By Regd Post with Ack-due

Kadapa,
26-05-2018.
From:-
Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District,
Pin code: 516001.
To:-
Sri.M.V.Bali Reddy B.A., B.L
Advocate
House No:12532, L.I.G.H - 2,
A.P.G.H Colony,
Yerramukkapalle Post,
Kadapa city,
Pin code: 516004.
Sir,
Sub: Reply notice for your legal notice dated 19-05-2018 – Rg.
Under the instructions and on behalf of my client Smt. Langaluru
Kantamma Widow of Dharmaiah milk vendor residing at Door No.
38/6264, Achrala colony, near Ramanjaneya Puram, Sankarapuram post,
Kadapa city, I herely issue this reply notice to you with the following facts
for your legal notice dated 19-05-2018 issued on behalf of your clients
1.Nakkala Venkata Siva Reddy and his wife, 2. Sarada residing at Achrala
colony near Ramanjaneya Puram Kadapa city.
1. Your notice schedule property in S.No. 474 extent 0.02 cents
in not mentioned in O.S No. 780/2017 suit filed by my client. The
property of my client is situated in S.No. 424/2 extent 0.02 cents plot No.
90 with the following boundaries.
East : Road
West : Site of Sreenu
North : Vacant site
South : Site of Yarramma
The above said property in S.No. 424/2 extent 0.02 cents plot No.
90 belongs to my client and does not belong to either to Smt.P. Jayamma
or to Smt.P. Jayalakshmi. Your clients are illegally and without any right
demanding my client to give consent letter to electricity department for
cancellation H.S.C connection 121904 dated 01-05-2018. Why should my
client give consent letter for cancellation?
My client intentionally with all the rights made an application for
current supply to her property and that the electricity department was
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pleased to order current supply to my client and current supply was
legally given to my client. The alleged owner Jayamma and Jayalakshmi
are not opposing my client and never questioned the right of my client
over the property of my client.
2. The alleged property of Smt.P. Jayamma is having the
following boundaries without any plot number
East : Road
West : Site of Chandrasekhar Reddy
North : Site of Achari
South : Site of Jayalakshmi.
The alleged property of Smt.P. Jayalakshmi is having the following
boundaries without any plot number.
East : Road
West : Site of Chandrasekhar Reddy
North : Achari site
South : Site of Guraaiah
Hence, the said Smt. Jayamma and Smt. Jayalakshmi have no right
or authority over the property of my client. The Tahsildar of Kadapa did
not grant D.Form No. 266/1418 and and D.Form No. 273/1418 in the
names of Smt. Jayamma and Smt. Jayalakshmi at any point of time and
that those two women are not at all enjoying the property of my client as
shown in para No. 1 of this reply notice. The Tahsildar of Kadapa did not
state anywhere about the delivery of your notice schedule property to
Smt.P. Jayamma and Smt.P. Jayalakshmi. Your notice schedule property is
100% differing from that of the property shown in the alleged D.K.T
Forms of Smt.P. Jayamma and Smt.P. Jayalashmi. The Tahsildar of Kadapa
gave possession certificate to my client as per the D.K.T Form No.
2896/1417 dated 20-04-2008 for the property in S.No 424/2 plot No. 90.
The said Smt.P. Jayamma and Smt.P. Jayalakshmi are not in possession of
property mentioned in their D.K.T forms. My client is in exclusive
possession of the property in S.No.424/2 extent 0.02 cents in plot No. 90.
3. The Assistant Engineer of A.P.S.P.D.C.L Sankarapuram Kadapa
city has every right to provide electricity to my client since my client got
injunction order in O.S No. 780/2017 on 29-12-2017 against your clients
and 3 others since my client submitted her D.K.T patta and injunction
order of court to the Assistant Engineer of A.P.S.P.D.C.L Sankarapuram
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Kadapa city. There is no illegality in giving current supply to my client
since my client is the law full owner of her property shown in her D.K.T
patta No. 2896/1417 dated 20-04-2008. Your client No.2 named Sarada
has no D.K.T patta for the property of my client. Your client Sarada has no
right or authority to ask for current supply and apply through MEE-SEVA
for paying charges of Rs. 1,910/- for getting current supply to the
property of my client. Langaluru Kantamma who is my client is the
rightful owner to D.K.T No. 2896/1417 dated 20-04-2008 property.
4. You are alleging that Jayamma and Jayalakshmi are the
owners of your notice schedule property. Then that Jayamma and
Jayalakshmi should have come to the Assistant Engineer for current
supply by paying required charge. The Jayamma and Jayalakshmi did not
approach Assistant Engineer for current supply to your notice schedule
property since they are not the owners of your notice schedule property.
5. Therefore please take this reply notice and please advise your
clients not to venture in speculative litigation since your client have no
title or right over your notice schedule property or the property of my
client covered under her D.K.T patta No. 2896/1471 dated 20-04-2008.
My client will take appropriate civil and criminal action against your
clients if your clients continue to harass and torment my clients in spite of
this clear-cut reply notice by holding your clients liable for costs and
consequences and costs of Rs. 2,000/- of this reply notice.

(K.Venata Reddy)
Advocate
Copy to the following authority for information and necessary
action.
The Assistant Engineer, A.P.S.P.D.C.L Sankarapuram, Kadapa city.