0.S No.

Iv of 2016
Between:
Buchireddigari Srinivasulu Reddy
...plaintiff
And
digari Shankar Reddy and another
...defendants AFFIDAVIT FILED ONBEHALF OF THE PLAINTIFF
I, Buchireddigari Srinivasulu Redcly S/O Late B.Rami Reddy, hindu, aged about
years, Cultivation, residing at D.No.D.No.1-24/1, Thandlam Village and post, Renigunta Mandal,
Chittoor district do hereby solemnly affirm and state as follows.
(1)
I am the plaintiff in the above suit and deponent herein. I know the facts of the above
case.
(2)
I submit that, I filed the above suit against the defendants for permanent injunction for the
plaint schedule property. The plaint and the: documents filed by me may be read as part and
parcel of this affidavit.
(3)
I begs to submit that, I am an agriculturist and having agricultural lands in Thandlam
Village and Post, Renigunta Mandal. I am also owning cows and doing milk vending business.
The first defendant is the father of the second defendant. The defendants are the nearest blood
relatives to me.
(4)
I further submits that, prior to the year 1996, the entire plaint schedule property is
covered with thorney bushes and covered it with big pits and it is not useful for the defendants.
The plaint schedule property is the adjacent property to me and it is convenient to me only. At
that juncture, I purchased the plaint schedule mentioned property for using it for keeping the
cattle and also to made hayric pendyal for storing the dry grass and also for construction of
lavatory and the bathroom.
,Aitr
I further submits that, On 18-08-1996 I purchased the plaint schedule property from the
(5)
first defendant for a sum of Rs.40,000/- and the first defendant was also delivered the possession
of the plaint schedule property to me on the same day. Eversince, the date of purchase, the I have
been in absolute and uninterrupted possession and enjoyment of the plaint schedule mentioned
property with absolute rights. The defendants are the nearest relatives to me. Hence, I could not
insisted the first defendant for execution of a registered sale deed in my favour. At the time of
purchase of the plaint schedule property, it was covered with a big pits and thorny bushes. After
the purchase, I have removed the thorney bushes and
dumped 100 trips of sand in the plaint schedule property for covering the pits in the plaint
ea De In nnri/.. I nianted the white rut ctnnec arntind the
Hence, I spent huge amounts for clearing the bushes and leveling the plaint schedule property
and also erecting the white cut stones around the plaint schedule property.
(6)
I further states that, immediately after the purchase of the plaint schedule property in the
year 1996, I laid down two pendyals in the plaint schedule property for keeping dry gross and put
the cattles in the plaint schedule property. I was also constructed a bathrooms and lavatory on the
western side of the aint schedule property in the year 1996 itself. This fact is
known to one and all including the defendants.
Aiir AA 141,
(7)
I further states that, there was a misunderstanding between myself and the defendants
since from the elections in the year 2014. Due to the said misunderstandings, taking the
advantage of non registration of the plaint ;chedule property from the first defendant, now the
defendants created a false stories to grab the plaint schedule property. The defendants and his
brothers colluded with each other and created a sham, nominal , collusive and fraudulent
documents to defeat and defraud my legitimat., rights . They have no right to do so and it is not

justified to do so. If, the defendants has created any documents those documents are not true and
correct and it is not binding on me. The defendants has no any legal right over the plaint schedule
property. The defendants has no right, title, interest, possession or enjoyment over the plaint
schedule property. On the other hand, I purchased the plaint schedule property by spending a
huge amounts from the defendants and also spent huge amounts for developing the plaint
schedule property. I have been in possession and enjoyment of the plaint schedule property for
more than statutory period. On the other hand the defendants never in possession and enjoyment
of the plaint schedule property since 1996.
(8)
I further states that, on 31-12-2015 the first defendant issued a legal notice to me with all
false allegations and in his notice he requested me to remove the hayric pendyal and lavatory
constructed in the plaint schedule mentioned property within three day and also requested me to
handover the vacant possession of the plaint schedule property. I also gave suitable reply on 1901-2016.
(9)
I further submits that, I am the owner of the house bearing No.1-24/1, Thandlam Village
and Post, Renigunt Mandal. I am paying the electricity consumption charges to the A.P.S.P.D.C.L
authorities regularly. My house is also assessed to the house tax vide assessment No.40. I am
also paying the house.tax regularly to the Thandlam Grampanchayat authorities.
(10) I further submits that, on the northern side of the plaint schedule property, there was a
channel. On the northern side of the plaint schedijleproperty the defendants have been
ESinrte fnr latiallincr thP rhannpl The defendants alcn trying to vacate ma frnm
(11) I further submits that, Since one week the defendants seriously trying to interfere with 6)
5:) 12,yg the plaint schedule property without any right or what so ever. Yesterday i.e on 31-032016 at .01,1 about 5.00 p.m the defendants along with their hench men came in to the plaint
schedule property high handedly and threatened me and tried to interfere in the plaint schedule
property. The defendants are also made galata and uttering me and my family members with
unfilthy language. They are also seriously tried to dispossess me from the plaint schedule
property. The neighbouring house owners and some other people was rescued me and resisted the
illegal and high handed acts of the defendants and their men. The defendants also warned me, if I
will not vacate the plaint schedule property, they once again come with more people and forcibly
vacate me from the plaint schedule property. The defendants has no respect for the law. They can
do their own ways. I have no capacity to stop the illegal and high handed acts of the defendants.
So, I suspect that, the defendants will take law in to their hands and vacate the premises within
no time.
(12) In the above said circumstances, I am obliged to file this suit for permanent injunction
restraining the defendants their men, agents, followers e.t.c from trespassing in to or in any way
interfering with my peaceful possession and enjoyment of the plaint schedule property.
(13) it is therefore prayed that the honourable court may be pleased to to grant exparte
temporary injunction restraining the defendants their men, agents, followers e.t.c from
tresspassing into or in any way interfering with my peaceful possession and enjoyment of the
petition schedule property by dispensing with prior plaint to the respondants/defendants and also
grant ad-interium reliefs to the like effect to be operative till the disposal of the petition. Else, i
will be put to serious loss and hardship.
DEPONENT
Solomenly affirm and signed before me at Tirupati on
- 04-2016.
ADVOCATE/ATTESTOR