law in force.

7. PRAYER: Therefore I pray that the Honourable court may be

pleased to dismiss this EP in the interest of justice

Solemnly affirmed and signed before me on 28th day of December 2018

at Kadapa

Advocate
 IN THE COURT OF FIFTH ADDL
DISTRICT JUDGE AT RAYACHOTY
E.P No.26/2018
In
O.S No. 10/2014
1. Veeraballi Mallikarjuna
2. Vankiriaplli Rizwan basha
3. Syed Sadaq Ali
… Petitioners
Vs.

1. Shaik Nissar Ahammad

2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan

… Respondents

CHIEF-EXAMINATION
AFFIDAVIT OF RW-1 (SECOND
RESPONDENTs FILED ON
BEHALF OF THE RESPONDENTS
U/O 18 RULE 4 (1) OF C.P.C

Filed by:

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

Advocate for the respondents,
Kadapa
IN THE COURT OF FIFTH ADDL DISTRICT JUDGE AT RAYACHOTY
E.A No. /2018
In
E.P No.25/2018
In
O.S No. 9/2014
1. Shaik Nissar Ahammad
2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan … Petitioners
Vs.
Vankiripalli Chinna Hussain … Respondent
AFFIDAVIT
I, Shaik Ghouse Mohidin, S/o. Shaik Mohaboob Sahed, Aged about
65 years, Senior citizen, Muslim, Business, residing in the house bearing
door No:-65/16, Nayab sab Street, Rayachoty Town post and Mandal,
Kadapa District, Do hereby solemnly affirm and state as follows:-

1. I am the second petitioner in E.P no.25/2018 and second

defendant in O.S no.9/2014.

2. The respondents field this E.P against us. We could not file
the documents mentioned in the petition since we could not trace those
documents at the time of filing our counter. The said documents are
necessary and material evidence for proving our case against the decree
holders. The delay may kindly be condoned for not filing those document
at the time of filing our courter.
3. The said documents are material document for establishing
our case against the D.Hrs.
4. Therefore I pray that the Honorable court was pleased to
receive the following documents for marking on our behalf in E.P
NO.25/2018 in O.S No.9/2014 in the interest of justice. Otherwise we will
suffer from irreparable loss and injustice.

Solemnly affirmed and signed before me on 28th day of December

2018 at Kadapa

Advocate
IN THE COURT OF FIFTH ADDL DISTRICT JUDGE AT RAYACHOTY
EA NO. /2018
In
E.P No.25/2018
In
O.S No. 9/2014
1. Shaik Nissar Ahammad, S/o Abdula Gafoor, aged about
65 years, Muslim, Business, resident of D.No.13/97,
Near Mahammadpura Mazid, Kothappli, Rayacoty town,
Post and Mandal, Kadapa district
2. Shaik Ghouse Mohiddin, S/o Mohabbob Saheb, aged 62
Years, Muslim, Business, resident D.No. 65/16, Nayab
Saheb Street, Gandhi Bazar, Rayachoty Town, Post and
Madal, Kadapa district.
3. Khayamkhni Tayubulla Khan, S/o. Azmathulla Khan,
Aged about 45 years muslim, Business, resident of
D.No.24/72, Trunk road, Rayachoty town, post
and Mandal, Kadapa district. …Petitioners/J.Drs
Vs.
Vankiripalli Chinna Hussain, S/o. Pakkir Sab, aged
about 59 years, Dudekula retired employee,
resident of door No.53/181A, Galiveedu road,
Kothapeta, Rayachoty town post & Mandal Kadapa dt. … Respondent/D.Hr
PETITIONERS FIELD ON BEHALF OF PETITIONERS
UNDER ORDER 8 RULE 1A (3) OF C.P.C
For the reasons stated in the accompanying affidavit that the
Honorable court was pleased to receive the following documents
for marking on behalf of the respondents(J.Drs) in E.P NO.25/2018
in O.S No.9/2014 in the interest of justice. Otherwise we will suffer
from irreparable loss and injustice.

ADVOCATE FOR THE PETITIONERS

LIST OF DOCUMENTS FILED:
1. Served copy of legal notice dated 17-01-2018 issued by the
advocate of the petitioner to the respondents.
2. Office copy of the reply notice dated 17-01-2018 issued on
behalf of the respondents to the advocate for the petitioner.
3. Postal receipt dated 27-01-2018 addressed to the advocate of
the petitioner.
4. Postal acknowledgement dated 03-02-2018 signed by the
counsel of the petitioner.

ADVOCATE FOR THE PETITIONERS

 IN THE COURT OF FIFTH ADDL
DISTRICT JUDGE AT RAYACHOTY
E.A No. /2018
In
E.P No.25/2018
In
O.S No. 9/2014
Vankiripalli Chinna Hussain
… Petitioner
Vs.

1. Shaik Nissar Ahammad

2. Shaik Ghouse Mohiddin
3. Khayam Khani Thyubulla Khan

… Respondents

PETITIONERS FIELD ON
BEHALF OF PETITIONERS
UNDER ORDER 8 RULE 1A (3)
OF C.P.C

Filed by:

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

Advocate for the petitioners,
Kadapa