IN THE COURT OF FOURTH ADDL JUNIOR CIVIL JUDJE KADAPA

EP NO: 103/2017

OS NO: 542/2015

CH.Vydehi … Petitioner

Vs.

V.Nagasubba Reddy …Respondent

Counter filed on behalf of the Respondent

1. This E.P is unjust and not maintainable either in law or on facts.

2. The Petitioner is to be put to strict proof on all the allegations made in the
Petition which are not expressly admitted here in by this respondent.

3. The petitioner filed E.P: 103/2017 petition against the respondent for
realization of amount of RS: 2, 53,849/- by selling the E.P schedule property. The
E.P: 103/2017 item No:1 property does not belong to the respondent. Smt.Varanasi
Devi purchased item No: 1 property on 27-12-2007 from Radhappalli Narayana
Reddy under registered sale deed No: 849/2007 dated 27-12-2007 for RS: 57, 000/-
and that Varanasi Devi mortgaged item NO: 1 property to S.B.I yarramukkapalli for
RS:30,00,000/- for construction of ground floor and 3 floors for the purpose of
public school. So the respondent is not the owner of item NO: 1 property of
Varanasi Devi for realization of EP amount.

4. The E.P items 2 and 3 were mortgaged to sreerama finance company

during 2013 year by the respondent and borrowed RS:20,00,000/- (Rupees twenty
lakhs) for his private business. So the items 2 and 3 are in the mortgage from 2013
year and that the attachment by the Petitioner during 2015 year is not valid and
those items 2 and 3 cannot be sold for realization of E.P amount without redeeming
that registered mortgage of finance company. The first item of E.P property does
not to being to the respondent but that item NO:1 property belongs to Smt.Varanasi
Devi. The E.P items 2 and 3 are encumbered by registered mortgage deed of 2013
year in favor sreerama finance company of kadapa city for RS:20,00,000/-. So the
Petitioner has no right or authority to sell the E.P schedule property. The
respondent filed I.P: 14/2016 in Addl senior Civil Judge court at kadapa against the
petitioner by showing the name of the petitioner and this E.P amount. So this E.P
amount is covered in I.P:14/2016 on the file of Addi Senior Civil Judge Kadapa.
 5. PRAYER: Therefore the respondent prays that the Honourble court may be
pleased to dismiss this EP:103/2017 in the interests of Justice.

The above stated facts are verified and those facts are true and correct and
signed this at kadapa on -10-2017

Advocate for the Respondent

List of documents filed:-

1. Copy of sale deed no 849/2007 dated 27-12-2007 executed in favor

Smt.Varanasi Devi by Rachapalli Narayana Reddy for E.P schedule item
NO:1 property.

Advocate for the Respondent

 IN THE COURT OF FOURTH ADDL

JUNIOR CIVIL JUDJE KADAPA

EP NO: 103/2017

OS NO: 542/2015

CH.Vydehi
… Petitioner

Vs.

V.Nagasubba Reddy
…Respondent

Counter filed on behalf

of the Respondent

FILED BY:-
SRI.K. VENKATA REDDY, B.Com. B.L.,
Advocate for the Respondent
KADAPA