Duddela Balakrishna, B.A., B.L.

,
,
ADVOCATE, ,

Tirupati – 517 501.

_____________________________________________________________________________________________________

Dated: 27-12-2017

To

Sri P.Murali, B.A., B.L.,

Advocate,
D.No.8-3-M22/240,
Prakasam Road,
Near Mahathi Auditorium,
Tirupati,
Chittoor District.

Sir,

Under instructions from my client Smt. D.Visalakshi, W/o late

D.Ramanaiah, residing at D.No.20-2-472/6D, Korlagunta, Maruthi
Nagar, Tirupati, I give you the following Reply to your notice, dated
13-12-2017 issued on behalf of your client Sri G.Subba Rao, S/o
G.Srinivasulu, residing at Flat No.403, Hillon Towers, Sivajyothi Nagar,
Tirupati, Chittoor District..

1. My client does not admit any of the allegations in your notice

except those that are specifically admitted herein. Your client is put to
strict proof of the same.

2. The allegations in para 1 of your notice that your client has

borrowed a sum of Rs.3,00,000/- from my client for his urgent
necessities on 1-10-2016 and executed three different blank signed
demand promissory notes of Rs.1,00,000/- each on the same day for
easy repayment of the above debt are not true and correct. Your client is
put to strict proof of the same.

3. The allegations in para 2 of your notice that after due negotiatons,

he has cleared the above said debt along with interest amounting to
Rs.4,00,000/- towards full and final settlement of the same vide four
separate Demand Drafts in favour of my client and at the time of
repayment of the above said amount, my client assured your client that
he will return the said three different blank signed demand promissory
notes, dated 1-10-2016 of Rs.1,00,000/- which was given by my client at
the time of borrowal as the same has been misplaced somewhere in my
client’s house, for which your client believed my client’s version

2. My client states that No.2 of you have preferred a Revision in

R.P.No.186/83(H1) challenging the said orders of Assistant Settlement
Officer before Director of Settlement and the same was dismissed on
30-9-1999. Then No.2 of you again preferred Revision in P3/1639/99
challenging the said orders of D.S.O. before Commissioner of Appeals
and the same was dismissed by the Commissioner of Appeals on 18-12-
2001.

3. My client states that No.2 of you have filed a Writ in

W.P.No.22868/2002 in Hon’ble High Court of Judicature A.P.
challenging the said orders of the Commissioner of Appeals. My
P.T.O.

:: 2 ::

client and others filed another Writ in W.P.No.22656/2002 against the

Government of A.P., District Collector, Tahsildar of Tirupati Urban
Mandal for implementation of Ryotwari Patta granted by Assistant
Settlement Officer, Nellore, which has been confirmed by Director of
Settlement and Commissioner of Appeals in Revenue Records. The
Hon’ble High Court of A.P. dismissed the W.P.No.22868/2002 filed by
the Tahsildar conforming the Ryotwari Patta granted by the Assistant
Settlement Officer, Nellore and allowed my client’s Writ in
W.P.No.22656/2002 directing the Government to implement the orders
passed by the Assistant Settlement Officer, Nellore granting Ryotwari
Patta in favour my client and others in respect of Ac.23-83 cents in
S.No.46 of Akkarampalli Village. The said orders passed on 8-8-2005.

4. My client states that No.2 of you has filed a Writ Appeal in W.A.No.
1817 /2005 on the file of A.P. High Court challenging the orders passed
in the said Writ petitions. The said Writ Appeal was allowed. Then my
client and others have challenged the orders passed in the said Writ
Appeal in Supreme Court by filing Special Leave Petition (c) 14140-
14143/2014. The Hon’ble Supreme Court of India has taken up the said
appeal and sent notices to you and also passed an order directing both
the parties to maintain Status Quo with regard to possession prevailing
as on the date of filing of the Special Leave Petition. The said matter is
pending disposal in Supreme Court. The said Status Quo order is in
force.

5. My client states that he has seen a news item in Eenadu Daily

Chittoor District Edition, dated 18-6-2015 and Saakshi Daily Chittoor
District Edition, dated 18-6-2015 that you are going to deliver the land in
S.No.46, Akkarampalli Village accounts which is locally called
Poolavanigunta in favour of Tirumala-Tirupati Devasthanams for
development of Park and other purposes. As the said land is in dispute
between my client and you which is pending in the said Special Leave
Petition in Supreme Court you have no right to deliver possession of the
same to Tirumala-Tirupati Devasthanams and if you deliver the
possession of the same to Tirumala-Tirupati Devasthanams it will
amounts to contempt of court and my client will take appropriate steps
P.T.O.

:: 3 ::

against you in Supreme Court for committing Contempt of Court. I am

also herewith enclosing zerox copy of the orders passed by the Supreme
Court in the said Special Leave Petition for your perusal.

6. I, therefore, on behalf of the my client do hereby call upon you not

to deliver possession of the said land in favour of Tirumala-Tirupati
Devasthanams, violating the orders passed in the said Special Leave
Petition by the Supreme Court, as otherwise my client will take
appropriate steps against you for taking penal action against you for
committing contempt of Court.

ADVOCATE
 0877-2225813

P.Prabhakara Naidu, B.Sc.,B.L.,

D.No.13-6-581,
ADVOCATE, Peddakapu
Layout,

Tirupati – 517 501.

_____________________________________________________________________________________________________

Dated: 28-9-2015

To

1. The Executive Officer,

Tirumala-Tirupati Devasthanams,
T.T.D. Administrative Building,
TIRUPATI.

2. The District Collector,

CHITTOOR.

3. The Revenue Divisional Officer,

TIRUPATI.

4. The Tahsildar,
Tirupati Urban Mandal,
TIRUPATI.

Sirs,

Under instructions from my clients Sri D.R.Venkatadri Reddy, S/o

late D.Rami Reddy, residing at D.No.34/2, Khadhi Colony, Tirupati, I
give you the following:-
NOTICE
1. My client states that he and others have filed a petition in
S.R.No.65/ 11(a)/1981, Chittoor before Assistant Settlement Officer,
Nellore for grant of Ryotwari Patta to an extent of Ac.23-83 cents of land
situated in S.No.46 in Akkarampalli Village accounts, Tirupati Urban
Mandal previously Chandragiri Taluk which absolutely belonged to them.
After due enquiry and after hot contest the said petition was allowed on
25-10-1982 granting Ryotwari Patta in favour of my client and others for
the said land.

2. My client states that No.4 of you have preferred a Revision in

R.P.No.186/83(H1) challenging the said orders of Assistant Settlement
Officer before Director of Settlement and the same was dismissed on
30-9-1999. Then No.4 of you again preferred Revision in P3/1639/99
challenging the said orders of D.S.O. before Commissioner of Appeals
and the same was dismissed by the Commissioner of Appeals on 18-12-
2001.
P.T.O.

:: 2 ::

3. My client states that No.4 of you have filed a Writ in

W.P.No.22868/2002 in Hon’ble High Court of Judicature A.P.
challenging the said orders of the Commissioner of Appeals. My client
and others filed another Writ in W.P.No.22656/2002 against the
Government of A.P., District Collector, Tahsildar of Tirupati Urban
Mandal for implementation of Ryotwari Patta granted by Assistant
Settlement Officer, Nellore, which has been confirmed by Director of
Settlement and Commissioner of Appeals in Revenue Records. The
Hon’ble High Court of A.P. dismissed the W.P.No.22868/2002 filed by
the Tahsildar conforming the Ryotwari Patta granted by the Assistant
Settlement Officer, Nellore and allowed my client’s Writ in
W.P.No.22656/2002 directing the Government to implement the orders
passed by the Assistant Settlement Officer, Nellore granting Ryotwari
Patta in favour my client and others in respect of Ac.23-83 cents in
S.No.46 of Akkarampalli Village. The said orders passed on 8-8-2005.

4. My client states that No.4 of you has filed a Writ Appeal in W.A.No.
1817 /2005 on the file of A.P. High Court challenging the orders passed
in the said Writ petitions. The said Writ Appeal was allowed. Then my
client and others have challenged the orders passed in the said Writ
Appeal in Supreme Court by filing Special Leave Petition (c) 14140-
14143/2014. The Hon’ble Supreme Court of India has taken up the said
appeal and sent notices to you and also passed an order directing both
the parties to maintain Status Quo with regard to possession prevailing
as on the date of filing of the Special Leave Petition. The said matter is
pending disposal in Supreme Court. The said Status Quo order is in
force.

5. My client states that he has seen a news item in Eenadu Daily

Chittoor District Edition, dated 18-6-2015 and 8-9-2015 are going to
deliver the land in S.No.46, Akkarampalli Village accounts which is
locally called Poolavanigunta in favour of Tirumala-Tirupati
Devasthanams for development of Park and other purposes. As the said
land is in dispute between my client and revenue department which is
pending in the said Special Leave Petition in Supreme Court you have no
P.T.O.

:: 3 ::

right to deliver possession of the same to Tirumala-Tirupati

Devasthanams and if you deliver the possession of the same to Tirumala-
Tirupati Devasthanams it will amounts to contempt of court and my
client will take appropriate steps against you in Supreme Court for
committing Contempt of Court. I am also herewith enclosing zerox copy
of the orders passed by the Supreme Court in the said Special Leave
Petition for your perusal.

6. I, therefore, on behalf of the my client do hereby call upon you not

to deliver possession of the said land in favour of Tirumala-Tirupati
Devasthanams, violating the orders passed in the said Special Leave
Petition by the Supreme Court, as otherwise my client will take
appropriate steps against you for taking penal action against you for
committing contempt of Court.

ADVOCATE
 0877-2225813

P.Prabhakara Naidu, B.Sc.,B.L.,

D.No.13-6-581,
ADVOCATE, Peddakapu
Layout,

Tirupati – 517 501.

_____________________________________________________________________________________________________

Dated: 27-10-2015

To

1. The Executive Officer,

Tirumala-Tirupati Devasthanams,
T.T.D. Administrative Building,
TIRUPATI.
2. The District Collector,
CHITTOOR.
3. The Revenue Divisional Officer,
TIRUPATI.
4. The Tahsildar,
Tirupati Urban Mandal,
TIRUPATI.
5. The Vice-Chairman,
Tirupati Urban Development Authority(TUDA),
TIRUPATI.
6. The Commissioner,
Tirupati Municipal Corporation,
TIRUPATI.
7. The Divisional Forest Officer,
Tirumala-Tirupati Devasthanams,
Harerama Harekrishna Road,
TIRUPATI.

Sirs,

Under instructions from my clients Sri D.R.Venkatadri Reddy, S/o

late D.Rami Reddy, residing at D.No.34/2, Khadhi Colony, Tirupati, I
give you the following:-
NOTICE
1. My client states that he and others have filed a petition in
S.R.No.65/ 11(a)/1981, Chittoor before Assistant Settlement Officer,
Nellore for grant of Ryotwari Patta to an extent of Ac.23-83 cents of land
situated in S.No.46 in Akkarampalli Village accounts, Tirupati Urban
Mandal previously Chandragiri Taluk which absolutely belonged to them.
After due enquiry and after hot contest the said petition was allowed on
25-10-1982 granting Ryotwari Patta in favour of my client and others for
the said land.
P.T.O.

:: 2 ::

2. My client states that No.4 of you have preferred a Revision in

R.P.No.186/83(H1) challenging the said orders of Assistant Settlement
Officer before Director of Settlement and the same was dismissed on
30-9-1999. Then No.4 of you again preferred Revision in P3/1639/99
challenging the said orders of D.S.O. before Commissioner of Appeals
and the same was dismissed by the Commissioner of Appeals on 18-12-
2001.

3. My client states that No.4 of you have filed a Writ in

W.P.No.22868/2002 in Hon’ble High Court of Judicature A.P.
challenging the said orders of the Commissioner of Appeals. My client
and others filed another Writ in W.P.No.22656/2002 against the
Government of A.P., District Collector, Tahsildar of Tirupati Urban
Mandal for implementation of Ryotwari Patta granted by Assistant
Settlement Officer, Nellore, which has been confirmed by Director of
Settlement and Commissioner of Appeals in Revenue Records. The
Hon’ble High Court of A.P. dismissed the W.P.No.22868/2002 filed by
the Tahsildar conforming the Ryotwari Patta granted by the Assistant
Settlement Officer, Nellore and allowed my client’s Writ in
W.P.No.22656/2002 directing the Government to implement the orders
passed by the Assistant Settlement Officer, Nellore granting Ryotwari
Patta in favour my client and others in respect of Ac.23-83 cents in
S.No.46 of Akkarampalli Village. The said orders passed on 8-8-2005.

4. My client states that No.4 of you has filed a Writ Appeal in W.A.No.
1817 /2005 on the file of A.P. High Court challenging the orders passed
in the said Writ petitions. The said Writ Appeal was allowed. Then my
client and others have challenged the orders passed in the said Writ
Appeal in Supreme Court by filing Special Leave Petition (c) 14140-
14143/2014. The Hon’ble Supreme Court of India has taken up the said
appeal and sent notices to you and also passed an order directing both
the parties to maintain Status Quo with regard to possession prevailing
as on the date of filing of the Special Leave Petition. The said matter is
pending disposal in Supreme Court. The said Status Quo order is in
force.

P.T.O.

:: 3 ::

5. My client states that he has seen a news item in Eenadu Daily

Chittoor District Edition, dated 18-6-2015 and 8-9-2015 are going to
deliver the land in S.No.46, Akkarampalli Village accounts which is
locally called Poolavanigunta in favour of Tirumala-Tirupati
Devasthanams for development of Park and other purposes. As the said
land is in dispute between my client and revenue department which is
pending in the said Special Leave Petition in Supreme Court you have no
right to deliver possession of the same to Tirumala-Tirupati
Devasthanams and if you deliver the possession of the same to Tirumala-
Tirupati Devasthanams it will amount to contempt of court and my client
will take appropriate steps against you in Supreme Court for committing
Contempt of Court. I am also herewith enclosing zerox copy of the orders
passed by the Supreme Court in the said Special Leave Petition for your
perusal.

6. I, therefore, on behalf of my client do hereby call upon you not to

deliver possession of the said land in favour of Tirumala-Tirupati
Devasthanams, violating the orders passed in the said Special Leave
Petition by the Supreme Court, as otherwise my client will take
appropriate steps against you for taking penal action against you for
committing contempt of Court.

ADVOCATE